Compliance Analysis Report

Evidence from document

“The technical specification describes the model architecture and training dataset, but contains no section on risk identification, risk estimation, risk evaluation, or residual risk controls as required by Art. 9(2).”

Recommendation

Implement and document a continuous risk management system covering the full lifecycle. At minimum: (1) identify known and foreseeable risks, (2) estimate and evaluate risks, (3) adopt risk management measures, (4) residual risk communication.

Evidence from document

“Section 4 ("System Description") describes intended use but omits: accuracy metrics disaggregated by demographic group, foreseeable unintended uses, and performance limitations under out-of-distribution inputs.”

Recommendation

Expand the instructions for use to include: (a) accuracy and performance metrics per subgroup, (b) known limitations and conditions under which accuracy degrades, (c) human oversight measures the deployer must implement.

Evidence from document

“No reference to a quality management system (QMS) or equivalent process is present in any of the scanned documents. Art. 17 requires providers of high-risk AI systems to put a QMS in place.”

Recommendation

Establish or reference an existing QMS covering: design and development controls, data governance procedures, post-market monitoring, incident reporting, and corrective action processes. ISO 42001 certification is a recognized approach.

Evidence from document

“The privacy policy (pages 3–4) describes data collection for "service improvement" without specifying the legal basis for automated profiling that affects user decisions.”

Recommendation

Add an explicit legal basis (Art. 6(1) GDPR) for each processing purpose involving automated decision-making. If relying on legitimate interests, document the balancing test. If consent-based, ensure granular consent mechanisms are implemented.

Evidence from document

“The document is dated but contains no version history or change log. Art. 11 and Annex IV require technical documentation to reflect the current version of the AI system and record significant changes.”

Recommendation

Add a version table at the beginning of the technical documentation recording: version number, date, description of changes, and responsible author. Maintain this log through the system lifecycle.