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AI Compliance Assistant · Provider Obligations

Fulfil provider obligations (conditional chapter)

Updated on 11 min Pro plan Open in Cenedril

Goal For systems in the provider role, generate the AI provider policy, compile the technical documentation under Annex IV, choose the conformity assessment procedure, send the declaration for signature and define the monitoring plan.

In the AI Compliance Assistant you fulfil the provider obligations of the AI Act in the Provider Obligations chapter: you generate the AI Provider Policy, compile the Technical Documentation under Annex IV for each system, choose the assessment procedure on the Declaration of Conformity page and send the EU declaration of conformity for signature, and you define the monitoring plan under Post-Market Monitoring. The chapter only appears when a system is classified in your own provider role or a system held as importer carries the high risk class. At the end, policy, documentation, declaration and plan are stored as documents and records in Cenedril.

Open the chapter

Open Provider Obligations from the overview

In the sidebar open Wizards, select the Artificial Intelligence card and click the Provider Obligations row in the chapter list of the overview. The opening page explains why the obligations apply and names the four steps of the chapter: AI provider policy, Technical documentation, Declaration of conformity and Post-market monitoring.

Continue to the provider policy

Click Next at the bottom. The progress bar at the top lists the pages of the chapter in the order in which they build on each other; you can also open any page directly from there.

Generate the AI provider policy

Check the basis

The AI Provider Policy page records the quality management system under Art. 17 in writing: for each aspect the rule in force and the document that carries it out. The card above the editor shows the AI officer from the AI roles; that person appears in the policy as responsible for the quality management system. If nobody is named, the Edit AI roles link leads to the roles page. If your organisation is established outside the Union, the block Authorised representative mandate (Art. 22) is also available with a contract proposal that Copy text places on the clipboard.

Generate the draft

Select the language in the editor using the flags and click Generate Document. The draft is built from the organisational context, the organisation profile, the AI roles and the classification of the systems; whatever is missing there is missing from the text as well. Only the selected language is generated. Regenerate overwrites the displayed text completely after confirmation.

Edit three places

The draft proposes criteria for a substantial modification, the testing rhythm with metrics and release threshold, and security of supply for purchased models, computing power and tools. Cenedril keeps no fields for these three points; adapt them directly in the editor to your release practice. If the box The basis of this policy has changed appears above the editor, a chapter switch has flipped after generation, for example the route with a notified body. Then regenerate, or add the paragraph by hand and close the box with Already covered.

Set up the annual review

Under Annual review of the AI provider policy, create the recurring reminder with Set reminder (yearly). The recipient list is prefilled with the AI officer. The reminder is created immediately, independent of saving the page.

Save the policy

Save as Draft secures the editor content of both languages without publishing anything. Save & Continue publishes the policy, creates one document version per language with content and leads to the Technical Documentation. If both languages are empty, the page rejects the click with an error message. The policy is then approved in the documentation area; you set the completion mark under Policies & Documents with Complete.

Compile the technical documentation

Open the system card

The Technical Documentation page shows one expandable card per system with the provider role, with system name and risk class. For High risk and for the exemption cases under Art. 6(3) the card holds the full Annex IV dossier: the blocks Asset data, Training data, the questionnaire, Evidence (PDF upload) and the Technical documentation editor. For Limited risk (transparency) and Minimal risk the card shows only the three records Design and system architecture, Verification and validation and Instructions for use. The card Authorised representative in the Union (Art. 22) above the system cards is for viewing only; the designation is maintained in the organisation profile.

Maintain the asset data

In the Asset data block, enter the Version of the system and check the model fields, such as Model Type, Learning approach, ML Framework, Deployment Model, Model Version and Accuracy / Performance Metrics. These details belong to the asset itself: a change is saved as soon as you leave the field, independent of the footer, and takes effect everywhere the asset is read.

The “Asset data” block saves every change directly to the asset, independent of the page footer.

Complete the training data

The Training data block lists the datasets linked to the system in the AI register; linking and unlinking happens there. Here you fill in the groups Origin and scope, Labelling, Bias examination, Data quality and Retention and disposal for each dataset. These fields are also saved immediately to the dataset.

Fill in the questionnaire

Work through the questionnaire in the order of Annex IV: System and deployment, Development procedures, Data and data governance, Testing and performance, Technical operating assumptions, Interpreting and using the output, Cybersecurity, Logging, Applied standards and Value chain (Art. 25(4)). Under Performance metrics (Annex IV No. 4) choose the metrics first; the rows for the acceptance thresholds and the accuracy by domain are derived from them. The questionnaire answers reach the record only through the footer.

Upload the evidence

Under Evidence (PDF upload) each annex takes exactly one PDF file of up to 20 MB: Annex A: Architecture and data-flow diagrams, Annex C: Test reports and benchmark results and Annex E: Instructions for use (Art. 13). For the instructions for use, the link under Or link to the online/wiki version is sufficient as an alternative. Uploaded files are stored immediately; the link is saved with the footer. Which information does Article 13(3) require? opens the list of minimum contents your instructions for use must contain.

Generate and save the document

In the Technical documentation editor, click Generate Document. The Annex IV document is built from the entries on the card, the AI register, the impact assessment, the risk scenarios and the organisation profile; the state of the annexes is described as it is at that moment. Save & Continue creates the record “Technical documentation (AI)” for each system with generated text, which is approved under records, and leads to the Declaration of Conformity.

Choose the conformity assessment procedure and send the declaration

Set the procedure

On the Declaration of Conformity page one card appears per high-risk system in the provider role. Under Conformity assessment procedure choose between Internal control (Annex VI) and Assessment by a notified body (Annex VII); if the system is an Annex I product in the classification, Sectoral product procedure (Annex I) is available as well. The choice determines section 7 of the declaration. As soon as a declaration has been sent, has expired or has been signed, the choice is locked.

The “Conformity assessment procedure” choice with the card buttons Annex VI and Annex VII; after sending it is locked.

Check the internal control

For Annex VI the block Internal control (Annex VI point 3) opens. Two derived tables show which Particulars under Annex IV are recorded and which Requirements of Articles 8 to 15 are evidenced in the technical documentation. Close open items in the documentation, then tick The technical documentation has been verified against the requirements of Articles 8 to 15; the tick saves immediately. For Annex VII, fill in the fields Name of the body, Identification number (four digits) and Certificate number in the Notified body block.

Choose the language and read the preview

Above the preview, choose the official language under Language of the declaration. Below it Cenedril shows the EU declaration of conformity under Annex V as a certificate preview; there is no editor here, because Annex V prescribes the required particulars and their order. Read the preview once in full from top to bottom. A gap in the organisation profile or in the technical documentation remains visible in the finished legal document.

Send for signature

In the Signature block, fill in the Name, Function and Email of the authorised signatory and click Send for signature. Cenedril checks the required data under Annex V, freezes the text and emails the person a personal signature link; they do not need a Cenedril account. The status in the block shows Sent, Viewed, Signed, Expired or Revoked; as long as the declaration is unsigned, Resend and Revoke are available.

The preview of the declaration with the locked language selector and the “Signature” block in status “Sent” with “Resend” and “Revoke”.

Record market access after signing

Once signed, the card carries the Declaration signed badge, and the Signature block shows View record, Save as PDF and Machine-readable version (JSON). Only now does the card show the block Market access: CE marking and registration with Placed on market / put into service, CE marking (Art. 48), the member states of marketing, the registration field derived from the classification, the Accessibility check (Art. 16(l)) and the Annex VIII summary with Copy all. The blocks Keep documents available for ten years and Provider markings (Art. 16(b)) are available before signing.

After signing: the “Signature” block with “View record”, “Save as PDF” and “Machine-readable version (JSON)”; the “Declaration signed” badge sits in the card header, the “Market access” block follows below.

Save the conformity page

Under Conformity re-check after substantial modification at the bottom of the page, set up the recurring reminder. Save & Continue publishes the entries, creates the record “Internal control (AI)” for each system, transfers the market data to the AI register and leads to Post-Market Monitoring. If the system is substantially modified later, Revise declaration releases the procedure choice again; the signed version remains as a record.

Define the monitoring plan

Choose the cadence and the responsible person

The Post-Market Monitoring page shows one card per high-risk system in the provider role. Choose the Evaluation cadence (Continuous, Monthly, Quarterly, Semi-annually or Annually) and the Responsible person from the people in the asset register. The cadence follows how quickly the system can deteriorate unnoticed.

Tick the data sources

Under Data sources, tick the channels that are actually evaluated, such as Operation and performance logs (logs under Art. 12), Error and incident reports, Deployer feedback or Technical model monitoring (drift detection). Cadence and data sources enter chapter 9 of the technical documentation.

Define the trigger criterion

The Trigger criterion block determines from which monitoring result a review starts. The Operating margins (significant performance change) are only displayed here; they are maintained in the AI register. In addition, tick the Events that trigger on their own: Anomaly in operation, Near miss, Feedback from use, Complaint or Other event, which you name in the field below.

The trigger criterion: the operating margins from the AI register are displayed only, the triggering events are ticked here.

State an existing monitoring system

If the AI system is part of a product with its own statutory market surveillance, or your organisation is a financial institution subject to existing supervision, tick Monitoring is integrated into an existing statutory surveillance system. under Existing monitoring system and name the system in the field below. This means a statutory system; an internal quality management system or a monitoring dashboard is not sufficient.

Create the recurring evaluation and complete

Under Recurring evaluation, create the reminder once cadence and responsible person are set; the repetition follows the cadence, and the responsible person is prefilled as recipient if their person entry is linked to a user account. Save & Continue creates the record “Post-market monitoring plan (AI)” for each system and returns to the overview. The scheduled evaluation itself takes place later in the Post-market monitoring tool on the overview.

Update the technical documentation

Regenerate the document

Open the Technical Documentation page once more via the progress bar, click Regenerate in the editor and confirm with Yes, regenerate. Only now do annexes D and F name the issued declaration and the defined monitoring plan. Save & Continue creates the new version of the record.

Result: the AI Provider Policy is stored as a document version awaiting approval, each system has the records “Technical documentation (AI)”, “Internal control (AI)” and “Post-market monitoring plan (AI)” in Cenedril, the EU declaration of conformity has been sent for signature or is signed, and the overview shows the count Conformity declarations signed in the Provider Obligations row.

Frequently asked questions

Why is the “Provider Obligations” chapter greyed out in the overview?

The chapter becomes active as soon as an AI system is classified in your own provider role (provider, or provider and deployer, regardless of risk class) or a system held as importer carries the high risk class. As long as neither applies to any system, the row shows the note “Not required”. The role is determined on the “Roles and system risk” page of the classification.

Why does “Send for signature” stop with an error message?

Before sending, Cenedril checks the required data under Annex V. The most common gap is the missing answer under “Applied standards (Annex IV No. 7)” in the questionnaire of the technical documentation; “No harmonised standard and no common specification applied” counts as an answer there. On the Annex VII route the name, four-digit identification number and certificate number of the notified body must also be entered. The message names what is missing.

Can I still change the declaration of conformity after it has been signed?

The signed text is fixed. If the system is substantially modified, release the declaration via “Revise declaration”; the procedure choice and the entries can then be edited again and you issue a new declaration. The signed version remains as a record with signature, hash and audit trail.

Why does the technical documentation say that the declaration of conformity and the monitoring plan are still open?

The Annex IV document describes the state of the annexes at the moment it is generated. The declaration of conformity and the monitoring plan are created on the two pages after the technical documentation. Open the page once more afterwards, click “Regenerate” and save again; annexes D and F then name the actual state.

What does a provider system below the high-risk threshold see in this chapter?

On the “Technical Documentation” page a system with limited or minimal risk receives only the evidence area with the three uploads “Design and system architecture”, “Verification and validation” and “Instructions for use” under ISO/IEC 42001. Questionnaire, declaration of conformity and monitoring plan apply to high-risk systems and the exemption cases under Article 6(3); the monitoring plan applies to high-risk systems only.