EU AI Act · Control protocol

Build an EU AI Act matrix that withstands examination

A useful matrix does not recite the Regulation. It connects an applicable provision, an expected outcome, an owner, an observable control, a performed test, dated evidence and a decision.

On this page
Unit of conclusion

A control counts only when its result is demonstrated

The matrix is built after qualifying the system and each entity’s role. One row addresses one verifiable assertion for one identified version. It never concludes beyond the scope actually tested.

Applicability
Provision, condition, role and date
Control
Objective, mechanism, owner and frequency
Examination
Population, procedure, threshold and result
Conclusion
Status, limitation, decision and approver
Traceability chain

Keep one thread from the legal text to the decision

Each field answers a different question. Merging them creates a record that cannot be reviewed; connecting them lets a second examiner reconstruct the conclusion.

  1. Source

    Article, paragraph, annex, consolidated text and consultation date.

  2. Applicability

    Triggering fact, relevant role, deadline and rationale.

  3. Expected outcome

    Precise assertion the arrangement must satisfy.

  4. Control

    Technical or organisational mechanism, owner and frequency.

  5. Test

    Population, sample, procedure, threshold and failure criterion defined before execution.

  6. Evidence

    Inputs, raw results, version, provenance, integrity and limitation.

  7. Decision

    Row status, action, decision authority and reopening condition.

Provider · high-risk systems

Examine requirements across the lifecycle

For providers, the requirements in Articles 8 to 15 and associated obligations cannot be demonstrated by one document. Each domain receives its own assertions, tests, records and decisions.

DomainBasisExpected controlTest and evidence
RiskArt. 9Continuous process connected to hazards, intended use, foreseeable misuse and residual riskReplay a scenario, verify metrics and thresholds, retain results and acceptance
DataArt. 10Governance of data used for training, validation or testing, as applicableExamine lineage, quality criteria, relevance, representativeness and relevant bias
DocumentationArt. 11 · Annex IVTechnical file consistent with the system presented for examinationReconcile architecture, versions, performance, limitations and cited records
LogsArt. 12Recording capabilities suited to system traceabilityTrigger events; verify integrity, timestamps and retrieval
InformationArt. 13Accurate instructions that a deployer can actually usePerform a task, limitation and incident response from the instructions alone
Human oversightArt. 14Measures designed to understand, monitor, disregard, override or stop as applicableTest permissions, response time, degraded modes and intervention record
Performance and securityArt. 15Declared accuracy, robustness and cybersecurity levels maintainedRun relevant nominal, boundary, error, attack and drift scenarios
Quality systemArts. 16–21 · 72–73Ownership, change, retention, correction, monitoring and incidents organisedSample one change and one incident end to end through the decision
Deployer · high-risk systems

Verify actual operating conditions

The deployer does not inherit the provider’s matrix. It must demonstrate what it controls in its organisation: configuration, authorised people, input data, monitoring, suspension, logs and information where those duties apply.

ObjectBasisExpected controlTest and evidence
Use as instructedArt. 26(1)Configuration and procedure aligned with instructions for useCompare active settings, procedure and instruction version
OversightArt. 26(2)Competent, trained, authorised and supported peopleRole-based exercise, access matrix, training and decision log
Input dataArt. 26(4)Relevance and sufficient representativeness where controlled by the deployerSample production inputs, exclusions and relevant sub-populations
Monitoring and suspensionArt. 26(5)Detected signal, named escalation and genuinely available stopSimulate a risk and incident; measure detection, notification and suspension
LogsArt. 26(6)Logs under the deployer’s control retained for the applicable periodExtract a period; verify completeness, access, integrity and retention rule
InformationArt. 26(7) and (11)Workers or persons informed when conditions are metCheck content, recipients, timing and proof of delivery
Registration and DPIAArt. 26(8) and (9)Context-dependent duties examined before useVerify entity status, EU registration and GDPR interaction
Test protocol

Write the test before requesting evidence

Evidence is not selected because it is easy to obtain. The protocol starts from the assertion and states in advance what will support, fail or limit the result.

  1. Baseline

    Freeze the system, configuration, data and period under examination.

  2. Assertion

    State an observable outcome without relying on vague verbs such as “manage” or “ensure”.

  3. Population

    Define covered cases, exclusions and the sampling strategy.

  4. Procedure

    Describe actions, tools, inputs and calculation rules so the test can be repeated.

  5. Criterion

    Set success threshold, tolerance, severity and expected response before seeing the result.

  6. Record

    Retain raw outputs, anomalies, protocol deviations, conclusion and signatory.

Evidential strength

Retain what a third party must be able to verify

A screenshot or unexercised policy may establish a limited fact; it does not by itself demonstrate operational effectiveness. The file retains both the item and the context that permits — or prevents — extrapolation.

Provenance
Author, source system and collection path
Time
Date, covered period and timestamp
Version
Model, code, rules, data and configuration
Integrity
Original, hash or preservation mechanism
Result
Raw data, calculation, exception and observation
Scope
Covered population, exclusion and conclusion limit
Row status

Separate result, evidence and decision

The status qualifies one precise assertion. It does not turn one successful row into a general statement of system compliance.

StatusConditionConsequence
EffectiveProcedure performed, criterion met and sufficient evidenceConclusion valid for the tested version and scope
FailedCriterion missed or mechanism unavailableFinding, severity, owner, due date and closure test
Not demonstratedMissing evidence, unperformed procedure or non-reproducible resultLimitation or finding; no assumed compliance
Not applicableApplicability condition tested and rationale retainedValidated exclusion with a reopening trigger
For determinationDisputed interpretation, fact or thresholdIsolated question, named authority and expected decision
Replayable case · human oversight

Move from a stated policy to a supported conclusion

Entirely synthetic example: a high-risk system assists a recruitment decision. Documentation states that the business owner can disregard the recommendation and suspend use.

FieldRegister entry
BasisArticles 14 and 26(2), subject to the retained qualification and role
AssertionThe supervisor understands the output, can challenge it and suspend the system during service
ProcedureExercise on the production version with business and administrator profiles, nominal, boundary and incident cases
ObservationThe recommendation can be disregarded; suspension remains restricted to the administrator profile
EvidencePermission export, exercise recording, timestamped logs and raw results
ConclusionSuspension control failed; named correction and retest required before closure
Register governance

Reopen the conclusion whenever its object changes

The register remains tied to the configuration in service. It distinguishes who operates the control, who produces evidence, who examines it and who accepts residual risk.

  • Version Re-examine after a model, data, rule, interface or supplier change.
  • Use Re-examine after a change in purpose, population, influenced decision or context.
  • Role Re-examine after rebranding, integration, substantial modification or transfer of responsibility.
  • Result Re-examine after drift, incident, complaint, threshold breach or control failure.
  • Law Re-examine after a change to the text, deadline, guidance or sector rule.

Primary sources

Sources this page relies on

Last documentary review: 5 September 2026.

Before you write to us

Frequently asked questions

Is an internal policy sufficient evidence?

It shows that a rule has been stated, not that it operates. The conclusion also depends on the mechanism, owner, procedure performed, result and tested system version.

Can providers and deployers use the same matrix?

The structure may be shared, but provisions, responsibilities and evidence are assigned to the qualified role. High-risk system requirements must not be confused with operating duties.

How should unavailable evidence be handled?

The register states what is missing, why, the alternatives examined and the effect on the conclusion. A material absence becomes a limitation or finding, never assumed compliance.

Does one “effective” row prove that the system is compliant?

No. It supports one assertion for the tested version, population and period. The overall conclusion depends on all applicable requirements, limitations, findings and the conformity-assessment procedure where required.

EU AI Act evidence register

Does your file distinguish what exists from what has actually worked?

We start from the qualification, the version in service and actual responsibilities to build and examine the evidence chain.

Present the system