Conformity Assessment Checklist
Complete EU AI Act conformity assessment checklist covering Articles 9-17, 47, 48, 71, 72.
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This checklist provides a comprehensive guide for conducting conformity assessments of high-risk AI systems per EU AI Act requirements. It ensures all necessary requirements are verified before placing high-risk AI systems on the market or putting them into service.
- Complete this checklist for all HIGH-RISK AI systems before deployment
- Mark each requirement as Met, Partially Met, Not Met, or Not Applicable
- Document evidence and location for each requirement
- Address all "Not Met" and "Partially Met" items before proceeding
- Obtain all required approvals before issuing EU Declaration of Conformity
1.1AI system risk classification completed (FORM-AI-CLS-001)
Partial1.2System confirmed as high-risk
Partial1.3Conformity assessment path determined (internal vs. third-party). Note: Art. 43(2) mandates internal control (Annex VI) for Annex III points 2-8; for Annex III point 1, Art. 43(1) provides a choice but defaults to third-party (Annex VII) when harmonised standards are not applied.
Partial1.4Technical documentation prepared per Annex IV
Partial1.5All development phase requirements completed
Partial1.6Risk assessment completed (FORM-AI-RM-001)
Partial1.7Testing and validation completed
Partial2.1.1Risk management system established
Partial2.1.2Risk management system documented
Partial2.1.3System maintained throughout AI lifecycle
Partial2.1.4System includes iterative process
Partial2.2.1Known and foreseeable risks identified
Partial2.2.2Risks to health assessed
Partial2.2.3Risks to safety assessed
Partial2.2.4Risks to fundamental rights assessed
Partial2.2.5Risks from intended use assessed
Partial2.2.6Risks from reasonably foreseeable misuse assessed
Partial2.2.7Post-market monitoring data considered
Partial2.3.1Risk mitigation measures implemented
Partial2.3.2Residual risks are acceptable
Partial2.3.3Residual risks communicated to deployers
Partial2.3.4Measures proportionate to risks
Partial2.4.1Testing procedures defined for risk management
Partial2.4.2Testing conducted at appropriate development stages
Partial2.4.3Testing against clearly defined metrics
Partial2.4.4Real-world testing conducted where appropriate
Partial3.1.1Data governance and management practices established
Partial3.1.2Design choices for data documented
Partial3.1.3Data collection processes documented
Partial3.1.4Data preparation operations documented
Partial3.2.1Training datasets clearly identified
Partial3.2.2Validation datasets clearly identified
Partial3.2.3Testing datasets clearly identified
Partial3.2.4Data provenance documented
Partial3.2.5Data labeling procedures documented
Partial3.3.1Data is relevant to intended purpose
Partial3.3.2Data is sufficiently representative
Partial3.3.3Data is free from errors to the extent possible
Partial3.3.4Data is complete for intended purpose
Partial3.3.5Appropriate statistical properties for target group
Partial3.4.1Possible biases in datasets examined
Partial3.4.2Biases affecting health, safety, fundamental rights identified
Partial3.4.3Appropriate bias mitigation measures applied
Partial3.5.1Personal data processing complies with GDPR
Partial3.5.2Special category data processing justified
Partial3.5.3DPIA completed where required
Partial4.1.1Intended purpose described
Partial4.1.2Provider name and contact provided
Partial4.1.3System version/release identified
Partial4.1.4Interaction with hardware/software described
Partial4.1.5Forms of AI system distribution described
Partial4.2.1System architecture described
Partial4.2.2Main components described
Partial4.2.3Development process described
Partial4.2.4Computational resources documented
Partial4.2.5Third-party tools/components identified
Partial4.3.1AI methods and algorithms described
Partial4.3.2Design specifications documented
Partial4.3.3Key design choices explained
Partial4.3.4Trade-offs documented
Partial4.3.5Main classification choices documented
Partial4.4.1Capabilities clearly described
Partial4.4.2Limitations clearly described
Partial4.4.3Accuracy levels documented
Partial4.4.4Foreseeable unintended outcomes documented
Partial4.4.5Potential risks to health/safety/fundamental rights documented
Partial4.5.1Validation procedures documented
Partial4.5.2Testing procedures documented
Partial4.5.3Metrics used documented
Partial4.5.4Test results documented
Partial4.5.5Performance against target groups documented
Partial4.6.1Risk management system documented
Partial4.6.2Identified risks documented
Partial4.6.3Mitigation measures documented
Partial4.7.1Substantial changes documented
Partial4.7.2Change impact assessments documented
Partial5.1.1Automatic logging capability implemented
Partial5.1.2Events recorded throughout system operation
Partial5.1.3Recording period identification of use documented
Partial5.1.4Monitoring of operation enabled
Partial5.2.1Date/time of system use logged
Partial5.2.2Reference database (input data) logged
Partial5.2.3Input data that led to match logged
Partial5.2.4Identity of natural persons involved in verification logged
Partial5.3.1Logs secured against tampering
Partial5.3.2Logs retained for appropriate period
Partial5.3.3Logs accessible to competent authorities
Partial6.1.1System designed for transparency
Partial6.1.2Operation sufficiently transparent for deployers
Partial6.1.3Deployers can interpret output
Partial6.1.4Deployers can use output appropriately
Partial6.2.1Instructions for use provided
Partial6.2.2Provider identity included
Partial6.2.3Intended purpose described
Partial6.2.4Performance levels documented
Partial6.2.5Known circumstances affecting performance documented
Partial6.2.6Human oversight measures described
Partial6.2.7Expected lifetime documented
Partial6.2.8Maintenance requirements documented
Partial7.1.1System designed for human oversight
Partial7.1.2Human oversight proportionate to risks
Partial7.1.3Oversight during period of use enabled
Partial7.2.1Persons can fully understand system capabilities
Partial7.2.2Persons can fully understand system limitations
Partial7.2.3Persons can detect automation bias
Partial7.2.4Persons can correctly interpret output
Partial7.2.5Persons can decide not to use or disregard output
Partial7.2.6Persons can intervene on operation
Partial7.2.7Persons can stop system via "stop" button
Partial7.3.1If system has high autonomy, measures identified for risk
Partial7.3.2Measures proportionate to automation level
Partial8.1.1Appropriate level of accuracy achieved
Partial8.1.2Accuracy levels declared in instructions
Partial8.1.3Accuracy metrics appropriate for intended purpose
Partial8.2.1Appropriate level of robustness achieved
Partial8.2.2Resilience to errors, faults, inconsistencies
Partial8.2.3Robustness through technical redundancy
Partial8.2.4Fail-safe mechanisms implemented
Partial8.3.1Appropriate level of cybersecurity achieved
Partial8.3.2Resilient against unauthorized third-party access
Partial8.3.3Resilient against adversarial manipulation
Partial8.3.4Protection against data poisoning
Partial8.3.5Protection against model manipulation
Partial8.3.6Protection against input manipulation
Partial9.1QMS established
Partial9.2QMS documented
Partial9.3QMS implemented
Partial9.4QMS maintained
Partial9.5Strategy for regulatory compliance documented
Partial9.6Design, verification, validation procedures documented
Partial9.7Systems and procedures for data management documented
Partial9.8Risk management system documented
Partial9.9Post-market monitoring documented
Partial9.10Procedures for incident reporting documented
Partial9.11Communication with competent authorities documented
Partial9.12Resource management documented
Partial9.13Accountability framework documented
Partial10.1Post-market monitoring system established
Partial10.2System proportionate to AI technology
Partial10.3Data actively collected
Partial10.4Data reviewed and analyzed
Partial10.5Compliance with requirements evaluated
Partial10.6System integrated into QMS
Partial10.7Post-market monitoring plan documented
Partial10.8Plan included in technical documentation
Partial11.1Declaration prepared in required format
Partial11.2Provider name and address included
Partial11.3AI system identification included
Partial11.4Statement of conformity included
Partial11.5Reference to standards/specifications made
Partial11.6Notified body details included (if applicable)
Partial11.7Declaration dated
Partial11.8Declaration signed by authorized representative
Partial11.9Declaration kept for 10 years
Partial11.10Translation available in required languages
Partial12.1CE marking affixed (if required)
Partial12.2Marking visible, legible, indelible
Partial12.3Marking accompanied by notified body number (if applicable)
Partial12.4Marking affixed before placing on market
Partial13.1AI system registered in EU database
Partial13.2Registration completed before placing on market
Partial13.3Required information provided
Partial13.4Registration kept up to date
Partial13.5Registration reference documented
Partial1. Pre-Assessment[ ] Pass [ ] Fail
Not Started2. Risk Management (Art. 9)[ ] Pass [ ] Fail
Not Started3. Data Governance (Art. 10)[ ] Pass [ ] Fail
Not Started4. Technical Documentation (Art. 11)[ ] Pass [ ] Fail
Not Started5. Record-Keeping (Art. 12)[ ] Pass [ ] Fail
Not Started6. Transparency (Art. 13)[ ] Pass [ ] Fail
Not Started7. Human Oversight (Art. 14)[ ] Pass [ ] Fail
Not Started8. Accuracy/Robustness/Security (Art. 15)[ ] Pass [ ] Fail
Not Started9. Quality Management (Art. 17)[ ] Pass [ ] Fail
Not Started10. Post-Market Monitoring (Art. 72)[ ] Pass [ ] Fail
Not Started11. EU Declaration of Conformity[ ] Pass [ ] Fail
Not Started12. CE Marking[ ] Pass [ ] Fail
Not Started13. EU Database Registration[ ] Pass [ ] Fail
Not Started1[ ] Complete [ ] In Progress [ ] Not Started
Not Started2[ ] Complete [ ] In Progress [ ] Not Started
Not Started3[ ] Complete [ ] In Progress [ ] Not Started
Not Started4[ ] Complete [ ] In Progress [ ] Not Started
Not Started5[ ] Complete [ ] In Progress [ ] Not Started
Not Started1Technical Documentation
Not Started2EU Declaration of Conformity
Not Started3Test Reports
Not Started4Risk Assessment
Not Started5QMS Documentation
Not Started6Notified Body Certificate
Not Started