Annex IV is often mentioned when people talk about the EU AI Act, usually with a sense of urgency. It is described as a major documentation burden, sometimes even as something teams should prepare immediately, regardless of where they are in development.
That framing causes unnecessary confusion.
For most teams, Annex IV is neither an immediate obligation nor a distant abstraction. It sits in between. Understanding its purpose is far more useful than treating it as a checklist.
Annex IV defines the technical documentation that certain AI system providers must be able to produce. Its role is not to force exhaustive technical disclosure. Its role is to preserve traceability. In practice, this means being able to explain what a system is, why it was designed the way it was, and how risks were identified and addressed.
This is about accountability over time, not paperwork.
Responsibility for Annex IV documentation usually lies with the provider of the AI system. This is typically the organization that develops the system or places it on the EU market under its own name. Deployers are not normally expected to create this documentation themselves, but they often rely on it, especially when systems are integrated into larger workflows or used in new contexts.
Annex IV does not apply to every AI system. It becomes relevant mainly when a system is classified as high risk under the EU AI Act. If a system does not fall into that category, the formal Annex IV requirements do not apply, although basic documentation and governance still matter for future reassessment.
This distinction is where many teams misjudge timing. Some assume Annex IV must be prepared immediately for any AI system. Others delay documentation entirely, believing it only matters at deployment. In reality, the obligation may come later, but the inputs that make documentation meaningful are created much earlier.
Annex IV is also commonly misunderstood as a final deliverable produced at the end of development. That rarely works in practice. The elements that Annex IV draws on are design decisions, data assumptions, performance trade-offs, and risk controls. These are not decisions teams reconstruct accurately months later. They emerge gradually as the system is built.
When teams try to recreate this context under pressure, documentation tends to become vague or overly verbose without adding clarity.
In practical terms, Annex IV documentation usually brings together a limited set of core elements:
- what the system is intended to do and where it is used
- how it functions at a high level
- how data was selected and evaluated
- which risks were identified and how they were mitigated
- how human oversight is implemented and where limits exist
The level of detail should reflect the system’s impact. Proportionality matters more than volume.
Most difficulties with Annex IV come down to mindset. Teams either treat it as a legal form to be filled later, or they over-engineer documentation far beyond what is required. Both approaches create unnecessary friction.
A more useful question than “Do we need Annex IV now?” is this: would we be able to explain this system clearly and consistently a year from now? If the answer is uncertain, documentation debt is already forming, regardless of whether the obligation has formally started.
Annex IV is not about satisfying regulators with documents. It is about preserving understanding as systems evolve. Teams that capture intent and risk decisions as part of normal development rarely struggle later, even when formal requirements begin to apply.