Annex IV: What Technical Documentation Do You Need for AI?

What Annex IV Requires

Annex IV is essentially a detailed table of contents for the documentation package that must accompany every high-risk AI system. It requires a general description of the AI system, detailed information about system development, monitoring and control features, risk management documentation, changes to the system over its lifecycle, and information about how the system was validated and tested.

This documentation serves two purposes: it allows regulators to evaluate whether the AI system complies with the law, and it enables deployers to understand what they're working with.

Provider Documentation vs. Deployer Documentation

The heavy documentation burden falls on AI providers — the companies that build and sell AI systems. They need to create comprehensive technical documentation covering how the system was designed, built, tested, and validated. This is the vendor's responsibility.

As a deployer, your documentation needs are lighter but still important. You should maintain records of what AI systems you use and for what purposes, your risk assessments, your human oversight arrangements, training records for staff who use AI, any incidents or problems you've encountered, and correspondence with your AI vendor about the system's performance.

Practical Documentation Tips

Don't make documentation harder than it needs to be. Create a simple filing system — digital folders organized by AI tool — where you keep all relevant documents. Use templates to standardize your records. Update your documentation whenever something changes — a new tool, a new use case, a new team member, or an incident.

Keep your documentation accessible but secure. You may need to share it with regulators, but it may contain sensitive business information. Regular backups and access controls are good practice.

What to Request From Your Vendor

When you purchase or subscribe to a high-risk AI system, ask your vendor for a summary of their technical documentation, instructions for use, information about the system's capabilities and limitations, data governance practices, and contact information for reporting issues. A good vendor will provide these proactively. If they can't or won't provide basic documentation, consider it a serious risk factor.

This article is for informational purposes only and does not constitute legal advice. Regulatory requirements change frequently — verify current rules with official sources. Built by Sawai Gyoseishoshi Office, Hiroshima, Japan.