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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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