EU AI Act High-Risk AI System Documentation
Overview
The EU AI Act (Regulation 2024/1689, entered into force 1 August 2024, with high-risk obligations applicable from 2 August 2026) establishes a risk-based regulatory framework for artificial intelligence systems. High-risk AI systems — those listed in Annex III or used as safety components of products covered by Union harmonisation legislation in Annex I — must meet extensive documentation, transparency, and governance requirements before being placed on the EU market. Cerebrum AI Labs must prepare comprehensive technical documentation, implement a risk management system, ensure data governance, and undergo conformity assessment for each high-risk AI system.
High-Risk Classification
Annex III Categories Relevant to Cerebrum AI Labs
| Category |
Annex III Reference |
Cerebrum AI Labs System |
Classification |
| Employment and workers management |
Annex III, para. 4(a) |
CV Screening AI — automated filtering of job applications |
High-risk |
| Access to essential services |
Annex III, para. 5(b) |
Credit Scoring AI — creditworthiness assessment for financial products |
High-risk |
| Law enforcement |
Annex III, para. 6(a) |
Not applicable |
N/A |
| Biometric identification |
Annex III, para. 1(a) |
Facial Verification AI — identity verification at onboarding |
High-risk |
| Education and vocational training |
Annex III, para. 3(a) |
Not applicable |
N/A |
Classification Decision Tree
Is the AI system listed in Annex III?
├── Yes → High-risk (unless exception applies under Art. 6(3))
│ └── Does the system make decisions materially affecting natural persons?
│ ├── Yes → High-risk confirmed
│ └── No → May qualify for Art. 6(3) exception (narrow, profiling, preparatory)
│
├── No → Is it a safety component of a product under Annex I legislation?
│ ├── Yes → High-risk (subject to third-party conformity assessment)
│ └── No → Not high-risk under AI Act
│
└── Is it a general-purpose AI model with systemic risk? (Art. 51)
├── Yes → GPAI systemic risk obligations
└── No → GPAI transparency obligations only
Technical Documentation Requirements (Art. 11)
Annex IV — Required Documentation Content
Section 1: General Description
| Document Element |
Content for Cerebrum AI Labs CV Screening AI |
| Intended purpose |
Automated screening and ranking of job applications based on qualification match |
| Provider name and contact |
Cerebrum AI Labs, 42 Innovation Drive, Dublin, Ireland |
| AI system version |
v2.4.1 (deployed March 2026) |
| Hardware/software requirements |
Cloud-hosted on EU infrastructure (AWS eu-west-1), Python 3.11, PyTorch 2.2 |
| Product integration |
Integrated into Cerebrum TalentFlow ATS platform |
Section 2: Detailed Description of System Elements
| Element |
Documentation Required |
| Development methodology |
Model architecture, training approach, design choices and rationale |
| Computational resources |
Training compute (GPU hours), energy consumption |
| Training data |
Data sources, collection methods, size, labeling methodology, preprocessing |
| Validation and testing |
Test datasets, metrics, results, known limitations |
| Input data specifications |
Expected input format, quality requirements |
| Output description |
Output format, confidence scores, decision thresholds |
Section 3: Monitoring, Functioning, and Control
| Element |
Documentation Required |
| Human oversight measures |
Art. 14 requirements: override capability, decision review process |
| Technical measures for accuracy |
Accuracy metrics, drift detection, retraining triggers |
| Cybersecurity measures |
Data encryption, access controls, adversarial robustness testing |
| Performance in edge cases |
Known failure modes, boundary conditions, degradation behavior |
Section 4: Risk Management
| Element |
Documentation Required |
| Risk management system |
Art. 9 risk management process documentation |
| Known and foreseeable risks |
Risk register with severity and likelihood |
| Mitigation measures |
Controls for each identified risk |
| Residual risk assessment |
Acceptable residual risk justification |
Risk Management System (Art. 9)
Continuous Risk Management Process for Cerebrum AI Labs
| Phase |
Activity |
Frequency |
| Identification |
Identify risks to health, safety, and fundamental rights |
Initial + quarterly |
| Analysis |
Estimate risk severity and likelihood |
Initial + quarterly |
| Evaluation |
Compare risks against acceptance criteria |
Initial + quarterly |
| Mitigation |
Implement risk reduction measures |
Ongoing |
| Monitoring |
Track risk indicators in production |
Continuous |
| Review |
Review and update risk assessment |
Quarterly |
Risk Register — CV Screening AI
| Risk ID |
Risk Description |
Severity |
Likelihood |
Mitigation |
Residual Risk |
| R-001 |
Gender bias in screening recommendations |
High |
Medium |
Bias testing on protected attributes, debiasing training data |
Low |
| R-002 |
Discrimination against non-native language speakers |
High |
Medium |
Multilingual evaluation, language-agnostic features |
Medium |
| R-003 |
Over-reliance on AI recommendations by recruiters |
Medium |
High |
Mandatory human review, confidence thresholds |
Low |
| R-004 |
Inaccurate qualification matching for novel job roles |
Medium |
Medium |
Fallback to keyword matching, human review flag |
Low |
| R-005 |
Privacy breach via training data memorization |
High |
Low |
Differential privacy in training, memorization audit |
Low |
Data Governance (Art. 10)
Training Data Requirements
| Requirement |
Implementation at Cerebrum AI Labs |
| Relevance and representativeness |
Training data sourced from 50,000 job applications across 12 EU countries, balanced by gender, age, nationality |
| Bias examination |
Statistical parity analysis on protected attributes (gender, age, ethnicity, disability) before and after training |
| Gap identification |
Identified underrepresentation of applicants with disabilities; augmented with synthetic examples |
| Data quality |
Automated data quality checks: completeness >95%, label accuracy >98% (human-verified sample) |
| Personal data processing |
DPIA completed (DPIA-AI-2026-001); lawful basis: Art. 6(1)(f) legitimate interest; special categories removed |
Conformity Assessment (Art. 43)
Assessment Procedure for Cerebrum AI Labs
| System |
Assessment Type |
Basis |
| CV Screening AI |
Internal conformity assessment (Art. 43(2)) + quality management system |
Annex III, para. 4 — not biometric, not critical infrastructure |
| Credit Scoring AI |
Internal conformity assessment (Art. 43(2)) |
Annex III, para. 5 |
| Facial Verification AI |
Third-party conformity assessment (Art. 43(1)) via notified body |
Annex III, para. 1 — biometric identification |
Internal Conformity Assessment Steps
- Verify quality management system is established (Art. 17)
- Prepare technical documentation per Annex IV
- Conduct risk management assessment per Art. 9
- Verify data governance per Art. 10
- Verify transparency and information provision per Art. 13
- Verify human oversight per Art. 14
- Verify accuracy, robustness, and cybersecurity per Art. 15
- Draw up EU Declaration of Conformity (Art. 47)
- Affix CE marking (Art. 48)
- Register in EU database (Art. 49)
Post-Market Monitoring (Art. 72)
| Activity |
Frequency |
Owner |
| Performance metric monitoring |
Continuous |
ML Engineering |
| Bias drift detection |
Weekly |
Responsible AI team |
| Incident reporting |
As needed (within 15 days for serious incidents per Art. 73) |
DPO + Legal |
| User feedback collection |
Continuous |
Product team |
| Risk register update |
Quarterly |
Risk Management |
| Technical documentation update |
On material change |
ML Engineering + Legal |
Key Legal References
- EU AI Act (Regulation 2024/1689) — Full text, entered into force 1 August 2024
- AI Act Art. 6 + Annex III — High-risk classification criteria
- AI Act Art. 9 — Risk management system requirements
- AI Act Art. 10 — Data and data governance requirements
- AI Act Art. 11 + Annex IV — Technical documentation requirements
- AI Act Art. 13 — Transparency and provision of information to deployers
- AI Act Art. 14 — Human oversight requirements
- AI Act Art. 43 — Conformity assessment procedures
- AI Act Art. 72 — Post-market monitoring obligations
- AI Act Art. 73 — Reporting of serious incidents
- GDPR Art. 22 — Automated individual decision-making (complementary to AI Act)
- EDPB-EDPS Joint Opinion 5/2021 on the AI Act Proposal — Data protection perspective on AI regulation