Documenting High-Risk AI: A European Regulatory Perspective

Isabelle Hupont · Marina Micheli · Blagoj Delipetrev · Emília Gómez · Josep Soler Garrido

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Digitalization, Law, and Regulation Ethics and Social Impacts of AI Explainable Artificial Intelligence (XAI)

Abstract

The increasing adoption of Artificial Intelligence (AI) systems in high-stakes applications brings new opportunities for innovation, economic growth and the digital transformation of society. However, this often comes with associated risks to the safety, health or fundamental rights of people, highlighting an urgent need for the systematic adoption of trustworthy AI practices. Transparency is key for building trust in AI systems, as it facilitates their understanding and scrutiny. This article discusses transparency obligations introduced in the AI Act, the recently proposed European regulatory framework for Artificial Intelligence. Specifically, we look at requirements for providers of high-risk AI systems in terms of provision of information to users and technical documentation. An analysis of the extent to which current approaches for AI documentation satisfy these requirements is presented, assessing their suitability as a basis for future technical standards and making recommendations for their potential development in this direction.

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References

2019Model Cards for Model Reporting 1976The Delphi method: Techniques and applications 2018AI Fairness 360: An Extensible Toolkit for Detecting, Understanding, and Mitigating Unwanted Algorithmic Bias 2020Co-Designing Checklists to Understand Organizational Challenges and Opportunities around Fairness in AI 2019FactSheets: Increasing trust in AI services through supplier's declarations of conformity 2021Towards Accountability for Machine Learning Datasets: Practices from Software Engineering and Infrastructure 2018The Dataset Nutrition Label: A Framework To Drive Higher Data Quality Standards

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2023How artificial intelligence adopts human biases: the case of cosmetic skincare industry 2024Use case cards: a use case reporting framework inspired by the European AI Act 2023The landscape of data and AI documentation approaches in the European policy context 2024AI Cards: Towards an Applied Framework for Machine-Readable AI and Risk Documentation Inspired by the EU AI Act 2023Advancing accountability in AI 2025Building Symbiotic Artificial Intelligence: Reviewing the AI Act for a Human-Centred, Principle-Based Framework

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