European UnionAI Act, Article 18 (documentation keeping)
Regulation (EU) 2024/1689, Article 18
An AI governance rule binding public and private bodies.
- How the hook was established
- express
- What makes it apply
- Market targeting, Place of effect
- Obligation class
- Governance, Retention
- Audit expectation
- on_request
- Who audits it
- Regulator
- Where the report goes
- Kept, Produced on request
As of .
What it requires
- This duty takes effect on for a high-risk AI system classified under Article 6(2) and Annex III, and on for one classified under Article 6(1) and Annex I (Article 113, third paragraph, point (c), as replaced by Regulation (EU) 2026/1744), other than a system related to a product covered by the Union harmonisation legislation listed in Section B of Annex I, to which, under Article 2(2), only Article 6(1), Article 60a and Articles 102 to 112 apply, and Articles 57, 58 and 59 apply only in so far as the requirements for high-risk AI systems under this Regulation have been integrated in that Union harmonisation legislation; a system already placed on the market or put into service before its date is reached only once its design changes significantly, or by if it is intended for use by public authorities.
- If you are the provider of a high-risk AI system, keep at the disposal of the national competent authorities, for a period ending 10 years after the system has been placed on the market or put into service: its technical documentation under Article 11; the documentation concerning your quality management system under Article 17; where applicable, the documentation concerning changes approved by notified bodies and the decisions and other documents notified bodies issued; and the EU declaration of conformity under Article 47.NIST AI RMFGOVERN 1.1
- If you are a financial institution subject to internal-governance requirements under Union financial services law, maintain the technical documentation as part of the documentation kept under the relevant Union financial services law.no control in the NIST AI RMF
These lines are LexLint's reading of the law's text, as of .
In the frameworks
- NIST AI RMF
- GOVERN 1.1Legal and regulatory requirements involving AI are understood, managed, and documented.
- NIST AI 600-1
- GAI-RISK-07Human-AI Configuration
- NIST AI 200-2 Draft
- OWASP LLM Top 10
- LLM03:2026Excessive Agency
- OWASP Agentic Top 10
- ASI09Human-Agent Trust Exploitation
- MIT mitigations Draft
- FINOS AIGF
- AIR-PREV-005System Acceptance Testing
- AIR-PREV-006Data Quality & Classification/Sensitivity
- AIR-PREV-024Human-in-the-Loop Action Approval Gate
- AIR-DET-004AI System Observability
- AIR-DET-011Human Feedback Loop for AI Systems
- AIR-DET-021Agent Decision Audit and Explainability
- ETSI EN 304 223
- 5.1.4-1Capability for human oversight designed in and maintained.
- 5.2.1-1Full inventory of assets, including their dependencies and connections.
- 5.2.4-1Developers keep an audit trail of system design and post-deployment maintenance plans and offer it downstream.
- 5.4.2-1Operators log system and user actions.
Our reading of where this law's duties sit in each framework, and in the NIST AI RMF, line by line beside each duty above. It never says that running a control meets the law. How we read a framework against the law
Identifiers refer to ETSI EN 304 223 V2.1.1 (2025-12), © ETSI 2025, all rights reserved. ETSI owns the standard; no ETSI text (titles or sentences) is reproduced here. The standard is free to download from ETSI.
If you get it wrong
Private right of actionNo
Penalty structure
Article 99(4)(a): non-compliance with the obligations of providers under Article 16 is fined up to EUR 15,000,000 or 3% of worldwide annual turnover, whichever is higher. Article 16, point (d), requires a provider to keep the documentation referred to in Article 18, the duty this row states; Article 99(6) requires the lower of the two amounts for an SME, including a start-up; Article 99(6a), inserted by Regulation (EU) 2026/1744, gives the same lower-of treatment to a small mid-cap enterprise, since both apply to paragraph 4 fines.
- Rule
- Lower of for SME
- As of
- Currency
- EUR
- Fixed cap
- 15,000,000
- Turnover percentage cap
- 3
Who enforces it
Settledness
- As of
- Open questions
- From which placing on the market does the 10-year period in Article 18(1) run for a high-risk AI system whose units of one type and model are placed on the market over several years: the first unit, or each unit?
What it makes you log
Who may demand the log
Regulator
Log retention
Ten years after the high-risk AI system has been placed on the market or put into service, for the technical documentation, the quality management system documentation, any notified-body documents and the EU declaration of conformity; the period is for those documents, not for the logs, whose minimum period is Article 19's.
- Unit
- Years
- As of
- Basis
- Fixed
- Maximum value
- 10
- Minimum value
- 10
Logging duty
Article 18 is a duty to keep named documents at the national competent authorities' disposal for a fixed period. It does not create the documents (Articles 11, 17 and 47 and the notified bodies' procedures do) and it does not cover the logs a system automatically generates, which a provider keeps under Article 19.
- Kind
- Explicit
- As of
- Provision
- Article 18(1)
- Trigger
- high_risk_systems
What this law does
The provider of a high-risk AI system must, for a period ending 10 years after the system has been placed on the market or put into service, keep at the disposal of the national competent authorities its technical documentation under Article 11, the documentation concerning its quality management system under Article 17, where applicable the documentation concerning changes approved by notified bodies and the decisions and other documents notified bodies issued, and the EU declaration of conformity under Article 47.
Each Member State must determine the conditions under which the documentation listed in Article 18(1) remains at the disposal of the national competent authorities for the period that paragraph sets where a provider, or its authorised representative, established on its territory goes bankrupt or ceases its activity before that period ends.
A provider that is a financial institution subject to internal-governance requirements under Union financial services law must maintain the technical documentation as part of the documentation kept under that law.
Article 18 sits in Chapter III, Section 3, so like Article 12 it takes effect on the schedule the Digital Omnibus on AI (Regulation (EU) 2026/1744, in force since ) wrote into Article 113: for a system classified as high-risk under Article 6(2) and Annex III, and for a system classified as high-risk under Article 6(1) and Annex I, rather than the Regulation's general application date.
Under Article 111(2), as the Digital Omnibus on AI rewrote it, the Regulation reaches the operators of a high-risk AI system placed on the market or put into service before the date Chapter III applies only if, from that date, the system's design changes significantly; in any case, the providers and deployers of a high-risk AI system intended to be used by public authorities must take the necessary steps to comply with the Regulation's requirements and obligations by .
Article 18 does not apply to a high-risk AI system related to a product covered by the Union harmonisation legislation listed in Section B of Annex I, to which, under Article 2(2), only Article 6(1), Article 60a and Articles 102 to 112 apply, and Articles 57, 58 and 59 apply only in so far as the requirements for high-risk AI systems under this Regulation have been integrated in that Union harmonisation legislation.
When LexLint raises it
When your app profile says your app makes high-risk automated decisions or processes biometric data.