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EU AI Act Article 47: the EU declaration of conformity

Article 47 requires the provider of a high-risk AI system to draw up a written EU declaration of conformity for each system, and to keep it at the disposal of national authorities for ten years after the system is placed on the market or put into service. The declaration must state that the system meets the requirements of Chapter III Section 2, follow the content set out in Annex V, be translated into the languages required by the Member States where the system is made available, and be kept up to date as the system changes.

Who it applies to

Providers of high-risk AI systems under Article 6, and any distributor, importer, or deployer who becomes a provider under Article 25. The obligation runs alongside CE marking and registration once the relevant high-risk deadlines apply — 2 August 2026 for most Annex III systems, 2 August 2027 for Annex I products.

What evidence this implies

The declaration itself is a document, but it is only as credible as what backs it: the technical documentation under Annex IV, the conformity assessment outcome under Article 43, and — increasingly, in practice — the ability to show that the deployed system actually matches what was assessed. "Up to date" means the declaration needs to be revised, and re-justified, whenever the system materially changes.

Gaps to state honestly

The Regulation does not require the declaration to include run-level logs, and a signed piece of paper says nothing about how the system has behaved since it was signed. A declaration that isn't backed by any way to check ongoing behavior is a claim, not evidence.

How Vetro helps

Vetro does not draft the declaration of conformity. It records, in a hash-chained, ed25519-signed ledger, what the system actually did — which model, which tools, which policy version, on every run — so the declaration's claims can be checked against reality over time, not just at signing. Vetro Attest verifies a ledger or OTLP GenAI trace for free and, for 29 USD, issues a counter-signed report mapping that evidence to the EU AI Act. This is technical evidence, not legal advice.

Not sure if Article 47 applies to your system? Run it through 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.