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Article 17; Article 63(1)-(2)

UpcomingConditional timing

Maintain a Quality Management System for High-Risk AI

Applies to Provider; High-Risk AI.

Actors
Provider
AI class
High-Risk AI
Themes
Risk & Assurance

Tracker Guidance

Establish a documented quality management system for high-risk AI that covers the Article 17 elements through written policies, procedures and instructions. Implement it proportionately to the size of the provider, including where the provider is an SME, start-up or small mid-cap, while maintaining the required level of rigour and protection. Where relevant, integrate these elements into an existing sectoral quality-management system. Financial institutions may satisfy much of this obligation through applicable Union financial-services governance requirements, but the Article 17(1)(g), (h) and (i) elements remain separately applicable. For Article 6(1)/Annex I systems, also check Article 2(13), which may limit specific Article 17 obligations where equivalent or higher requirements apply under relevant Union harmonisation legislation and overall protection is not reduced. Qualifying SMEs, including start-ups, may comply with certain QMS elements in a simplified manner under Article 63(1), provided they do not have partner or linked enterprises within the meaning of Recommendation 2003/361/EC. This does not exempt them from the other AI Act requirements identified in Article 63(2).

Official text

Article 17Official source
1. Providers of high-risk AI systems shall put a quality management system in place that ensures compliance with this Regulation. That system shall be documented in a systematic and orderly manner in the form of written policies, procedures and instructions, and shall include at least the following aspects: (a) a strategy for regulatory compliance, including compliance with conformity assessment procedures and procedures for the management of modifications to the high-risk AI system; (b) techniques, procedures and systematic actions to be used for the design, design control and design verification of the high-risk AI system; (c) techniques, procedures and systematic actions to be used for the development, quality control and quality assurance of the high-risk AI system; (d) examination, test and validation procedures to be carried out before, during and after the development of the high-risk AI system, and the frequency with which they have to be carried out; (e) technical specifications, including standards, to be applied and, where the relevant harmonised standards are not applied in full or do not cover all of the relevant requirements set out in Section 2, the means to be used to ensure that the high-risk AI system complies with those requirements; (f) systems and procedures for data management, including data acquisition, data collection, data analysis, data labelling, data storage, data filtration, data mining, data aggregation, data retention and any other operation regarding the data that is performed before and for the purpose of the placing on the market or the putting into service of high-risk AI systems; (g) the risk management system referred to in Article 9; [Excerpt - see official source for complete provision]

Excerpt stored at a complete legal-unit boundary. See the official source for the full provision.

Article 63(1)-(2)Official source
1. SMEs, including start-ups, may comply with certain elements of the quality management system required by Article 17 in a simplified manner, provided that they do not have partner enterprises or linked enterprises within the meaning of Recommendation 2003/361/EC. For that purpose, the Commission shall develop guidelines on the elements of the quality management system which may be complied with in a simplified manner considering the needs of SMEs, without affecting the level of protection or the need for compliance with the requirements in respect of high-risk AI systems. 2. Paragraph 1 of this Article shall not be interpreted as exempting those operators from fulfilling any other requirements or obligations laid down in this Regulation, including those established in Articles 9, 10, 11, 12, 13, 14, 15, 72 and 73.

Timing depends on the system

  • 2 Dec 2027Article 6(2) / Annex III high-risk AI
  • 2 Aug 2028Article 6(1) / Annex I Section A high-risk AI
  • 2 Dec 2027Pre-existing Annex III high-risk AI type/model first placed on the market or put into service before 2027-12-02
  • 2 Aug 2028Pre-existing Article 6(1) / Annex I high-risk AI type/model first placed on the market or put into service before 2028-08-02
  • 2 Aug 2030Pre-existing high-risk AI intended to be used by public authorities

Sub-obligations

These are independently assessable parts of the parent requirement.

  1. Article 17(1)(a)

    Upcoming

    Maintain a Regulatory Compliance and High-Risk AI Modification Management Strategy

    Tracker Guidance

    Maintain a regulatory-compliance strategy for the high-risk AI system, including the applicable conformity-assessment approach and a process for managing modifications to the system.

    Official text

    Article 17(1)(a)Official source
    (a) a strategy for regulatory compliance, including compliance with conformity assessment procedures and procedures for the management of modifications to the high-risk AI system;
  2. Article 17(1)(b)-(d)

    Upcoming

    Control High-Risk AI Design, Development, Quality Assurance, Testing and Validation

    Tracker Guidance

    Define and operate systematic procedures for design, design control, design verification, development, quality control, quality assurance, examination, testing and validation. Specify when and how often required tests and validations are performed.

    Official text

    Article 17(1)(b)-(d)Official source
    (b) techniques, procedures and systematic actions to be used for the design, design control and design verification of the high-risk AI system; (c) techniques, procedures and systematic actions to be used for the development, quality control and quality assurance of the high-risk AI system; (d) examination, test and validation procedures to be carried out before, during and after the development of the high-risk AI system, and the frequency with which they have to be carried out;
  3. Article 17(1)(e)

    Upcoming

    Define Applicable Technical Specifications, Standards and Alternative Compliance Measures

    Tracker Guidance

    Identify the technical specifications and standards used to demonstrate compliance. If relevant harmonised standards are not fully applied or do not cover all applicable requirements, document the means used to ensure the high-risk AI system still meets those requirements.

    Official text

    Article 17(1)(e)Official source
    (e) technical specifications, including standards, to be applied and, where the relevant harmonised standards are not applied in full or do not cover all of the relevant requirements set out in Section 2, the means to be used to ensure that the high-risk AI system complies with those requirements;
  4. Article 17(1)(f)

    Upcoming

    Maintain High-Risk AI Data Management Procedures

    Tracker Guidance

    Maintain procedures governing the data operations relevant to the high-risk AI system, including acquisition, collection, analysis, labelling, storage, filtration, mining, aggregation, retention and other applicable data-management activities.

    Official text

    Article 17(1)(f)Official source
    (f) systems and procedures for data management, including data acquisition, data collection, data analysis, data labelling, data storage, data filtration, data mining, data aggregation, data retention and any other operation regarding the data that is performed before and for the purpose of the placing on the market or the putting into service of high-risk AI systems;
  5. Article 17(1)(g)-(i)

    Upcoming

    Integrate Risk Management, Post-Market Monitoring and Serious Incident Reporting Into the QMS

    Tracker Guidance

    Ensure the quality management system incorporates the Article 9 risk-management process, Article 72 post-market monitoring and Article 73 serious-incident reporting processes.

    Official text

    Article 17(1)(g)-(i)Official source
    (g) the risk management system referred to in Article 9; (h) the setting-up, implementation and maintenance of a post-market monitoring system, in accordance with Article 72; (i) procedures related to the reporting of a serious incident in accordance with Article 73;
  6. Article 17(1)(j)-(k)

    Upcoming

    Maintain QMS Procedures for Regulatory Communications and Record-Keeping

    Tracker Guidance

    Maintain procedures for communications with competent authorities, notified bodies, other operators, customers and other relevant parties, together with systematic record-keeping for compliance documentation and information.

    Official text

    Article 17(1)(j)-(k)Official source
    (j) the handling of communication with national competent authorities, other relevant authorities, including those providing or supporting the access to data, notified bodies, other operators, customers or other interested parties; (k) systems and procedures for record-keeping of all relevant documentation and information;
  7. Article 17(1)(l)-(m)

    Upcoming

    Maintain Adequate Resources and Management Accountability for High-Risk AI Compliance

    Tracker Guidance

    Define how the provider manages resources needed for high-risk AI compliance, including security-of-supply considerations where relevant, and establish clear accountability for management and staff responsibilities within the quality management system.

    Official text

    Article 17(1)(l)-(m)Official source
    (l) resource management, including security-of-supply related measures; (m) an accountability framework setting out the responsibilities of the management and other staff with regard to all the aspects listed in this paragraph.

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Article 17; Article 63(1)-(2): Maintain a Quality Management System for High-Risk AI | EU AI Act Library