Agent Liability Europe

Readiness scorecard. Know where the file stands.

Twenty five questions across five obligation categories, each answered No, Partial or Yes for 0, 1 or 2 points, and one percentage at the end. Built against the Annex III obligations that apply from 2 December 2027. Free, anonymous, and nothing leaves your browser.

A. Risk managementCategory 1 of 5 · Articles 9 and 26

Risk management

Article 9 requires providers to establish a risk management system. Article 26 requires deployers to check that inputs are appropriate and to monitor use. These questions test whether the foundations are in place.

Has your organisation identified all high-risk AI systems it currently deploys or intends to deploy before 2 December 2027? Art. 26, Annex III

Has a formal risk assessment been conducted for each high-risk AI deployment, documented in writing? Art. 9, Art. 26

Does your organisation verify that input data fed to high-risk AI systems is relevant and sufficiently representative of the intended use? Art. 26(4)

Are risk management activities reviewed and updated when the deployment context changes materially? Art. 9(4)

Has responsibility for AI risk management been assigned to a named function or individual with adequate authority and resources? Art. 26

B. Human oversightCategory 2 of 5 · Articles 14 and 26(2)

Human oversight

Article 14 sets the oversight capabilities that must be built into high-risk systems. Article 26(2) requires deployers to assign oversight to natural persons with competence, authority and adequate support.

Are the persons assigned to human oversight of AI systems identified by name or role in writing? Art. 26(2)

Do oversight personnel have documented competence (training, qualifications, or experience) to understand AI system outputs and intervene effectively? Art. 26(2), Art. 14(4)

Do oversight personnel have the authority to stop, override, or disregard an AI system output without requiring senior approval? Art. 14(4)(e)

Is there a defined escalation path when the AI system outputs a result that the oversight person cannot validate or is uncertain about? Art. 14(4)

Is human oversight practically exercised before any AI-assisted decision with legal or similarly significant effect on a natural person is finalised? Art. 14(2), Art. 26(2)

C. Documentation and loggingCategory 3 of 5 · Article 26(6)

Documentation and logging

Article 26(6) requires deployers to keep automatically generated logs for the period applicable law sets. These questions test whether documentation and logs would hold up in an enforcement inquiry.

Are automatically generated logs from your high-risk AI systems retained for at least the period required by Union or national law (minimum 6 months where no specific period is prescribed)? Art. 26(6)

Does your organisation hold the technical documentation or information sheet provided by the AI system provider in accordance with Article 13? Art. 13, Art. 26(1)

Is there an internal AI deployment record that captures: system name, provider, deployment date, intended purpose, and the oversight person assigned? Art. 26

Can your organisation produce a complete log of AI-assisted decisions on a specific natural person within 5 working days if requested by a supervisory authority or affected individual? Art. 26(6), Art. 86 AI Act

Where a FRIA is required under Article 27, has it been completed and filed before the system went into service? Art. 27

D. Transparency to affected partiesCategory 4 of 5 · Articles 13 and 26

Transparency to affected parties

Article 13 requires providers to design systems so that deployers can inform people they are subject to AI decisions. Article 26 obliges deployers to pass that information on. These questions test your disclosure.

Are affected persons informed, before or at the time of an AI-assisted decision, that the decision was supported or produced by an AI system? Art. 13(1), Art. 26

Can an affected person request and receive a meaningful explanation of how an AI-assisted decision was reached? Art. 13(3)(b), Art. 86 AI Act

Is the intended purpose of each high-risk AI system disclosed to users and affected persons in plain language? Art. 13(3)(a)

Has your organisation reviewed its privacy notices and terms of service to ensure AI processing is disclosed consistently with GDPR obligations? Art. 13 AI Act, Art. 13/14 GDPR

Where the AI system operates in a language other than the default language of affected persons, are disclosures provided in the relevant language? Art. 13(1)

E. Incident response and monitoringCategory 5 of 5 · Article 26(5)

Incident response and monitoring

Article 26(5) requires deployers to notify providers and, where required, national authorities of serious incidents. These questions test whether incident handling and monitoring work in practice.

Does your organisation have a written procedure for detecting and escalating serious incidents involving high-risk AI systems? Art. 26(5)

Is the relevant national market surveillance or supervisory authority identified, and is there a process for notifying them of serious incidents within the required timeframe? Art. 26(5), Art. 73

Is the performance and accuracy of each high-risk AI system monitored on an ongoing basis after deployment? Art. 26(5)

Is there a mechanism for internally reporting AI performance concerns or potential malfunctions by any staff member who interacts with the system? Art. 26(5)

Has your organisation communicated AI incident reporting obligations to the provider, and confirmed contractually that the provider will notify you of incidents on their side? Art. 25, Art. 26(5)

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Next steps for the file

The Annex III obligations apply from 2 December 2027. An operator that starts its documentation now has time to iterate before they apply. The FRIA checklist sets out a working order, and the FRIA generator produces a first draft in about fifteen minutes.

FRIA generator     FRIA checklist     Article 27 guide     All tools