Chapter 24 of 25
Annexes I–VI: Classification and Core Compliance Evidence
The annexes turn abstract legal duties into lists, templates and technical specifications. This module connects product legislation and serious-offence exceptions to Annex III use cases, Annex IV documentation and the formal evidence required for declarations and internal-control assessment.
A map of Annexes I-VI
From rules to evidence
Annexes I-VI turn legal architecture into lists, classifications, required records, declarations, and an internal-control assessment procedure.
The compliance chain
Annex I lists legislation; Annex II lists offences; Annex III lists high-risk areas; Annex IV records evidence; Annex V declares conformity; Annex VI checks it.
Read the labels closely
Each annex is tied to a named Article. This module follows the supplied annexes and does not add rules where their text is silent.
Annex I: Two lists of Union harmonisation legislation
Section A
"Section A. List of Union harmonisation legislation based on the New Legislative Framework" contains 12 instruments in the supplied text.
Medical devices
Section A includes "Regulation (EU) 2017/745 of the European Parliament and of the Council of 5 April 2017 on medical devices" and Regulation (EU) 2017/746.
Section B
"Section B. List of other Union harmonisation legislation" contains eight instruments, including transport, marine, rail, vehicle, and aviation regimes.
Aviation is limited
The Regulation (EU) 2018/1139 entry is limited to cases "where it concerns unmanned aircraft and their engines, propellers, parts and equipment to control them remotely".
Currency check
Signed-pending and proposed changes do not replace the supplied Annex I text today. The source's Section A and Section B positions remain the operative positions.
Annex II: The serious-offence list
The listed offences
Annex II supplies the criminal offences referred to in Article 5(1), first subparagraph, point (h)(iii); it is not framed as a general criminal-law catalogue.
Keep the wording exact
The list includes "terrorism", "trafficking in human beings", and "sexual exploitation of children, and child pornography".
International and organised crime
It also includes "crimes within the jurisdiction of the International Criminal Court" and participation in a criminal organisation involved in listed offences.
Annex III: Biometrics, infrastructure, and education
Biometrics
Area 1 applies only where use is permitted under relevant Union or national law. It lists remote identification, sensitive-attribute categorisation, and emotion recognition.
A specific exclusion
Remote biometric identification does not include biometric verification whose sole purpose is confirming that a specific person is who they claim to be.
Critical infrastructure
"AI systems intended to be used as safety components in the management and operation of critical digital infrastructure, road traffic, or in the supply of water, gas, heating or electricity" are listed.
Education
Education entries include access and admission, learning-outcome evaluation, education-level assessment, and monitoring prohibited behaviour during tests.
Annex III: Employment, services, public power, and democracy
Worked match: recruitment
Filtering CVs and scoring candidates maps to "AI systems intended to be used for the recruitment or selection of natural persons".
Worked match: lending
A consumer loan-scoring tool maps to "AI systems intended to be used to evaluate the creditworthiness of natural persons or establish their credit score".
Worked match: evidence
A police-support tool that assesses evidence reliability maps to the listed law-enforcement evidence use case.
Migration and voting
Visa or asylum eligibility assistance is listed; direct voter-influence systems are listed, while non-exposed administrative or logistical campaign tools are excluded.
Quiz: Which Annex III entry fits?
Choose the answer that most closely follows the wording of Annex III.
A university deploys AI to evaluate students' learning outcomes, and the results are used to steer each student's learning process. Which Annex III area most directly describes this use?
- Education and vocational training
- Employment, workers' management and access to self-employment
- Administration of justice and democratic processes
- Critical infrastructure
Show Answer
Answer: A) Education and vocational training
Annex III area 3(b) lists AI systems intended to evaluate learning outcomes, including where those outcomes are used to steer the learning process of natural persons in educational and vocational training institutions at all levels.
Quiz: Identify the Annex III exclusion
Test the limits of the supplied wording rather than relying on a broad intuition about biometric systems.
Which use is expressly excluded from the Annex III entry for remote biometric identification systems?
- A system whose sole purpose is biometric verification that a specific person is the person they claim to be
- A system used for emotion recognition
- A system used for categorisation based on inferred sensitive attributes
- A system used to identify people in a public space
Show Answer
Answer: A) A system whose sole purpose is biometric verification that a specific person is the person they claim to be
The supplied text states that the remote-biometric-identification entry shall not include AI systems intended for biometric verification where the sole purpose is confirming that a specific natural person is the person he or she claims to be.
Annex IV: Build the technical documentation file
The minimum rule
"The technical documentation referred to in Article 11(1) shall contain at least the following information, as applicable to the relevant AI system".
General description
Record intended purpose, provider and version, interactions, software or firmware versions, delivery form, intended hardware, interface, and instructions for use.
Design and development
Document development steps, third-party or pre-trained tools, and "the design specifications of the system, namely the general logic of the AI system and of the algorithms".
Data provenance
Where relevant, record training methods and datasets, including "information about their provenance, scope and main characteristics; how the data was obtained and selected".
Testing evidence
Validation and testing must include data, metrics, discriminatory impacts, and "test logs and all test reports dated and signed by the responsible persons".
Annex IV: From a model card to a compliance record
Marketing text is not enough
A brief product claim cannot replace Annex IV: the record must explain purpose, versions, integrations, architecture, development, data, testing, and operation.
Monitor real operation
Part 3 requires capabilities and limitations, accuracy, foreseeable unintended outcomes, risks, oversight, output interpretation measures, and input specifications.
Risk and standards
The file includes "A detailed description of the risk management system in accordance with Article 9" and standards or alternative technical solutions.
Post-market evidence
The documentation includes post-market performance evaluation and "the post-market monitoring plan referred to in Article 72(3)".
Annex V and Annex VI: Declare, verify, and assess
Annex V: identify and accept responsibility
The declaration identifies the AI system and provider, and includes "A statement that the EU declaration of conformity referred to in Article 47 is issued under the sole responsibility of the provider".
Annex V: state compliance
It includes "A statement that the AI system is in conformity with this Regulation" and, for personal-data processing, the specified data-protection compliance statement.
Annex VI: quality management
"The provider verifies that the established quality management system is in compliance with the requirements of Article 17."
Annex VI: technical assessment
"The provider examines the information contained in the technical documentation in order to assess the compliance of the AI system" with relevant essential requirements.
Flashcards: Annexes I-VI recall
Flip each card, then explain how the item fits into the classification-to-evidence chain.
- What are the two headings in Annex I?
- "Section A. List of Union harmonisation legislation based on the New Legislative Framework" and "Section B. List of other Union harmonisation legislation".
- What is the limited civil-aviation wording in Annex I?
- "where it concerns unmanned aircraft and their engines, propellers, parts and equipment to control them remotely".
- Name three Annex II offences using the source wording.
- "terrorism"; "trafficking in human beings"; and "sexual exploitation of children, and child pornography".
- What Annex III wording covers applicant filtering and candidate evaluation?
- "AI systems intended to be used for the recruitment or selection of natural persons".
- What does Annex IV require at minimum?
- "The technical documentation referred to in Article 11(1) shall contain at least the following information, as applicable to the relevant AI system".
- What must Annex VI point 2 verify?
- "The provider verifies that the established quality management system is in compliance with the requirements of Article 17."
Key Terms
- Annex I
- The supplied list of Union harmonisation legislation, divided into Section A and Section B.
- Annex V
- The required contents of the EU declaration of conformity referred to in Article 47.
- Annex II
- The supplied list of criminal offences referred to in Article 5(1), first subparagraph, point (h)(iii).
- Annex IV
- The technical-documentation content required by Article 11(1), as applicable to the relevant AI system.
- Annex VI
- The conformity assessment procedure based on internal control.
- Provider
- The actor that Annex V identifies as bearing sole responsibility for issuing the EU declaration of conformity, and that Annex VI requires to perform specified verification and assessment activities.
- Annex III
- The supplied list of high-risk AI-system areas referred to in Article 6(2).
- Harmonised standards
- Standards whose references have been published in the Official Journal of the European Union, listed in Annex IV where applied in full or in part.
- Technical documentation
- The documented evidence set described in Annex IV, covering the AI system, its development, data where relevant, testing, risks, standards, changes, declaration, and post-market arrangements.
- Post-market monitoring plan
- The plan referred to in Article 72(3), which Annex IV requires as part of the detailed post-market performance-evaluation system.