Skip to content
SimpleAct Logo

Guide · AI audit

Updated 6 October 2026 · after the Digital Omnibus

AI Act audit preparation: a practical playbook

Who audits your AI – and what will they ask for first? This guide separates conformity assessment, requests from authorities and audits, lists the documents for the auditor’s file and shows how to turn gaps into an action plan with owners and due dates.

  • Who audits what – five types of review
  • Auditor’s file with articles and retention
  • Audit playbook: actions, owners, status
  • Readiness check with the three largest gaps
app.simpleact.de

Audit Log & Export

247 of 312 entries

A

Audit readiness

Audit-ready

Complete

Partial

Missing

EU Declaration of Conformity (Art. 47)

PDF · DE/EN · incl. audit history

ActionEntityEvent
UPDATERisk AssessmentRe-assessment completed
CREATEEvidenceEvidence "DPIA report" added
UPDATEGovernanceApproved by reviewer
CREATEAI SystemSystem "Chatbot Lia" created

Short answer

The AI Act has no general “AI audit”. Compliance is reviewed through conformity assessment (Art. 43), market surveillance (Art. 74) and reasoned requests from authorities (Art. 21, Art. 26(12)); internal audit and customer audits come on top. Preparing means organising inventory, classification, documentation, logs and oversight so that every requirement can be evidenced.

Context

What people mean by “AI audit” – and what they don’t

Inside a company, anything that looks like scrutiny gets called an audit: a large customer asking about your AI use, an internal audit questionnaire, a conversation with the data protection authority. The AI Act (Regulation (EU) 2024/1689) barely uses the word. It speaks of conformity assessment – the process of assessing whether a high-risk AI system meets the requirements of Chapter III, Section 2 (Art. 3(20)). And it speaks of market surveillance by national authorities (Art. 74). Audits are expressly mentioned, for example, where a notified body regularly checks a provider’s approved quality management system (Annex VII, point 5.3).

For your preparation this distinction is not hair-splitting. A provider has to initiate conformity assessment itself before placing a system on the market. A request from an authority comes from outside, often with a short deadline, and incorrect or incomplete answers can be fined in their own right (Art. 99(5)). A customer audit, by contrast, follows the contract – the AI Act sets neither its scope nor its procedure. Knowing which kind of review is coming tells you which documents you need and in how much depth.

The good news: the documents overlap heavily. An up-to-date AI inventory, a reasoned classification for each system, the technical documentation or the providers’ instructions for use, retained logs, named oversight persons and evidence of AI literacy measures carry you through almost any review. This guide sorts them by type of review, names the articles and shows how to work through missing items as actions with an owner, a due date and a status.

On timing: since the Digital Omnibus (Regulation (EU) 2026/1744, in force since 27 July 2026), the high-risk requirements apply to Annex III systems from 2 December 2027 and to Annex I products from 2 August 2028 (Art. 113(c)). Already reviewable today are the prohibitions (Art. 5) and AI literacy (Art. 4), both since 2 February 2025, and the transparency obligations under Art. 50 since 2 August 2026. An audit playbook pays off now – not just before the deadline.

Retention of technical documentation, QMS documentation, declaration of conformity (Art. 18, Art. 47)
10 years
Retention of technical documentation, QMS documentation, declaration of conformity (Art. 18, Art. 47)
Logs kept by providers and deployers (Art. 19, Art. 26(6))
≥ 6 mo.
Logs kept by providers and deployers (Art. 19, Art. 26(6))
High-risk obligations for Annex III systems (Art. 113)
2 Dec 2027
High-risk obligations for Annex III systems (Art. 113)

Legal basis

The provisions that decide what an auditor may see

The table lists the provisions that authorities, notified bodies and your own preparation rely on. Chapter III obligations for high-risk systems become practically relevant from 2 December 2027 (Annex III) or 2 August 2028 (Annex I).

Scroll the table sideways →

The provisions that decide what an auditor may see
ProvisionContentApplies toWhat it means for a review
Art. 3(20), (22)Conformity assessment is the process of assessing whether the requirements for high-risk AI are met; a notified body is a conformity assessment body that has been notified.ProvidersMakes clear that “audit” is not a legal term of its own. Always ask first which basis a review relies on.
Art. 4Providers and deployers take measures to support the development of AI literacy among their staff; no particular level has to be guaranteed.Providers, deployersApplies since 2 Feb 2025. Auditors ask for measures and evidence: who, which content, when.
Art. 6(3), (4)An Annex III system can be considered not high-risk where there is no significant risk; the provider documents the assessment before placing it on the market, registers under Art. 49(2) and provides the documentation on request.ProvidersA frequent review point: anyone relying on the exception needs a dated, reasoned assessment.
Art. 11 · Annex IVTechnical documentation drawn up before placing on the market, kept up to date, with at least the information in Annex IV; SMEs and small mid-caps may use a simplified form.ProvidersThe core document of every conformity assessment and authority review.
Art. 17Quality management system covering, among other things, change management, test and validation procedures, risk management, post-market monitoring, incident reporting, communication with authorities and an accountability framework – proportionate to size.ProvidersUnder Annex VII, the subject of regular audits by the notified body.
Art. 18, 19Keep technical documentation, QMS documentation, approved changes, decisions of notified bodies and the declaration of conformity for 10 years; keep logs for at least six months.ProvidersAuditors ask where things are stored, which versions exist and who has access – not only about content.
Art. 21Upon a reasoned request, providers supply all information and documentation needed to demonstrate conformity, in a language easily understood by the authority; access to logs where applicable.ProvidersThe typical “request from an authority”. Define the routine and the contact person in advance.
Art. 26Deployers use the system in line with the instructions for use, assign oversight to competent persons, monitor operation, keep logs for at least six months, inform workers and cooperate with authorities (para. 12).DeployersFor most mid-sized companies the main review point: evidence of proper operation.
Art. 43 · Annex VI, VIIAnnex III points 2–8: internal control without a notified body. Annex III point 1: internal control or notified body, depending on the use of harmonised standards. New assessment after a substantial modification.ProvidersDecides whether an external assessor is involved at all.
Art. 44Certificates from notified bodies are valid for at most five years (Annex I) or four years (Annex III); suspension or withdrawal where requirements are no longer met.ProvidersValidity periods and follow-up audits belong in the review calendar.
Art. 47–49EU declaration of conformity (kept for 10 years), CE marking, registration in the EU database before placing on the market or putting into service.Providers, public deployersFormal evidence – quick to check and embarrassing when missing.
Art. 72, 73Post-market monitoring based on a plan (part of Annex IV); reporting of serious incidents within 15 days at the latest, 2 days for a widespread infringement or critical infrastructure, 10 days in the event of a death.Providers (deployers via Art. 26(5))Auditors want to see that data from operation is actually analysed.
Art. 74(12), (13)Market surveillance gets access to the documentation and to training, validation and testing data sets, where appropriate via API or remotely; source code only upon a reasoned request when other means have been exhausted.ProvidersData sets and their origin must be retrievable – not merely described.
Art. 99(5)Incorrect, incomplete or misleading information supplied to notified bodies or competent authorities: up to €7.5 million or 1 % of worldwide annual turnover; for SMEs the lower amount.All operatorsAn honest gap with an action plan beats a polished answer.
KI-MIG § 2 (Germany)The Federal Network Agency is the competent market surveillance authority unless otherwise provided; BaFin for AI directly connected with regulated financial activities; authorities for Annex I products remain competent.Everyone in GermanyTells you where a request will realistically come from.

Article texts checked on 6 October 2026 in the consolidated version after Regulation (EU) 2026/1744. Summaries are abridged; the wording in the Official Journal prevails.

How it works

From the reason for the review to a closed finding

Seven steps that work for a request from an authority, a customer audit and internal audit alike. The depth depends on the type of review, the order does not.

  1. 1

    Clarify the reason and the basis

    Decision

    Who is reviewing, on what basis, with which deadline? A request from the Federal Network Agency under Art. 21 calls for a different answer than a supplier questionnaire. With authorities, always ask in writing for the exact question and note the deadline.

    Who
    Compliance, legal
    Output
    Review brief with basis, scope, deadline
    Basis
    Art. 21, 26(12), 74
  2. 2

    Set the scope and a reference date

    Which AI systems are affected, in which role (provider, deployer), as of which date? Without a reference date the auditor compares documents from different points in time – the most common cause of follow-up questions.

    Who
    Compliance, IT
    Output
    System list with role and reference date
    Basis
    Art. 3(3), (4) · Art. 25
  3. 3

    Assemble the auditor’s file

    Bring inventory, classifications, technical documentation or instructions for use, QMS, logs, oversight concept, literacy evidence, incident register and formal evidence together in one place – versioned, with storage location and owner.

    Who
    System owners, compliance
    Output
    Auditor’s file with a table of contents
    Basis
    Art. 11, 17, 18, 19, 26
  4. 4

    Self-assessment and gap list

    Check every requirement against the file: evidenced, partly evidenced, missing. Stay honest – a documented gap with an action is easier for any auditor to place than a claim without evidence.

    Who
    Compliance, internal audit if available
    Output
    Gap list per system and article
    Basis
    Art. 43 · Annex VI
  5. 5

    Set up the audit playbook

    Decision

    Every gap becomes an action with an owner, a due date, a priority and a status. Anything deliberately deferred gets a justification. The result is the action plan you can show the auditor.

    Who
    Compliance, business units
    Output
    Action plan with status
    Basis
    Art. 17(1)(a), (m)
  6. 6

    Dry run on a sample

    Recommendation: pick one system and review it the way an outsider would – request the documents, retrieve one day’s logs, interview the oversight person. Shows whether the file holds up when it matters.

    Who
    Internal audit or a colleague from another team
    Output
    Dry-run record
    Basis
    Recommendation
  7. 7

    Accompany the review and follow up

    Name one contact person, log every document handed over, turn findings into new actions and record the closure. With authorities, approve answers before they are sent.

    Who
    Compliance, management
    Output
    Handover log, findings list, closing note
    Basis
    Art. 21 · Art. 99(5)

For providers with a notified body (Annex VII), this sequence does not replace the body’s procedure – it prepares for it.

Who audits what

Five types of review – and what each one asks for

Before you collect documents, find out who is asking. The basis decides the scope, the deadline and the consequences of an incomplete answer.

Scroll the table sideways →

Types of review by trigger, basis and requested documents
Type of reviewTypical triggerBasisWhat is requested first
Market surveillance authority (in Germany usually the Federal Network Agency, BaFin in the financial sector)Complaint (Art. 85), incident report, sweep, tip-off from the marketArt. 74 with Regulation (EU) 2019/1020, Art. 21, Art. 26(12), KI-MIG § 2Technical documentation, declaration of conformity, logs; for providers possibly training, validation and testing data (Art. 74(12))
Notified bodyConformity assessment under Annex VII, regular surveillance audits, renewal of the certificateArt. 43, Art. 44, Annex VII points 3–5QMS documentation under Art. 17, technical documentation per system, access to premises used for design, development and testing
Internal control by the provider itselfBefore placing a high-risk system under Annex III points 2–8 on the market; after a substantial modificationArt. 43(2), (4) · Annex VICheck of QMS, technical documentation and post-market monitoring – the provider assesses itself and is accountable for it
Internal auditAudit plan, mandate from management or the supervisory board, an incidentCompany law, internal policies – not the AI ActInventory, roles and responsibilities, classifications, action plan with status
Customer or supplier auditTender, contract renewal, the customer’s own duties as a deployerContract, data processing agreement, purchasing termsClassification, instructions for use, input for the customer’s DPIA (Art. 26(9)), incident process
Statutory auditor, certification body (e.g. ISO/IEC 42001)Audit of IT-supported processes in the annual audit, voluntary certificationEngagement letter or standard requirementsManagement system, roles, risk assessment, control evidence – does not replace conformity assessment under Art. 43

In addition, the data protection authority reviews under the GDPR whenever personal data is processed. Many documents (DPIA, records of processing) overlap, but the legal basis is different.

Distinctions

Conformity assessment, request from an authority, audit: three different things

Art. 43

Conformity assessment

A procedure initiated by the provider before a high-risk system is placed on the market. It results in the declaration of conformity and CE marking. Deployers do not carry out conformity assessment.

Art. 21 · 74

Requests and market surveillance

Triggered from outside, often by a specific event. The authority sets scope and deadline. Incorrect or incomplete information is itself subject to fines (Art. 99(5)).

Annex VII 5.3

Surveillance audit by the notified body

The one place where the AI Act expressly speaks of regular audits: the body checks that the approved QMS is maintained and applied, and may carry out additional tests.

Contract

Customer and supplier audits

The scope follows from the contract. Often the customer, as a deployer, wants to know whether it can meet its own Art. 26 duties – instructions for use, logs and incident process.

Internal

Internal audit

Checks whether your own organisation works: responsibilities, approvals, action tracking. A good dress rehearsal for any external review.

Art. 85

A complaint as the trigger

Any natural or legal person may lodge a complaint with the market surveillance authority. Many requests start here – without any warning to the company.

Auditor’s file

The documents an auditor wants to see first

The order reflects what is requested first in practice: the overview, then the reasoning, then the evidence from operation.

Scroll the table sideways →

Documents in the auditor’s file with article, role and retention
DocumentArticleProvider / deployerRetention
AI inventory with purpose, owner, provider, roleBasis for Art. 4, 6, 16, 26bothRecommendation: always current, version the snapshots
Classification per system with reasoning and dateArt. 5, 6, 50bothRecommendation: as long as the system is in use, plus the documentation period
“Not high-risk” assessment under Art. 6(3)Art. 6(4), Art. 49(2)providerDrawn up before placing on the market, provided on request
Technical documentation under Annex IVArt. 11, 18provider10 years from placing on the market / putting into service
QMS documentationArt. 17, 18provider10 years
Risk management documentationArt. 9 · Annex IV point 5providerPart of the technical documentation (10 years)
Post-market monitoring planArt. 72 · Annex IV point 9providerPart of the technical documentation
EU declaration of conformity, CE, proof of registrationArt. 47, 48, 49providerDeclaration of conformity 10 years
Decisions and certificates of notified bodiesArt. 18, 44provider (Annex VII)10 years; certificate valid for max. 4 or 5 years
Automatically generated logsArt. 12, 19, 26(6)both, as far as under their controlat least 6 months, longer where other law requires
Provider’s instructions for use and evidence of use in line with themArt. 13, 26(1)deployerRecommendation: as long as in use
Oversight concept with named persons and authorityArt. 14, 26(2)bothRecommendation: version the snapshots
AI literacy evidence (participants, content, date)Art. 4bothNo statutory period; recommendation: for the duration of the role
Information of worker representatives, DPIA, FRIA where requiredArt. 26(7), (9) · Art. 27deployerKeep DPIA and FRIA current; FRIA result goes to the authority
Incident register, reports, corrective actionsArt. 20, 26(5), 73bothRecommendation: at least as long as the technical documentation
Action plan (audit playbook) with status and justificationsArt. 17(1)(a), (m) (providers)bothRecommendation: export a snapshot at every review date

Periods without an article reference are recommendations. Set by law are the 10 years under Art. 18 and Art. 47 and the minimum of six months under Art. 19 and Art. 26(6).

Interactive

Audit readiness check: where would an auditor dig first?

Answer the statements for your organisation or a single system. Choose your role – the check then shows only the statements that apply. The result shows the status per area and the three documents an auditor would most likely request first.

Your role
  1. 01Inventory & rolesWe have an up-to-date AI inventory with purpose, business unit, provider and responsible person for each system.
  2. 02Inventory & rolesFor each system we have recorded whether we are provider or deployer – including possible role changes through our own brand or a substantial modification.
  3. 03ClassificationEvery classification (prohibited, high-risk, transparency obligation, minimal) is reasoned, dated and assigned to a person.
  4. 04ClassificationWhere we classify an Annex III system as not high-risk, the written assessment exists and registration has been dealt with.
  5. 05DocumentationFor each high-risk system there is versioned technical documentation with the information in Annex IV.
  6. 06DocumentationOur quality management system is documented in writing – including change management, testing, incident reporting and communication with authorities – and is applied.
  7. 07DocumentationThe conformity assessment procedure has been chosen; declaration of conformity, CE marking and registration are planned or done.
  8. 08DocumentationWe have the providers’ instructions for use and can show which measures we take to use the system in line with them.
  9. 09Operation & logsAutomatically generated logs are kept for at least six months, and we can retrieve the logs for a given day quickly.
  10. 10Operation & logsA post-market monitoring plan is part of the technical documentation, and feedback from operation is analysed.
  11. 11Operation & logsWe monitor operation on the basis of the instructions for use and report anomalies to the provider.
  12. 12Oversight & literacyFor each high-risk system, persons with an oversight role are named, authorised to stop or override the system, and trained for it.
  13. 13Oversight & literacyAI literacy measures are evidenced: who took part, which content, when.
  14. 14Oversight & literacyWorker representatives and staff were informed before workplace use; a DPIA and – where required – a FRIA exist.
  15. 15Incidents & authoritiesA procedure for serious incidents is in place: who recognises, who reports, which deadline (2, 10 or 15 days) applies.
  16. 16Incidents & authoritiesFor requests from authorities there is a contact person and a routine: record deadlines, review and approve answers, log handovers.
app.simpleact.de

Your result

0 of 16 statements answered

A

No answers yet

–

Answer the statements – your result appears here.

Status per area

  • Inventory & roles0%
  • Classification0%
  • Documentation0%
  • Operation & logs0%
  • Oversight & literacy0%
  • Incidents & authorities0%

What an auditor would request first

Answer the statements – the three largest gaps will appear here with a concrete next step.

Self-assessment without warranty. The check does not replace a review, a conformity assessment or legal advice. Your answers are not stored or transmitted.

Building the audit playbook

Turning the gap list into an action plan

An audit playbook is simply an action plan that ties every gap to a person, a due date and a piece of evidence. What matters is that it also shows what was deliberately not done – and why.

Auditors rarely expect perfection. They want to see that you know your gaps and manage them. A plan with twenty open items, each with an owner, a realistic due date and a justification, is more convincing than a checklist where everything is ticked but no evidence sits behind the ticks.

Prioritise with two questions: how serious is the gap for health, safety or fundamental rights? And how quickly would an auditor find it? Missing logs, a missing classification or a high-risk system without a named oversight person stand out in any sample. Wording issues in the technical documentation can wait.

Example: an engineering company deploys an AI tool that pre-screens job applicants (Annex III point 4) and does not keep logs for six months. Action: “Agree log retention with the provider and set it to six months”, owner: head of IT, due in four weeks, high priority, reference Art. 26(6). A second action, “Inform the works council about the deployment” (Art. 26(7)), gets its own line because it has a different owner.

Scroll the table sideways →

Fields of an action in the audit playbook
FieldContentExample
ActionA concrete, verifiable task – not a topic“Write down the Art. 6(3) reasoning for ticket routing”
ReferenceArticle, annex or internal policyArt. 6(4)
SystemThe affected AI system from the inventorySupport classifier v2
OwnerOne person who carries out the action – not a teamProduct owner, support
Due dateThe date the owner has committed to31 Oct 2026
PriorityHigh, medium, low – by risk and visibilityhigh
StatusOpen, in progress, done, deliberately deferredin progress
EvidenceWhere the result sits once doneClassifications folder / version 3
Justification when deferredWhy not now, who decided, when to revisit“System replaced on 1 Feb 2027; management decision of 2 Oct 2026”

A status of “done” without evidence is an open item for an auditor. Agree that actions are only closed with linked evidence.

30-day preparation

When the review has been announced: a four-week proposal

A recommendation, not a statutory procedure. With a request from an authority, the authority’s deadline applies – compress the plan accordingly.

Days 1–3

Reason, scope, team

Clarify basis and deadline, fix the affected systems and roles, name one contact person. Inform management. Set a reference date for all documents.

Days 4–10

Fill the file

Collect inventory extract, classifications, technical documentation or instructions for use, oversight concept and literacy evidence. Record missing pieces as actions straight away rather than collecting them first.

Days 11–18

Close the visible gaps

Start with what shows up in every sample: logs, classification reasoning, named oversight persons, incident process. Everything else goes into the plan with a realistic due date and a justification.

Days 19–24

Dry run

Review one system as an outsider would: request documents, retrieve the logs for a reference date, interview the oversight person. Feed the results into the plan.

Days 25–28

Approval and handover

Freeze the file (dated export), have answers to authorities legally reviewed and approved, prepare the handover list. Hand over only what has been requested.

Days 29–30

Buffer and follow-up

Answer follow-up questions and log what was handed over. After the review, turn every finding into an action with an owner and record the closure.

Typical findings

Where reviews get stuck in practice

These points are not statistics but patterns that come up again and again during preparation. Each of them can be fixed before the review.

An inventory without shadow AI

The inventory lists the officially procured systems but not the AI features in office software, CRM or HR tools. The auditor asks in the business unit – and finds more.

Classification without reasoning

“Minimal risk” is in the list, but nobody can say why. Without a check against Art. 5, Annex III and Art. 50, the classification is just a claim.

Art. 6(3) exception without documentation

An Annex III use case is treated as not high-risk, but the assessment was never written down and registration under Art. 49(2) was never checked.

Logs exist but are out of reach

The provider stores logs, the deployer has no access or does not know for how long. Art. 26(6) requires at least six months as far as the logs are under the deployer’s control – that needs to be settled in the contract.

Oversight only on paper

A “human oversight” role is named, but the person knows neither the system’s limits nor their authority to stop it. Art. 26(2) requires competence, training and authority.

Training without evidence

Everyone was “informed”, but there is no attendance list, no content, no date. For Art. 4 what counts is which measures you took – and that can only be shown with evidence.

No incident process with deadlines

Nobody knows who recognises a serious incident, who informs the provider and when the 2-, 10- or 15-day period under Art. 73 starts.

Documents without a version

Technical documentation, instructions for use and classification date from different months and contradict each other. A reference date and a version on every document prevent this.

Handing over more than asked

Out of caution the whole file is sent – including internal drafts and comments. Hand over what was requested and log it.

Timeline

What can be reviewed today – and what comes in 2027

Many companies postpone audit preparation because, after the Digital Omnibus, the high-risk obligations only apply from 2 December 2027 (Annex III) or 2 August 2028 (Annex I). That is only half the story. Market surveillance can already check today whether prohibited practices under Art. 5 are in use, whether AI literacy measures under Art. 4 have been taken and whether the transparency obligations under Art. 50 are met – for example telling people that they are interacting with an AI system, or deployers disclosing deepfakes.

For high-risk systems an early start pays off for a practical reason: technical documentation, risk management and a QMS are not built in four weeks. If you have an inventory and reasoned classifications today, you can build the rest methodically by the end of 2027; if you start in 2027, you will be working under pressure.

  • Since 2 Feb 2025: prohibitions (Art. 5) and AI literacy (Art. 4)
  • Since 2 Aug 2025: obligations for GPAI models, governance, penalties
  • Since 2 Aug 2026: general application, transparency obligations under Art. 50
  • From 2 Dec 2027: high-risk obligations for Annex III systems (incl. Art. 9–27)
  • From 2 Aug 2028: high-risk obligations for products under Annex I
  • Art. 72 and 73 relate to high-risk systems and become practically relevant from these dates

With SimpleAct

Actions, evidence and change history in one place

In SimpleAct’s audit playbook you create actions for each AI system – with an owner, a due date, a priority and a status. Gaps from legal logic and risk assessment become tasks, and the current state can be exported as part of the compliance report.

  • Actions per system with title, description, due date, owner and priority (LOW, MEDIUM, HIGH)
  • Status OPEN, IN_PROGRESS, DONE or SKIPPED – skipping with a justification in the comment
  • Export as PDF or DOCX with inventory, assessments, checklist status and change history
  • Audit trail as a hash chain with old and new values; integrity verification you can run yourself
  • Evidence register with approval by admins and finalisation gates (Governance)
  • Audit readiness score from the Professional plan

Access to the audit playbook requires audit permission. Governance and Legal Logic are marked as PRO modules in the app. SimpleAct structures the preparation; it replaces neither a review nor legal advice.

Open-Source Framework

simpleact-ai-governance-playbook

Open-source playbook: article mappings, action templates, and audit items for the EU AI Act – ready to use in SimpleAct.

View on GitHub

FAQ

Frequently asked questions about AI audits

There is no general audit obligation. Providers of high-risk systems must carry out a conformity assessment before placing them on the market (Art. 43). Authorities can request documents as part of market surveillance (Art. 21, Art. 74). Regular audits in the narrow sense are foreseen for notified bodies monitoring an approved QMS (Annex VII, point 5.3).
Under § 2 KI-MIG, the Federal Network Agency is in principle the competent market surveillance authority. For AI systems directly connected with regulated financial activities of the companies it supervises, it is BaFin. For products under Annex I, the existing market surveillance authorities remain competent.
No. Conformity assessment is the provider’s job. Deployers must use the system in line with the instructions for use, assign oversight to competent persons, monitor operation, keep logs for at least six months and cooperate with authorities (Art. 26). Anyone offering a system under their own name or substantially modifying it can, however, become a provider (Art. 25).
In practice usually the overview: AI inventory, roles and classifications. Then, depending on the role, technical documentation and QMS (providers) or instructions for use, logs and the oversight concept (deployers). AI literacy evidence under Art. 4 and the incident procedure are requested almost every time.
Market surveillance gets access to the documentation and to training, validation and testing data sets as far as needed for its tasks – also via API or remotely (Art. 74(12)). Source code only upon a reasoned request, and only where it is necessary for the assessment and other means have been exhausted (Art. 74(13)).
Gaps alone are not a separate offence – incorrect, incomplete or misleading answers to requests for information are (Art. 99(5): up to €7.5 million or 1 % of annual turnover, the lower amount for SMEs). Name gaps openly and enclose the action plan with due dates. Breaching the underlying obligation can be sanctioned separately.
No. A management system under ISO/IEC 42001 helps organise roles, risk assessment and controls, and many documents can be reused. It does not replace conformity assessment under Art. 43 or the duties under Art. 26.
Providers keep technical documentation, QMS documentation, approved changes, decisions of notified bodies and the EU declaration of conformity for 10 years (Art. 18, Art. 47). Providers and deployers keep logs for at least six months as far as they are under their control (Art. 19, Art. 26(6)). For other documents the AI Act sets no period.
Yes. Prohibitions (Art. 5), AI literacy (Art. 4) and transparency obligations (Art. 50) already apply and can be reviewed. And the documents for high-risk systems – technical documentation, risk management, QMS – take months, not weeks.
For every gap, an action with concrete content, reference (article), system, owner, due date, priority, status and evidence. Anything deliberately deferred gets a justification with the decision-maker and a review date. Export the state as of the review date.

More questions? We're happy to help. Send email · Get started

Sources, status and changes

Updated: · SimpleAct editorial team

This guide gives a general overview and is not legal advice. Whether and which obligations apply to your company depends on the individual case. Examples are marked as such; recommendations are not statutory duties.

Changes

  • 2026-10-06 – Page rebuilt: distinction between conformity assessment, requests from authorities and audits, types of review, auditor’s file with retention periods, action plan, 30-day preparation, readiness check; dates after the Digital Omnibus.
  • 2026-04-01 – First published as a product page for the audit playbook.

Start your next review with organised documents

Inventory, classification, actions and evidence in one system – with owners, due dates and a traceable change history.