What a customer can ask you to prove: an AI Act evidence checklist for providers

When a customer, auditor or procurement team reviews a high-risk AI system, the questions tend to map onto the same provisions. Here are 14 of them, with the evidence worth keeping for each.

Dates as published. High-risk requirements for Annex III systems apply from 2 December 2027, and for product-linked (Annex I) systems from 2 August 2028. Article 50 transparency has applied since 2 August 2026, with content marking for systems already on the market before that date due by 2 December 2026. Source: Regulation (EU) 2026/1744.

The checklist

Use it as a supplier questionnaire in either direction: as a provider, to check what you can show; as a deployer, to check what your vendor can show.

QuestionProvisionEvidence to keep
Is this system high-risk, and who decided?Art. 6, Annex IIIDated classification memo: intended purpose, Annex III area, rationale, named owner, review date.
Are you the provider or the deployer of this system?Art. 3(3)–(4), Art. 25Role map per system and per customer, with the matching contract clauses. Check the Art. 25 triggers: your own name or trademark on the system, a substantial modification, or a change of intended purpose.
Is risk managed as a continuous process?Art. 9Risk register covering intended use and reasonably foreseeable misuse; named risk owners; test results against defined thresholds; residual risks; scheduled reviews.
What data was the system built and tested on?Art. 10Dataset documentation: provenance, selection criteria, bias examination, known gaps.
Is there technical documentation?Art. 11, Annex IVA documentation package kept up to date and available to authorities.
Does the system keep logs?Art. 12Logging specification: events recorded, retention period, access controls.
What do deployers receive to use it correctly?Art. 13Instructions for use: intended purpose, performance levels and limitations, human-oversight measures.
Can a person meaningfully oversee and override it?Art. 14Oversight design: who can intervene, how, and with what information; measures against over-reliance on the output (automation bias).
How accurate, robust and secure is it?Art. 15Test reports, declared accuracy metrics, resilience and cybersecurity testing.
Is there a quality management system?Art. 17 (see Art. 40)QMS documentation. A presumption of conformity can only come from harmonised standards whose references are published in the Official Journal; check what is currently cited before relying on one.
Has conformity been assessed and declared?Arts. 43, 47–49Conformity assessment record, EU declaration of conformity, CE marking and registration where required.
What happens after launch?Arts. 72–73Post-market monitoring plan; serious-incident procedure and contacts.
Do the people operating it know what they are doing?Art. 4AI literacy training records by role.
Do users know they are dealing with AI?Art. 50Disclosure design; content-marking approach for generative systems.
Check the text. Article references follow Regulation (EU) 2024/1689 as originally numbered. Regulation (EU) 2026/1744 amends dates and some provisions: verify numbering and wording against the current consolidated text on EUR-Lex before relying on this page. Not legal advice.

Provider or deployer first

Every other row depends on the second one. A deployer can become a provider by putting its own name or trademark on a high-risk system, by making a substantial modification, or by changing the intended purpose of a system so that it becomes high-risk. We cover those triggers in You're Probably Both: Provider and Deployer Under the EU AI Act, and the terms are defined in the glossary.

From checklist to working file

If you want this as a structured vendor review rather than a list, the EU AI Act Vendor Risk Assessment & Due Diligence Toolkit is available on Gumroad. For questions about a specific use case, write to venactis@proton.me.

Dates as published in the Official Journal. Not legal advice.