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EU AI Act Annex IV artifact mapping

Regulation (EU) 2024/1689 (the EU AI Act), Annex IV - technical documentation.

This document lists PEAC surfaces that can be used as supporting evidence toward the Annex IV technical-documentation points §1(a) through §5 that a provider or deployer may reference when building their technical file. The scope is narrow: every row points at a concrete PEAC artifact (spec, fixture, test, package, or generated artifact) that may help evidence a given Annex IV requirement. Every row also states explicitly what PEAC does not do for that row.

This document is not a claim that PEAC satisfies Annex IV end-to-end. It is not a substitute for the provider or deployer technical documentation. It is a mapping that helps route an Annex IV checklist to the underlying PEAC artifacts where supporting evidence exists.

Applicability context: Regulation (EU) 2024/1689 entered into force on 1 August 2024 and applies from 2 August 2026, with exceptions under Article 113. This mapping is limited to PEAC artifacts that may support Annex IV technical documentation. It does not determine whether a system is high-risk and does not determine a provider's or deployer's obligations.

Scope and framing

  • Regulation: Regulation (EU) 2024/1689 (the EU AI Act).
  • Annex: Annex IV (technical documentation required by Article 11).
  • Section scope: Annex IV §1(a) through §5.
  • Artifact scope: PEAC surfaces that a provider or deployer can reference as supporting artifacts in their technical file.
  • Non-claim: PEAC does not perform provider classification, risk-category determination, conformity assessment, post-market monitoring, or any other Article- or Annex-level duty owed by a provider or deployer. PEAC provides portable signed interaction records and verification surfaces that a technical-documentation team can consume as evidence inputs.

Column legend

  • Annex IV §: Annex IV section reference and short requirement phrase.
  • PEAC primitive: the PEAC concept that produces the supporting evidence.
  • Artifact surface: concrete file, package, spec, fixture, or API endpoint under this repository. Every non-out-of-scope row MUST include at least one outward-facing stable artifact surface (one of docs/, specs/, contracts/, surfaces/, packages/schema/openapi/, or REPO_SURFACE_STATUS.json); internal src/ paths may appear only as secondary links.
  • Verification hint: concrete path, endpoint, fixture, or CI command an evaluator runs to verify the row.
  • Coverage qualifier: one of supports, can be used as evidence toward, provides primary artifact for, provides supporting artifact for, helps evidence, out-of-scope for PEAC.
  • Non-claim: explicit statement of what PEAC does not do for this row; one of PEAC does not do X, operator-owned, requires upstream attestation, evidence only; not a conformance claim.
  • Cross-reference: related Annex IV sections, related PEAC trust artifacts, and related ISO 42001 mapping rows; markdown links in this column must resolve.

Mapping

Annex IV § Requirement (short) PEAC primitive Artifact surface Verification hint Coverage qualifier Non-claim Cross-reference
1(a) General description of the AI system and intended purpose Declared-purpose claim on every record; purpose pillar classification docs/profiles/purpose.md, docs/specs/WIRE-0.2.md Issue a record with declared purpose; verify the purpose claim round-trips against the schema section of docs/specs/WIRE-0.2.md. provides supporting artifact for operator-owned. The provider owns the general-description text; PEAC records the purpose declared on each observed interaction that the text refers to. ISO 42001 Annex A A.9
1(b) Versions of relevant software or firmware and any requirement related to version update Stability contract per public surface, package version map, release history, published OpenAPI version header docs/STABILITY-CONTRACT.md, docs/PACKAGE_STATUS.md, CHANGELOG.md, packages/schema/openapi/verify.yaml Inspect info.version in packages/schema/openapi/verify.yaml; cross-check against docs/PACKAGE_STATUS.md and CHANGELOG.md. supports operator-owned. PEAC publishes its own versioning discipline; the provider owns their AI system's version documentation.
1(c) Description of the hardware on which the AI system is intended to run out-of-scope for PEAC - - out-of-scope for PEAC PEAC does not document hardware.
1(d) Description of the product of which the AI system is a component out-of-scope for PEAC - - out-of-scope for PEAC PEAC does not document product composition.
1(e) Description of all forms in which the AI system is placed on the market or put into service out-of-scope for PEAC - - out-of-scope for PEAC PEAC does not document distribution channels.
1(f) Description of user interface out-of-scope for PEAC - - out-of-scope for PEAC PEAC does not document user interfaces.
1(g) Instructions for use and installation instructions out-of-scope for PEAC - - out-of-scope for PEAC PEAC does not produce product instructions for third-party AI systems.
2(a) Methods and steps performed for development of the AI system Development-surface records; verification records across tool-call, API, MCP, A2A, commerce, and cross-runtime surfaces docs/specs/EVIDENCE-CARRIER-CONTRACT.md, docs/compatibility/core-use-case-coverage.md Sample records from each covered surface in docs/compatibility/core-use-case-coverage.md; verify each against the carrier contract in docs/specs/EVIDENCE-CARRIER-CONTRACT.md. can be used as evidence toward evidence only; not a conformance claim. PEAC can record the observed interactions during development; the provider owns the methodology description. ISO 42001 Clause 8.1
2(b) Design specifications including general logic of the AI system out-of-scope for PEAC - - out-of-scope for PEAC PEAC does not document AI system internal design.
2(c) Description of the system architecture explaining how software components build on each other out-of-scope for PEAC - - out-of-scope for PEAC PEAC does not document third-party AI system architecture.
2(d) Data sheets describing training methodologies and techniques out-of-scope for PEAC - - out-of-scope for PEAC PEAC does not produce training-data documentation.
2(e) Assessment of human oversight measures needed Portable signed records that support human review; back-reference via receipt_ref to the exact observed record docs/specs/EVIDENCE-CARRIER-CONTRACT.md, docs/HOW-IT-WORKS.md Extract receipt_ref per docs/specs/EVIDENCE-CARRIER-CONTRACT.md; confirm back-reference resolves to the observed record. helps evidence operator-owned. PEAC records enable reviewer back-reference to the observed interaction; the provider assesses and documents the oversight measures.
2(f) Description of predetermined changes to the AI system and its performance Stability contract deprecation schedule, deprecation policy docs/STABILITY-CONTRACT.md, docs/DEPRECATION_POLICY.md Inspect the deprecation schedule in docs/DEPRECATION_POLICY.md; cross-check against docs/STABILITY-CONTRACT.md. supports operator-owned. PEAC publishes its own change-control artifacts; the provider owns the AI system's predetermined-change documentation.
2(g) Validation and testing procedures used Conformance suite, requirement ID index, benchmark methodology, CI verification workflows specs/conformance/, specs/conformance/requirement-ids.json, docs/BENCHMARK-METHODOLOGY.md Run the conformance suite under specs/conformance/; reproduce benchmarks per docs/BENCHMARK-METHODOLOGY.md. provides supporting artifact for evidence only; not a conformance claim. PEAC publishes its own conformance and benchmark discipline; the provider owns the AI system's validation and testing procedures. ISO 42001 Clause 9.1
2(h) Cybersecurity measures Threat model, security operations document, JOSE hardening, SSRF prevention, signing-key custody docs/THREAT_MODEL.md, docs/SECURITY-OPERATIONS.md, docs/specs/SECURITY-CONSIDERATIONS.md, docs/KEY-CUSTODY-AND-TENANCY.md Review docs/THREAT_MODEL.md threat IDs and their linked test paths; verify per-threat coverage links resolve. provides supporting artifact for operator-owned. PEAC publishes its own cybersecurity artifacts; the provider owns AI system cybersecurity documentation.
3 Detailed description of the monitoring, functioning and control of the AI system Offline-verifiable signed interaction records; reference verifier; verifier security model spec docs/HOSTED_VERIFY_CONTRACT.md, docs/specs/VERIFIER-SECURITY-MODEL.md, surfaces/reference-verifier/ Run surfaces/reference-verifier/smoke.sh against the reference deployment. provides supporting artifact for operator-owned. PEAC supplies the record and verification surfaces; the provider documents the AI system's monitoring and control.
4 Description of appropriateness of the performance metrics Benchmark methodology, published SLO baseline stamps docs/BENCHMARK-METHODOLOGY.md, docs/SLO.md, specs/benchmarks/ Reproduce benchmarks per docs/BENCHMARK-METHODOLOGY.md; compare to baseline in specs/benchmarks/. helps evidence operator-owned. PEAC publishes its own engineering metrics; the provider selects and justifies the AI system's metrics.
5 Detailed description of the risk management system in accordance with Article 9 out-of-scope for PEAC - - out-of-scope for PEAC PEAC does not implement a risk management system. The provider builds the risk-management system and may reference PEAC records as input evidence. ISO 42001 Clause 6.1

What PEAC does not do for Annex IV

  • PEAC does not produce product-level documentation, user interfaces, or installation instructions for third-party AI systems.
  • PEAC does not describe training methodology, training data, or AI-system internal design.
  • PEAC does not perform risk-management activities.
  • PEAC does not determine provider or deployer classification or risk category.
  • PEAC does not perform conformity assessment, CE marking, or post-market monitoring.

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