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EU AI Act Conformity Assessment Checklist

A practical Article 43 readiness checklist for teams preparing role, high-risk, technical documentation, standards, and route evidence before qualified conformity review.

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XLSX checklist

Conformity assessment readiness checklist

Use the checklist to test whether role, risk status, route assumptions, technical documentation, and review questions are ready.

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Markdown companion

Conformity assessment markdown outline

Use this text outline for route-readiness notes, evidence gaps, and legal or notified-body review preparation.

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What this checklist is for

This checklist helps teams prepare for the conformity assessment conversation under Article 43 of Regulation (EU) 2024/1689. It does not select the route for you. It organises the facts needed to discuss internal control, notified-body involvement, substantial modification, standards, and evidence readiness with qualified reviewers.

Route-readiness questions

Question areaWhat to confirmEvidence to collect
Role and scopeIs the organisation acting as provider, deployer, importer, distributor, product manufacturer, authorised representative, or a mix?Contracts, labels, intended purpose, modification records, distribution facts.
High-risk basisWhy is the system high-risk, and which Annex III or product-safety route is relevant?Classification rationale, use case, sector/product mapping, exclusion analysis.
Documentation readinessIs technical documentation coherent enough for internal or external assessment?Annex IV-style evidence map, risk file, test reports, logs, instructions for use.
Standards and specificationsWhich harmonised standards, common specifications, or alternative methods are being used or tracked?Standards register, gap analysis, rationale for alternative controls.
Change controlWould a planned or implemented change require renewed assessment or qualified review?Change log, risk impact, performance comparison, approval record.

Checklist sections

1. Classification gate
Confirm high-risk basis, role, intended purpose, market placement, and deployment facts.
2. Route assumptions
Capture why the team believes internal control, notified-body involvement, or another route may apply.
3. Evidence completeness
Check whether technical documentation, risk management, data governance, testing, logs, oversight, and post-market records exist.
4. Standards position
Record standards used, gaps, common specifications, and unresolved technical interpretation points.
5. Declaration and CE marking preparation
List prerequisites before relying on declarations, labelling, or market placement claims.
6. Review decisions
Document counsel, product-safety, conformity-assessment, and technical reviewer questions before final route reliance.

What this checklist does not decide

This checklist does not determine legal status, certify the AI system, confirm CE marking readiness, or decide whether a notified body is required. It is a structured readiness gate for evidence preparation and qualified route review.

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FAQ

Is this a legal conformity assessment?

No. It is a readiness checklist. It helps prepare facts and evidence for qualified legal, product-safety, technical, or notified-body review.

Does every high-risk AI system require a notified body?

No single rule should be assumed from this checklist. The applicable route depends on the system, legal basis for high-risk status, standards, product-safety context, and other facts. Qualified review is required before reliance.

When should the checklist be rerun?

Rerun it after substantial design, model, data, intended-purpose, integration, deployment-context, performance, standards, or legal-guidance changes.

Source and review note

This page is educational and should be reviewed against Regulation (EU) 2024/1689, European Commission materials, national authority guidance, sector rules, and qualified legal or conformity-assessment advice where relevant. It does not confirm legal compliance and is not legal advice.