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ObligationUpcomingv1.0.0

Article 18: documentation keeping

The provider of a high-risk AI system keeps the technical documentation, the quality management system documentation, the changes approved by notified bodies and the decisions they issued, and the EU declaration of conformity at the disposal of the national competent authorities for a period ending ten years after the system has been placed on the market or put into service.

The official source remains authoritative. This is general information about obligations and not legal advice. See this object on the map

Address and citation

This object has an address of its own that is never renamed or reused. Store the identifier in your own file, not the title or the link.

Identifier
praxikon:eu:ai-act:obligation:article-18-document-retention
Payload hash (sha256)
0971f35c7a7daaf1306f4fbd7ae98680b8b1e2da44b5a84a5abf7d7610cbdbfb

Citation line

Praxikon, "Article 18: documentation keeping", praxikon:eu:ai-act:obligation:article-18-document-retention@1.0.0, dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.2.0 (schema 1.5.0), effective_at 2026-08-08T00:00:00.000Z, known_at 2026-09-06T00:00:00.000Z, sha256 0971f35c7a7daaf1306f4fbd7ae98680b8b1e2da44b5a84a5abf7d7610cbdbfb
Version
1.0.0
Legal time (effective_at)
27 July 2026
Knowledge time (known_at)
14 August 2026
Closed on
Not closed
Application date
2 December 2027
Topics
high-risk-requirements

Review status: Placed against the official source (14 August 2026). Next check due by 10 February 2027. The check date is the knowledge date of this version; no later recheck has been recorded.

Who must act and who is affected

On an obligation the addressee is recorded separately from the party that is merely affected. That difference decides who a supervisory authority addresses and who has work to do without the duty resting on them.

Duty holder

Affected actor

Oversight

Not recorded on this object.

Evidence owner

What this object links to

Every relation appears below as a path: from the source with its locator, through the conditions and exceptions of the object carrying the relation, to the consequence. A locator belongs to a statement in the data and not to a relation, so the source is the source anchor of the carrying object.

Who carries the duty

1 of 1 shown

The duty rests on this role. A supervisory authority addresses this role when it is not met.

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 18(1)-(3)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allApplies to the provider of a high-risk AI system. The period ends ten years after the system has been placed on the market or put into service.
    • Condition | allWhere the provider is a financial institution subject to requirements regarding internal governance, arrangements or processes under Union financial services law, it maintains the technical documentation of point (a) as part of the documentation it already keeps under that law. That is not an exemption from the retention duty but an indication of the regime in which it is carried out for that one component. Paragraph 3 does not mention points (b) to (e).

    Consequence

Who is affected without being the addressee

2 of 2 shown

This role is practically affected without being the addressee: it receives the information, has to cooperate, or absorbs the consequences in its own process.

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 18(1)-(3)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allApplies to the provider of a high-risk AI system. The period ends ten years after the system has been placed on the market or put into service.
    • Condition | allWhere the provider is a financial institution subject to requirements regarding internal governance, arrangements or processes under Union financial services law, it maintains the technical documentation of point (a) as part of the documentation it already keeps under that law. That is not an exemption from the retention duty but an indication of the regime in which it is carried out for that one component. Paragraph 3 does not mention points (b) to (e).

    Consequence

Who owns the evidence

1 of 1 shown

This duty holder creates, maintains and can produce the evidence.

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 18(1)-(3)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allApplies to the provider of a high-risk AI system. The period ends ten years after the system has been placed on the market or put into service.
    • Condition | allWhere the provider is a financial institution subject to requirements regarding internal governance, arrangements or processes under Union financial services law, it maintains the technical documentation of point (a) as part of the documentation it already keeps under that law. That is not an exemption from the retention duty but an indication of the regime in which it is carried out for that one component. Paragraph 3 does not mention points (b) to (e).

    Consequence

What has to be done

1 of 1 shown

This is what concretely has to be done under the obligation.

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 18(1)-(3)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allApplies to the provider of a high-risk AI system. The period ends ten years after the system has been placed on the market or put into service.
    • Condition | allWhere the provider is a financial institution subject to requirements regarding internal governance, arrangements or processes under Union financial services law, it maintains the technical documentation of point (a) as part of the documentation it already keeps under that law. That is not an exemption from the retention duty but an indication of the regime in which it is carried out for that one component. Paragraph 3 does not mention points (b) to (e).

    Consequence

What has to be recorded

1 of 1 shown

This is what has to be in the file to show that the action was carried out.

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 18(1)-(3)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allApplies to the provider of a high-risk AI system. The period ends ten years after the system has been placed on the market or put into service.
    • Condition | allWhere the provider is a financial institution subject to requirements regarding internal governance, arrangements or processes under Union financial services law, it maintains the technical documentation of point (a) as part of the documentation it already keeps under that law. That is not an exemption from the retention duty but an indication of the regime in which it is carried out for that one component. Paragraph 3 does not mention points (b) to (e).

    Consequence

What keeps it in place

1 of 1 shown

This is what keeps compliance in place over time, periodic or event-driven.

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 18(1)-(3)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allApplies to the provider of a high-risk AI system. The period ends ten years after the system has been placed on the market or put into service.
    • Condition | allWhere the provider is a financial institution subject to requirements regarding internal governance, arrangements or processes under Union financial services law, it maintains the technical documentation of point (a) as part of the documentation it already keeps under that law. That is not an exemption from the retention duty but an indication of the regime in which it is carried out for that one component. Paragraph 3 does not mention points (b) to (e).

    Consequence

Public tools

1 of 1 shown

This is the public route a reader can actually use.

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 18(1)-(3)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allApplies to the provider of a high-risk AI system. The period ends ten years after the system has been placed on the market or put into service.
    • Condition | allWhere the provider is a financial institution subject to requirements regarding internal governance, arrangements or processes under Union financial services law, it maintains the technical documentation of point (a) as part of the documentation it already keeps under that law. That is not an exemption from the retention duty but an indication of the regime in which it is carried out for that one component. Paragraph 3 does not mention points (b) to (e).

    Consequence

What points at this object

Objects hanging off this obligation

4 of 4 shown

The object belongs to this obligation. The source line it hangs off sits there.

  1. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 18(1)-(3)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allTo be set up before the system is placed on the market or put into service, and to be revisited on every change that leads to new technical documentation or a new declaration of conformity.

    Relation recorded on: Set up the ten year retention of the system documentation

    Consequence

  2. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 18(1)-(3)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Periodic check on completeness and retrievability of the retention file

    Consequence

  3. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 18(1)-(3)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Retention file per high-risk system

    Consequence

  4. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 18(1)-(3)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Full text of Article 18

    Consequence

What this object states

Official fact

Attributable to a named primary source, with a locator. Where they differ, the official source prevails.

  • Paragraph 1 provides that the provider shall, for a period ending 10 years after the high-risk AI system has been placed on the market or put into service, keep at the disposal of the national competent authorities: (a) the technical documentation referred to in Article 11; (b) the documentation concerning the quality management system referred to in Article 17; (c) the documentation concerning the changes approved by notified bodies, where applicable; (d) the decisions and other documents issued by the notified bodies, where applicable; (e) the EU declaration of conformity referred to in Article 47. Paragraph 2 provides that each Member State shall determine conditions under which that documentation remains at the disposal of the national competent authorities for the period indicated for the cases when a provider or its authorised representative established on its territory goes bankrupt or ceases its activity prior to the end of that period. Paragraph 3 provides that providers that are financial institutions subject to requirements regarding their internal governance, arrangements or processes under Union financial services law shall maintain the technical documentation as part of the documentation kept under the relevant Union financial services law.

  • The amended application dates for Chapter III, Sections 1, 2 and 3, with the exception of Article 6(5), are 2 December 2027 for the standalone Annex III route and 2 August 2028 for high-risk AI in products covered by the Annex I harmonisation legislation.

    • Locator: Amended Article 113 application datespraxikon:eu:ai-act:source:reg-eu-2026-1744Open official source

Our interpretation

Our own reading. It can change without the law changing, and it is not the position of a supervisory authority.

  • Four things here are our reading and not the text. First the application date: Regulation (EU) 2026/1744 does not name Article 18 separately, so the fact that this duty moves with 2 December 2027 and 2 August 2028 follows from its placement in Chapter III, Section 3, and not from an explicit provision. Second the starting moment. Paragraph 1 names the placing on the market and the putting into service side by side without choosing, and for a system where both moments occur that is years of difference at the end of the period. Counting from the later moment is the only count that falls short under neither reading, and that is what we would advise a provider. The other reading is defensible: in Union product law the placing on the market is usually the moment that counts, and then the period ends earlier. Third a substantially modified version: the text is silent, and it is equally defensible that every version gets its own period as that the original one continues. Fourth the reach of paragraph 3: it names only the technical documentation, so we keep points (b) to (e) under the general regime until the contrary is settled. Paragraph 2, finally, is addressed to the Member State and not to you. The Netherlands has not yet determined those conditions, so what happens to your file on insolvency or cessation of activity currently follows from contract and not from law.

  • Watch the boundaries of this duty, because they get crossed in both directions. The automatically generated logs are not among the five components: they fall under Article 19, with its own and much shorter period of at least six months, appropriate to the intended purpose, and with a clause for financial institutions that parallels paragraph 3. So do not stretch the ten years to your logs, and conversely do not settle for six months for your documentation. For a provider established in a third country the actual availability moreover sits with two parties at once: Article 22(3)(b) requires the authorised representative to keep, for ten years, the contact details of the provider, a copy of the EU declaration of conformity, the technical documentation and, if applicable, the certificate issued by the notified body at the disposal of the competent authorities and of the bodies referred to in Article 74(10). Two files that drift apart are worse than one. Point (e) overlaps with Article 47(1), which gives the declaration of conformity its own ten year period, and under Article 23(5) the importer carries ten years again for the certificate, the instructions for use and the declaration of conformity. That overlap is no reason to drop one of the periods: they are independent duties of different parties. It is a reason to choose a place of retention where they coincide. On the GDPR, finally: a retention duty under Union law is itself a ground under Article 6(1)(c) GDPR, and the storage limitation of Article 5(1)(e) permits retention that the law requires. The question is therefore not whether it is allowed but how far it reaches. Ten years applies to what Article 18(1) names, and not to everything created along the way: separate test sets, log samples and raw data dumps from the documentation you must be able to produce.

  • This is the duty that asks nothing at the moment you take it on and everything at the moment you have forgotten it. Ten years is longer than the average life of a supplier contract, a document management system and a product team. In the organisations where we encounter this, the five components rarely sit in one archive: the quality system sits with compliance, the notified body decisions with certification, the declaration of conformity with legal. That is not law, but it is common enough that it is worth checking before you assume your situation is different. Whoever first assembles the documents when an authority asks discovers that retention in fact depended on a person and not on a process. Note also the side that is not about you: paragraph 2 concerns the situation where the provider or its representative goes bankrupt, and that is exactly the risk you run as a customer of a small supplier. It is a contracting question before it becomes a compliance question.

Recommended step

A practical step we consider appropriate. Not an obligation following from the Regulation.

  • Designate per high-risk system one place of retention where the five components of paragraph 1 come together. Record side by side when the system was placed on the market and when it was put into service, and calculate the end date from the later of those two moments, so that you do not fall short under either reading. Set that end date as a commitment in a system that survives a change of staff, and keep the Article 19 logs separately with their own period. If you work with an authorised representative, record who holds which copy, because Article 22(3)(b) places the same availability on them as well. When procuring a high-risk system, put in the contract what happens to the documentation if the supplier stops or goes bankrupt, because paragraph 2 leaves that arrangement to national law that does not yet exist in the Netherlands.

When this applies

  1. 1Applies to the provider of a high-risk AI system. The period ends ten years after the system has been placed on the market or put into service.
  2. 2Where the provider is a financial institution subject to requirements regarding internal governance, arrangements or processes under Union financial services law, it maintains the technical documentation of point (a) as part of the documentation it already keeps under that law. That is not an exemption from the retention duty but an indication of the regime in which it is carried out for that one component. Paragraph 3 does not mention points (b) to (e).

When this does not apply

No exception recorded on this object.

Referring to this object

Citation block

Copy this reference into your advice, article or file. The identifier, the version and the hash keep the statement findable later, even once the dataset has moved on.

Reference

Praxikon, "Article 18: documentation keeping",
praxikon:eu:ai-act:obligation:article-18-document-retention@1.0.0,
dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.2.0 (schema 1.5.0),
effective_at 2026-07-27T00:00:00.000Z, known_at 2026-08-14T00:00:00.000Z,
sha256 0971f35c7a7daaf1306f4fbd7ae98680b8b1e2da44b5a84a5abf7d7610cbdbfb,
https://www.praxikon.com/en/verkenner/obligation/article-18-document-retention
(https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Aarticle-18-document-retention&effective_at=2026-07-27&known_at=2026-08-14&lang=en, accessed 2026-09-21)

Short form

praxikon:eu:ai-act:obligation:article-18-document-retention@1.0.0 (sha256 0971f35c)

BibTeX

@misc{praxikon-eu-ai-act-obligation-article-18-document-retention-1-0-0,
  author       = {{Praxikon}},
  title        = {Article 18: documentation keeping},
  year         = {2026},
  version      = {1.0.0},
  number       = {praxikon:eu:ai-act:obligation:article-18-document-retention},
  howpublished = {AI Act Change \& Evidence Graph, dataset 2.2.0, schema 1.5.0},
  note         = {effective_at 2026-07-27T00:00:00.000Z; known_at 2026-08-14T00:00:00.000Z; sha256 0971f35c7a7daaf1306f4fbd7ae98680b8b1e2da44b5a84a5abf7d7610cbdbfb},
  url          = {https://www.praxikon.com/en/verkenner/obligation/article-18-document-retention},
  urldate      = {2026-09-21},
  language     = {en}
}

CSL JSON

[
  {
    "id": "praxikon:eu:ai-act:obligation:article-18-document-retention@1.0.0",
    "type": "dataset",
    "title": "Article 18: documentation keeping",
    "container-title": "AI Act Change & Evidence Graph",
    "publisher": "Praxikon",
    "version": "1.0.0",
    "number": "praxikon:eu:ai-act:obligation:article-18-document-retention",
    "URL": "https://www.praxikon.com/en/verkenner/obligation/article-18-document-retention",
    "language": "en",
    "issued": {
      "date-parts": [
        [
          2026,
          8,
          14
        ]
      ]
    },
    "accessed": {
      "date-parts": [
        [
          2026,
          9,
          21
        ]
      ]
    },
    "note": "dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.2.0; schema 1.5.0; effective_at 2026-07-27T00:00:00.000Z; known_at 2026-08-14T00:00:00.000Z; sha256 0971f35c7a7daaf1306f4fbd7ae98680b8b1e2da44b5a84a5abf7d7610cbdbfb; retrieved_from https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Aarticle-18-document-retention&effective_at=2026-07-27&known_at=2026-08-14&lang=en; licence https://www.praxikon.com/nl/legal/terms"
  }
]

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