How do companies prove compliance for their AI deployments?
To prove AI Act compliance, companies must map their AI usage across workspaces, maintain always-ready documentation including technical files and conformity assessments, register in the EU database, and continuously monitor for changes over a 10-year retention period.
To prove compliance for their AI deployments under the EU AI Act, companies must treat compliance as an ongoing operational process that attaches to real-world deployments, rather than just evaluating abstract AI models in isolation.
Companies must take a structured approach to generate, maintain, and present specific documentation and evidence to auditors, enterprise customers, and regulatory authorities.
1. Mapping and scope definition
Because obligations depend entirely on how an AI system is used, companies must first map their AI usage across their distinct operational perimeters (workspaces). By clearly identifying underlying AI assets and evaluating how they are actually used in practice, by whom, and for what purpose, a company can correctly identify whether they are acting as a provider, deployer, or both.
2. Maintaining "always-ready" documentation
To prove compliance, companies must centralize specific evidence and documentation for each workspace and deployment. Depending on their role, this involves several formal requirements:
- Providers of high-risk systems must establish a documented quality management system (outlining policies for design, testing, data management, and risk management).
- Providers must draw up comprehensive technical documentation before the system is put into service, detailing the system's architecture, training data, algorithmic logic, cybersecurity measures, and human oversight mechanisms.
- Providers must successfully complete a conformity assessment procedure to prove the system meets all safety and fundamental rights requirements. Once passed, they must draw up an EU declaration of conformity and affix a visible CE marking to the product or its documentation.
- Deployers of high-risk systems must maintain documentation tracking their implementation of human oversight measures and monitoring controls.
- Deployers in specific high-risk scenarios (such as bodies governed by public law or entities providing essential public services) must perform and document a fundamental rights impact assessment prior to deploying the system, and notify the market surveillance authority of the results.
- Both providers and deployers are required to keep automatically generated logs of the AI system's operations to ensure traceability.
3. Registration in the EU database
Providers of high-risk AI systems must register themselves and their systems in a dedicated EU database before placing them on the market or putting them into service. Deployers that are public authorities, Union institutions, or agencies must also register their use of high-risk systems in this database.
4. Ensuring continuity
Because static documents fail as soon as reality changes, AI Act compliance is not a one-time exercise. To continually prove compliance, companies must monitor changes to their AI assets, deployments, and vendors. If a system undergoes a "substantial modification" or its intended purpose changes, it may trigger the need for updated risk levels, refreshed documentation, and a brand new conformity assessment.
Most formal compliance documentation, including the technical documentation, quality management records, and EU declarations of conformity, must be kept at the disposal of national competent authorities for 10 years after the system is placed on the market or put into service.