V77 Trust

High-risk obligations, simply put

What providers and deployers of high-risk AI must do, item by item, without the legal language.

2 min read·Updated 8 November 2026Compliance leadsProduct ownersEngineers

If you're the provider

  1. 1
    Risk management (Art. 9): identify and reduce risks throughout the system's life, and test against them.
  2. 2
    Data governance (Art. 10): use training and test data that is relevant, representative and as error-free as possible, and check it for bias.
  3. 3
    Technical documentation (Art. 11, Annex IV): describe how the system works, how it was built and tested, and its limits.
  4. 4
    Record-keeping (Art. 12): the system must log events automatically, so problems can be traced.
  5. 5
    Transparency to deployers (Art. 13): give clear instructions for use, including accuracy and known limits.
  6. 6
    Human oversight (Art. 14): design it so people can understand, monitor, override and stop it.
  7. 7
    Accuracy, robustness and cybersecurity (Art. 15): perform consistently and resist errors and attacks.
  8. 8
    Quality management system (Art. 17), conformity assessment (Art. 43), EU declaration of conformity, CE marking and registration in the EU database (Art. 49).
  9. 9
    Post-market monitoring (Art. 72) and serious incident reporting (Art. 73).

If you're the deployer

  1. 1
    Use the system according to the provider's instructions.
  2. 2
    Assign human oversight to people with the competence, training and authority to do it.
  3. 3
    Make sure input data you control is relevant for the purpose.
  4. 4
    Monitor how it works and tell the provider (and in some cases the authority) about risks and serious incidents.
  5. 5
    Keep the automatically generated logs for at least six months.
  6. 6
    Tell workers and their representatives before using high-risk AI at work.
  7. 7
    Tell people when a high-risk system makes or helps make decisions about them.
  8. 8
    Do a fundamental rights impact assessment first if you're a public body, a private company providing public services, or you use AI for credit scoring or life and health insurance pricing (Art. 27).

When

Annex III systems: 2 December 2027. Annex I products: 2 August 2028.

Tip

In V77 Trust each of these is a control with its own evidence. Mark a control implemented only once the evidence is uploaded; that's what an auditor will ask for.

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This page explains the law to help you find your way. It isn't legal advice.

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