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EU AI Act Article 16: the full list of provider obligations

Article 16 is the index of provider duties for high-risk AI systems. It does not create new requirements by itself; it points to the articles that do: ensure the system complies with Chapter III Section 2 (Article 8), have a quality management system (Article 17), keep technical documentation (Article 18), keep the logs automatically generated by the system when under the provider's control (Article 19), undergo conformity assessment before placing on the market, draw up the EU declaration of conformity (Article 47), affix CE marking, register in the EU database (Article 49), and take corrective action when the system is found non-compliant (Article 20).

Who it applies to

Providers of high-risk AI systems as classified under Article 6, and anyone who becomes a provider by rebranding or substantially modifying a system, per Article 25. Most of Article 16 applies from 2 August 2026 for the systems listed in Annex III, and from 2 August 2027 for AI systems that are safety components of products covered by Annex I.

What evidence this implies

Article 16 is a checklist, so the evidence is the sum of the evidence for each linked article: a QMS record, a technical documentation file, retained logs, a declaration of conformity, a registration entry, and a record of any corrective action taken. An auditor asking "are you compliant with Article 16" is really asking for all of these at once, cross-referenced to the same system version.

Gaps to state honestly

Article 16 does not tell you how to produce the underlying records, only that you must have them. A tool that logs API calls is not automatically a QMS, a technical documentation file, or a declaration of conformity. Each of those has its own required content, and log data can support but not replace them.

How Vetro helps

Vetro writes every model call, tool call and policy decision to a hash-chained, ed25519-signed ledger that anyone can verify with the public key. It does not draft your QMS or your declaration of conformity, but it gives you the run-level evidence — logs, retention, tamper-evidence — that those documents need to reference. Vetro Attest verifies a ledger or OTLP GenAI trace for free and, for 29 USD, issues a counter-signed report mapping the evidence to the EU AI Act, including an explicit list of what the log cannot show. This is technical evidence, not legal advice.

Not sure if your system is high-risk in the first place? Start with the high-risk classifier or the free checker.

See a sample ledger verified in one click, check your own logs free or get the countersigned EU AI Act report.