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AI AGENTS6 minAgents in Production / Ep. 9 · Stage 9-4

AI Act Technical File: How Long to Keep It and Key Dates

An auditor asks, in year nine, for the documentation behind one number. Can you hand over the right version?

XIN

IN 30 SECONDS

The retention period of the EU AI Act technical file is 10 years under Article 18, after the system is placed on the market or put into service. Article 72 has applied since 2 August 2026; Article 11 applies from 2027 or 2028, depending on the system.

KEY TAKEAWAYS · 3

  • Resolve the output to its release tag, then render the file for that tag.
  • Logs: at least six months unless other law says otherwise (Article 19). Technical documentation: 10 years (Article 18).
  • Article 72 has applied since 2 August 2026; Article 11 applies from 2027 or 2028, depending on the system.
On this page

When someone asks for the file, and for how long

IN SHORT When someone asks, you resolve their output to its release tag and render the file for that tag.

WORDS TO KNOW

Technical documentation
The file Article 11 asks a provider to draw up and keep up to date.
High-risk AI system
A system the Act classes as high-risk. Whether yours is one is a legal question.
Release tag
A version-control label, like 1.4.0, that marks one release.

An auditor, a notified body or a client’s risk team asks: show me the docs for the version that made this number.

A request for the technical file is a quick lookup only if the output names its version.

STEP BY STEP

Sequence diagram: 4 participants: Whoever asks, You, The build, The fileSequence diagram: 4 participants: Whoever asks, You, The build, The file. Step 1: Whoever asks to You, Docs for this number?. Step 2: You to The build, Resolve the output to its tag. Step 3: The build to The file, Check out the tag, render. Step 4: The file to Whoever asks, One dated file for that version. Step 5: You to The file, No tag: which version ran?.WHOEVER ASKS > YOUDocs for this number?YOU > THE BUILDResolve the output to its tagTHE BUILD > THE FILECheck out the tag, renderTHE FILE > WHOEVER ASKSOne dated file for thatversionYOU > THE FILENo tag: which version ran?

Step 1. The request. One number, one question: which version made it?

Pick a step to see it move
  1. The request One number, one question: which version made it?
  2. Resolve the tag The audit record links that output to its tag.
  3. Render that version The build checks out the tag and renders the nine points from one commit. Some evidence lives outside the repo, and people still review the file.
  4. Hand it over The asker gets one dated document for that exact version.
  5. No tag Without a release tag, you can hand over a document, but not prove it describes the system behind the number.
Four steps work, one fails. The cut arrow is a file with no version, or a version with no file.

Keep two clocks apart:

  • Logs the system writes by itself: at least six months (Article 19), unless other Union or national law says otherwise.
  • Documents: 10 years after the system is placed on the market or put into service (Article 18).

For those 10 years, Article 18 keeps these open to “national competent authorities”:

  • the Technical documentation The file Article 11 asks a provider to draw up and keep up to date. See the glossary;
  • your quality management system papers;
  • records of changes notified bodies approved, where applicable;
  • notified body decisions and documents, where applicable;
  • the Article 47 EU declaration of conformity.

WATCH OUT

In finance: providers that are financial institutions under EU financial services law keep the technical documentation in the files that law already requires.

ITEM GET

The tag is the thread

The per-action audit record I write for an auditor names the release behind each number, and that release resolves to one dated file.

Which dates apply: Article 72 now, Article 11 later

IN SHORT Article 72 already applies and points at the Annex IV file; Article 11 itself applies later.

Article 11 sits in Chapter III, Section 2. The consolidated Article 113 starts Sections 1 to 3 of Chapter III, except Article 6(5), on one of two dates. The date depends on how the system is classed.

TWO PROVISIONS, TWO CLOCKS
Article 72 (Chapter IX)
Post-market monitoring, including the plan in the Annex IV file
2 August 2026
Article 11 and Annex IV (Chapter III, Section 2)
Systems high-risk under Article 6(2) and Annex III
2 December 2027
Article 11 and Annex IV (Chapter III, Section 2)
Systems high-risk under Article 6(1) and Annex I
2 August 2028
Source: consolidated Article 113 and Article 72(3) on EUR-Lex. Which row applies to your system, if any, is a legal classification.

Article 72 sits in Chapter IX, which was not postponed, so it has applied since 2 August 2026. Its third paragraph says: “The post-market monitoring plan shall be part of the technical documentation referred to in Annex IV.”

The Commission is due to adopt guidance, with a template for that plan, by 2 September 2027.

IN PLAIN WORDS

Article 72’s monitoring duty already runs. Article 11’s file duty starts in 2027 or 2028, depending on the system.

What that overlap means for a given system is a question for a lawyer. I don’t answer it. Which branch covers a High-risk AI system A system the Act classes as high-risk. Whether yours is one is a legal question. See the glossary, if either does, is a legal classification too.

Sources: consolidated AI Act text (EUR-Lex), Regulation (EU) 2026/1744 (Official Journal), AI Act Service Desk on Article 11, Annex IV and Article 18. The Desk still showed old wording when I checked, so I used the amending law; unofficial trackers can lag too.

FAQ

From 2 December 2027 (Article 6(2), Annex III) or 2 August 2028 (Article 6(1), Annex I). Which branch covers a system, if either does, is a question for a qualified lawyer.

For 10 years after the system is placed on the market or put into service (Article 18). Logs are separate. They are kept at least six months, unless other Union or national law says otherwise (Article 19).

No. It doesn’t tell you if the law applies to you, if your system is high-risk, or how a regulator would read it. Ask a lawyer.

STAGE CLEAR

What you now know

  • The audit record links a number to its release; the tag links the release to its file.
  • Logs and the technical file run on different clocks, and which date applies to a system is a legal classification.

Check yourself

Tap or click a question to see the answer.

A team keeps its agent logs for seven months, then deletes them. Has it covered Article 18 for the technical file?

No. Six months is Article 19’s floor for logs, unless other law says otherwise. The 10 years of Article 18 apply to the technical documentation and the other listed documents.

Next episode:How do you decide the score a new version of an AI agent must reach before it ships?6 min
Adam Boudjemaa
Adam Boudjemaa

Former CTO of Integra. Named author (1 of 5) of ERC-3643, first author of ERC-6960, co-author of ERC-7410, and co-author of ERC-8203, which is still a draft. Building production AI and regulated Web3 systems.

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