Annex III, Section 3(d) of the AI Act covers AI systems intended to monitor and detect prohibited behaviour of students during tests. That is your proctoring system. Article 11 requires the provider to draw up technical documentation in accordance with Annex IV before placing the system on the EU market. The documentation covers architecture, training data, performance metrics, risk management and human oversight — nine sections, each mandatory. AICheck generates the 12 PDF documents in 45 minutes. €249. 100% browser-side — no student data leaves your machine.
€249 one-time payment per system · 12 PDF documents in ZIP · 45 minutes · 100% in your browser
Annex III, Section 3(d) classifies AI systems that monitor and detect prohibited behaviour of students during tests as high-risk. Article 11 requires the provider to produce Annex IV technical documentation — nine mandatory sections.
The deadline is 2 August 2026. Full obligations for Annex III high-risk systems enter into force on that date under Article 113 of the Regulation.
Five steps from classification to documented compliance for your proctoring system.
Annex III, Section 3(d) covers AI systems that monitor and detect prohibited behaviour. It does not require the system to make a final decision. If your AI flags potential cheating for human review, it is still monitoring behaviour during tests. The classification applies regardless of whether a human makes the final call.
Article 2 of Regulation (EU) 2024/1689 applies to providers who place AI systems on the Union market, regardless of where the provider is established. If any EU university uses your proctoring software, you are placing it on the EU market. The documentation obligation under Art. 11 is yours as the provider.
If your system uses machine learning, computer vision, or pattern recognition to detect behaviour (eye-tracking, face detection, keystroke analysis, browser lockdown with anomaly detection), it is an AI system under Art. 3(1). Video recording without AI processing is not covered. The moment AI analyses the feed, Art. 11 applies.
Each AICheck licence generates a ZIP with 12 PDF documents for one AI system. For 10 systems you need 10 licences and obtain 120 documents in total.
Art. 6 + Anexo III.
Art. 11 + Anexo IV.
Art. 47 + Anexo V.
Art. 111.
Executive summary.
Art. 17.
Art. 13.
Per Annex IV point.
Art. 73.
Art. 4.
Chapter III.
Art. 9.
Generated in your browser. No data leaves your device.
Generates the 12-document Annex IV dossier for your proctoring system. 45 minutes. €249. Provider obligation under Art. 11.
Before documenting, confirm your proctoring system falls under Annex III, Section 3(d) and that your risk management system (Art. 9) is in place. That is your internal work. AICheck documents the system once classified.
We document. You classify and manage risk.
Article 99 of Regulation (EU) 2024/1689.
Art. 99.3. Up to €35 million or 7% of worldwide annual turnover, whichever is higher. For SMEs: the lower of the two.
Art. 99.4. Includes failure to produce technical documentation per Art. 11 and Annex IV.
Art. 99.5.
| Alternative | Cost | What you get |
|---|---|---|
| Big Four consultancy | €8,000–€25,000 | Full audit + documentation. 3–6 months. |
| Document internally with Annex IV text | Free + team time | Weeks per system. Risk of gaps. |
| Ignore the obligation | €0 now | Up to €15M fine or 3% global turnover per system |
| AICheck × 10 systems | €249 | 120 documents, 1 week, no consultancy |
Each AICheck licence documents one AI system. If each institution runs a separate deployment with different configurations, each deployment needs its own dossier. Write to us for a Volume Pack with discounted pricing.
Request Volume PricingAICheck generates a document structured under Article 11 and Annex IV of Regulation (EU) 2024/1689 based on the information you enter. The truthfulness, accuracy and completeness of that information is your responsibility as provider of the AI system.
We guarantee that the document structure follows Article 11 and Annex IV of Regulation (EU) 2024/1689 and that the legal references cited are correct as of the latest verification date. We do not guarantee that a specific document will be accepted by a market surveillance authority in a specific case, nor by a commercial buyer in a procurement process.
AICheck is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.
Regulation (EU) 2024/1689 does not wait. Each high-risk system needs 12 documents under Annex IV. AICheck generates them in 45 minutes per system, 100% in your browser, with no data leaving your device.