Controls
The 19 EU AI Act controls with status and evidence per AI system.
The compliance checklist tells you what to do per system. The control library tells you which controls you operate as an organization – and, per AI system, how far their implementation has come. SimpleAct ships a fixed library of 19 controls along the EU AI Act; it is identical for every organization and therefore recognizable to auditors.
At a glance
- Included from
- Starter (core feature)
- Where in the app
- Open an AI system → Controls
- Output
- Control status per system with notes and evidence links
- API
- /api/v1/controls
How the library is structured
Every control has a stable key, a title, a description, a priority (HIGH or MEDIUM), and a reference to the Annex IV section its evidence belongs in. The key never changes – so you can reference it, carry it into your own reporting, and address it via the API.
The library itself contains no organization data. It is a template: only when you set a status for a control on a specific AI system does a record appear in your organization.
The 19 controls
Priority HIGH means: without this control, running a high-risk system is not defensible. MEDIUM means: important for auditability, but not a go-live blocker.
| Control | What it covers | Priority |
|---|---|---|
| Prohibited practices screening | A mandatory Art. 5 screening gate before every release and material change. | High |
| AI literacy programme | Role-based training, reminders, attendance records and exports (Art. 4). | High |
| Risk management process | A continuous risk management process across design, development and operation. | High |
| Data governance controls | Document data quality, lineage, minimization and bias mitigation. | High |
| Technical documentation | Keep intended purpose, limits and model behaviour current. | High |
| Logging and traceability | Decision-relevant logs, retention and access accountability. | High |
| Human oversight | Define intervention and stop criteria, ensure trained oversight roles. | High |
| Fundamental rights impact assessment | Affected groups, rights risks, discrimination, mitigations and DPIA reuse before the first high-risk deployment. | High |
| Deployer obligations | Use per instructions, input-data checks, oversight assignment, operational monitoring, log retention, informing affected persons. | High |
| Accuracy, robustness and cybersecurity | Quality metrics, robustness tests and protective controls per release. | High |
| Post-market monitoring | Operate recurring monitoring tasks and trigger reassessments on changes or incidents. | High |
| Serious incident reporting | Separate AI Act incidents from privacy and security incidents; track reporting deadlines, root cause, corrective actions and stop/rollback decisions. | High |
| Incident and corrective action management | The full lifecycle: intake, triage, root cause, corrective action, closure. | High |
| User information and transparency | Provide user instructions, system limitations and complaint/feedback channels. | Medium |
| Art. 50 transparency and labeling | Disclosures, labels and machine-readable marking for chatbots, generated content, deepfakes and emotion recognition. | High |
| GPAI and vendor supply chain | Model provider, version, region, provider documentation, sub-processors, terms changes and evidence requests. | High |
| Change and release reassessment | Trigger reassessment when purpose, model, data basis, thresholds or deployment context materially change. | High |
| Authority request handling | Freeze evidence packs and track communication, owners, deadlines, submissions and approvals. | Medium |
| Standards and controls mapping | Map obligations to versioned internal controls and emerging harmonised standards. | Medium |
Status model
The decisive difference is between the last two levels: "implemented" is a claim, "evidenced" is proof.
| Status | Meaning |
|---|---|
| NOT_STARTED | Not started – the initial state of every control. |
| IN_PROGRESS | Being implemented, not yet complete. |
| IMPLEMENTED | Implemented, but without stored evidence. Fine internally – in an audit it is a statement without proof. |
| EVIDENCED | Implemented and backed by evidence links. This is the state an auditor wants to see. |
What you store on a control
- Status – one of the four levels above.
- Notes – how the control is actually implemented at your organization. This is the text auditors read first.
- Evidence links – references to policies, tickets, test reports or documents. Several links per control are possible.
- Automatically: who last changed the status and when. Every change additionally lands in the audit trail.
Controls and Annex IV belong together
Every control points at the Annex IV section its evidence belongs in – for example "data governance" or "testing and validation". If you keep the controls current, you have already filled much of the Annex IV dossier instead of reconstructing it later from memory.