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19 changes: 14 additions & 5 deletions docs/verification.md
Original file line number Diff line number Diff line change
Expand Up @@ -167,8 +167,11 @@ them, and neither is a floor that is met.
elements Article 11(1) requires the technical documentation to contain at a minimum. It is
not a classification annex, since high-risk classification runs through Article 6 with
Annexes I and III, and neither Article 11 nor Annex IV imposes a verification obligation of
the kind `provenance_depth_verified` records. Two adjacent provisions are sometimes read as
supplying one, and neither does. Article 25(4), as amended by Regulation (EU) 2026/1744,
the kind `provenance_depth_verified` records. Article 12 does not impose one either, since it
requires that a high-risk system technically allow the automatic recording of events over its
lifetime, which is a capability requirement about logging rather than a statement about
provenance or build inputs. Two adjacent provisions are sometimes read as supplying one, and
neither does. Article 25(4), as amended by Regulation (EU) 2026/1744,
requires the provider of a high-risk AI system and a third party supplying an AI system, AI
model, tools, services, components or processes used or integrated in it to specify by
written agreement the information, capabilities, technical access and other assistance the
Expand All @@ -177,11 +180,17 @@ components other than general-purpose AI models publicly available under a free
open-source licence. Article 15(5) requires technical solutions addressing, where
appropriate, data poisoning, model poisoning, adversarial examples, confidentiality attacks
and model flaws, which is stated as an outcome rather than as a depth of supply-chain
verification. Articles 11, 15 and 25 sit in Sections 2 and 3 of Chapter III, whose
verification. Articles 11, 12, 15 and 25 sit in Sections 2 and 3 of Chapter III, whose
application Regulation (EU) 2026/1744 moved to 2 December 2027 for systems high-risk under
Article 6(2) and Annex III, and to 2 August 2028 for systems high-risk under Article 6(1)
and Annex I, subject to the Article 111(2) grace period for units of a type and model
already placed on the market.
and Annex I. Article 111(2), as replaced by the same Regulation, applies the AI Act to
operators of high-risk systems, other than the systems referred to in Article 111(1), that
have been placed on the market or put into service before that date of application, only if,
as from that date, those systems are subject to significant changes in their designs, and in
any case requires providers and deployers of high-risk systems intended to be used by public
authorities to take the necessary steps to comply by 2 August 2030. The reading that one unit
lawfully placed on the market or put into service carries the other units of the same type
and model is recital 39 of Regulation (EU) 2026/1744 rather than operative text.

**Regulation (EU) 2024/2847.** Annex I Part II point 1 requires manufacturers to identify
and document vulnerabilities and components, including by drawing up a software bill of
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