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Article 26 Deployer Checklist

Complete checklist for high-risk AI deployer obligations under Article 26 of the EU AI Act. Covers oversight, monitoring, logs, incidents, and workplace notification.

Import to Klarvo

Deployer Obligations Checklist

Use According to Instructions

Ensure the AI system is used according to the provider's instructions for use.

Evidence needed:
Instructions document, internal SOP

Assign Competent Human Oversight

Assign oversight to persons with necessary competence, training, and authority.

Evidence needed:
Oversight role assignment, training records

Manage Input Data Quality

Ensure input data is relevant and representative (if under your control).

Evidence needed:
Data quality checks, sampling notes

Monitor Operation

Monitor the AI system's operation per the provider's instructions.

Evidence needed:
Monitoring plan, periodic reports

Risk Escalation & Suspension

Inform provider and suspend use if you suspect risk to health, safety, or fundamental rights.

Evidence needed:
Escalation SOP, incident playbook

Serious Incident Reporting

Report serious incidents to provider and relevant authorities.

Evidence needed:
Incident record template, notification records

Keep Logs (≥6 months)

Keep automatically generated logs under your control for at least 6 months.

Evidence needed:
Retention policy, system config

Workplace Notification

If used in workplace, inform workers/representatives before deployment.

Evidence needed:
Worker notice, communication records

Related Resources

Article 26 Guide

Detailed explanation of deployer obligations with examples.

High-Risk Checker

Check if your AI system is high-risk under Annex III.

Frequently Asked Questions

What is Article 26 of the EU AI Act?

Article 26 sets out obligations for deployers (users) of high-risk AI systems. It covers requirements for human oversight, data management, monitoring, incident reporting, and transparency.

Who is a 'deployer' under the EU AI Act?

A deployer is any natural or legal person using an AI system under their authority, except where the AI system is used in the course of a personal non-professional activity.

How long must I keep AI system logs?

Deployers must keep logs automatically generated by high-risk AI systems under their control for at least 6 months, unless otherwise provided by applicable law.

When do I need to notify workers?

If you're using a high-risk AI system in a workplace context, you must inform workers and their representatives before putting the system into use.

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