Technical documentation is not a PDF in a folder. Annex IV defines nine required sections — each with specific content requirements, each needing an owner, evidence, and a readiness status.
EAB tracks technical documentation completeness section by section — so gaps surface before audit, not during it.
Annex IV completeness is not binary. Some sections may be complete while others have gaps. EAB makes the completeness state of each section visible — so work can be prioritised and gaps cannot be hidden.
General system description, intended purpose, and development process documentation. Each section has a named owner, required content fields, and an evidence upload area. Completeness is tracked, not assumed.
Training data provenance, validation methodology, and testing results — documented as structured governance records, not attached PDFs. Data documentation gaps surface before the approval review request.
Post-deployment monitoring arrangements and human oversight mechanisms — the section most commonly incomplete at audit. EAB links this section directly to the Human Oversight Documentation record to avoid duplication.
The Annex IV risk management section is linked directly to the Article 9 Risk Management Record. Evidence uploaded in the risk record is available here — no duplication, one governed artefact serving two documentation requirements.
Metrics, testing results, and cybersecurity measures — each documented with evidence. Sections 7–9 often require input from technical teams who are not primary users of the compliance platform. Ownership assignments make this explicit.
Technical documentation that can only be referenced but not submitted is not sufficient. EAB produces documentation that is exportable, structured, and demonstrably complete — section by section, with evidence and ownership.
Documentation completed at registration may become incomplete as systems evolve. EAB tracks completeness continuously — not just at initial documentation.
Each Annex IV section has a structured workspace — required content fields and an evidence upload area. The owner works through sections in order. Section completeness is tracked as a measurable governance state.
When sections are completed, the platform generates a completeness signal showing which sections are complete, in progress, or missing. The supervisor receives this signal before the approval request — not as a surprise during review.
The supervisor reviews Annex IV completeness as part of the approval workflow. Incomplete sections can trigger a return request. Approval is only granted when documentation completeness meets the required standard.
System changes — in architecture, data, deployment, or purpose — require documentation updates. EAB tracks which sections are affected by system changes and flags them for review. Documentation stays current, not static.
A PDF in a folder is not Annex IV compliance. EAB tracks each section — with evidence, ownership, and a readiness status that can be shown to regulators.
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