Article 11
Technical documentation

The text

What it requires, coded

SafeLegalAI's reading of each duty in this article: who, what, from when, under which fine tier, and whether it reaches a firm, chambers, court or legal-AI vendor. Descriptive, not advice; the quoted words are the Regulation's.

1. Art. 11(1)DocumentationHigh-risklegal practice

   Technical documentation for a high-risk AI system must be drawn up before market placement or putting into service and kept up to date.

   "The technical documentation of a high-risk AI system shall be drawn up before that system is placed on the market or put into service and shall be kept up-to date."

   Who

   Provider

   From

   2027-12-02 (Art. 113(c)(i) as amended by Reg. (EU) 2026/1744)As enacted in 2024: 2026-08-02 (Art. 113 second subparagraph); deferred by Regulation (EU) 2026/1744 (Digital Omnibus on AI).For Art. 6(1)/Annex I high-risk systems, Art. 113(c)(ii) as amended applies the corresponding obligation from 2028-08-02; Art. 111(2) gives public-authority high-risk systems until 2030-08-02.

   Fine tier

   Art. 99(4)

   Legal practice

   Reaches legal practice directly — Legal-AI vendors providing high-risk systems need current technical documentation before launch or deployment.

   See

   Annex III point 8

2. Art. 11(2)DocumentationHigh-risk

   For high-risk AI systems related to Annex I Section A products, a single technical documentation set must include Article 11 information and information required under those product laws.

   "Where a high-risk AI system related to a product covered by the Union harmonisation legislation listed in Section A of Annex I is placed on the market or put into service, a single set of technical documentation shall be drawn up containing all the information set out in paragraph 1, as well as the information required under those legal acts."

   Who

   Provider, Product manufacturer

   From

   2027-12-02 (Art. 113(c)(i) as amended by Reg. (EU) 2026/1744)As enacted in 2024: 2026-08-02 (Art. 113 second subparagraph); deferred by Regulation (EU) 2026/1744 (Digital Omnibus on AI).For Art. 6(1)/Annex I high-risk systems, Art. 113(c)(ii) as amended applies the corresponding obligation from 2028-08-02; Art. 111(2) gives public-authority high-risk systems until 2030-08-02.

   Fine tier

   Art. 99(4)

   Legal practice

   Institutional — Mostly product-regulated AI rather than ordinary legal-AI software, but relevant to legal advice on regulated products.

   See

   Annex I Section A

3. Art. 11(3)Delegated or implementing actHigh-risk

   The Commission may amend Annex IV by delegated act where technical progress requires changes so technical documentation provides all information necessary to assess Section 2 compliance.

   "The Commission is empowered to adopt delegated acts in accordance with Article 97 in order to amend Annex IV, where necessary, to ensure that, in light of technical progress, the technical documentation provides all the information necessary to assess the compliance of the system with the requirements set out in this Section."

   Who

   Commission

   From

   2027-12-02 (Art. 113(c)(i) as amended by Reg. (EU) 2026/1744)As enacted in 2024: 2026-08-02 (Art. 113 second subparagraph); deferred by Regulation (EU) 2026/1744 (Digital Omnibus on AI).For Art. 6(1)/Annex I high-risk systems, Art. 113(c)(ii) as amended applies the corresponding obligation from 2028-08-02; Art. 111(2) gives public-authority high-risk systems until 2030-08-02.

   Legal practice

   Reaches legal-AI vendors or public bodies — Changes to Annex IV can alter documentation expectations for legal-AI vendors with high-risk systems.

   See

   Annex IV · Art. 97