Provider, deployer and other operator obligations

Chapter III Sections 3 and 5 and Chapter IX: what providers, deployers, importers, distributors and authorised representatives of high-risk AI systems must do, from quality management and conformity assessment to registration, post-market monitoring and incident reporting.

Article 17 Quality management system

The documented quality management system every high-risk provider needs, its 13 required aspects, proportionality for SMEs and small mid-caps, integration with sectoral and financial-sector systems, and EN 18286:2026 as the first harmonised standard.

Article 18 Documentation keeping

How long and what providers must keep for authorities: technical documentation, QMS records, notified body changes and decisions, and the EU declaration of conformity for 10 years, including if the provider ceases trading.

Article 19 Automatically generated logs

The provider's duty to retain the logs its high-risk system generates, for at least six months where they are under its control, the financial-sector alternative, and authority access to those logs.

Article 23 Obligations of importers

Checks an EU importer must make before placing a non-EU provider's high-risk system on the market, what to do with suspect or falsified systems, labeling, storage, 10-year records and cooperation.

Article 24 Obligations of distributors

Verification and corrective duties for distributors of high-risk systems: CE marking and documentation checks, holding back non-conforming systems, corrective action after sale, and cooperation with authorities.

Article 25 Responsibilities along the AI value chain

When a deployer, importer, distributor or other party becomes the provider of a high-risk system, what the original provider then owes, the written agreements required with component and model suppliers, and the 2026 changes and fines.

Article 27 Fundamental rights impact assessment

Which deployers must assess the impact of a high-risk system on fundamental rights before first use, the six required elements, notification to the authority, and the 2026 link to GDPR data protection impact assessments.

Article 43 Conformity assessment

Which conformity assessment route a high-risk system must follow: internal control under Annex VI, notified body assessment under Annex VII, or the sectoral procedure for Annex I products, plus certificate validity and reassessment after substantial modification.

Article 49 Registration in the EU database

Who must register high-risk and claimed not-high-risk systems in the EU database before use, the data required by Annex VIII, the secure section for law enforcement and migration, and national registration for critical infrastructure.

Article 72 Post-market monitoring

The provider's system for collecting and analysing real-world performance data on a high-risk system over its lifetime, the post-market monitoring plan in the technical file, the Commission template due in 2027, and integration with sectoral systems.

Article 73 Reporting of serious incidents

The provider's duty to report serious incidents involving high-risk AI to market surveillance authorities: the 15, 10 and 2 day deadlines, investigation without altering evidence, sectoral carve-outs, AI Office reporting since 2026 and the Commission's draft guidance.

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