Reg (EU) 2024/1689Generate dossier — €249

You deploy AI-powered HR software. Under Article 26 of Regulation (EU) 2024/1689, you have deployer obligations: human oversight, worker information, log retention. Baker McKenzie published the guide. VerifyWise sells a policy pack. Your provider has not sent you the Annex IV documentation yet. Now what?

Baker McKenzie's PDF explains deployer obligations for HR. Taylor Wessing covers the AI Act from an HR perspective. VerifyWise sells deployer policy templates. But none of them solve the core problem: your HR AI provider has not given you the technical documentation or the deployer instructions required under Article 13. You have two options. Option A: pressure your provider. Option B: generate the Annex IV documentation yourself with AICheck and present it to your provider — or file it yourself if you become the de facto provider under Article 25. Twelve documents. 45 minutes. €249.

Generate Annex IV dossier — €249Free: check if your system is high-risk

€249 one-time payment per system · 12 PDF documents in ZIP · 45 minutes · 100% in your browser

Regulation (EU) 2024/1689 · Article 11 + Annex IV · 12 documents · 100% browser-side

Deployer obligations for HR AI: the documentation gap

Your provider should have given you Annex IV documentation and Art. 13 instructions. Most HR AI vendors have not produced them yet. That leaves you as deployer without the documentation you need to fulfil your own Art. 26 obligations.

Article 25 creates a secondary path: if you put your name on the system or substantially modify it, you become the provider. Either way, the documentation must exist.

Art. 26
Deployer obligations: human oversight, worker information, logs, FRIA
Art. 13
Provider must deliver instructions for use to the deployer. Has yours?
2 ago 2026
Annex III high-risk deadline

How to document all your AI systems in one week

You don't need to document 10 systems at once. This is the recommended workflow for companies with multiple high-risk AI systems.

1
Inventory
List every AI system in production. Use AICheck's free checker to verify which ones fall under Annex III.
2
Group by Annex III category
Cluster by category: 5(a) credit scoring, 4(a) recruitment, 4(b) performance evaluation, etc. Each category has specific documentation nuances.
3
Pilot dossier
Generate the dossier for your simplest system. 45 minutes. Review with your legal team. Refine the process.
4
Batch production
With the process validated, generate the remaining dossiers. €249 × N systems. Each takes 45 minutes.
5
Cross-review
Your DPO or compliance officer reviews the 12 documents in each dossier. AICheck allows 10 regenerations per licence for corrections.
6
Archive and traceability
Store the downloaded ZIPs. Record generation date, system documented, responsible person. You will need this before your national supervisory authority.

Deployer mistakes with HR AI

ERROR COMÚN

"Our provider says they are 'compliant' — we do not need to do anything"

Deployer obligations under Art. 26 exist independently of provider compliance. Even if your provider has perfect documentation, you still need: effective human oversight, worker information (Art. 26.7), log retention, and in some cases a fundamental rights impact assessment (Art. 27). 'Compliant provider' does not equal 'compliant deployer.'

ERROR COMÚN

"VerifyWise's deployer policy pack covers our obligations"

Policy templates are a starting point. Article 26 requires operational implementation: who oversees the system, how workers are informed, how logs are maintained, how incidents are reported. Templates describe what to do. AICheck generates the documentation your provider should have given you.

ERROR COMÚN

"We will switch providers if ours is not compliant"

Switching takes months. The deadline is 2 August 2026. Before switching, ask your current provider for the documentation. If they cannot produce it, generate it yourself with AICheck as a bridge solution. Document your due diligence effort regardless.

What each ZIP contains: 12 documents

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.

1

Risk Classification

Art. 6 + Anexo III.

2

Annex IV Technical Documentation

Art. 11 + Anexo IV.

3

EU Declaration of Conformity

Art. 47 + Anexo V.

4

Compliance Calendar

Art. 111.

5

Conformity Sheet

Executive summary.

6

Quality Management System (QMS)

Art. 17.

7

Deployer Instructions

Art. 13.

8

Evidence Checklist

Per Annex IV point.

9

Incident Template

Art. 73.

10

AI Literacy Programme

Art. 4.

11

Provider–Deployer Clauses

Chapter III.

12

Risk Committee Minutes

Art. 9.

Generated in your browser. No data leaves your device.

What you pay to document 10 systems

🧾 DEPLOYER COMPLIANCE ADVISORY FOR HR AI
€10,000–€25,000
3–6 months. Baker McKenzie rates.
✓ AICHECK
€249
12 documents. 45 min. Generate what your provider hasn't.

Structured documentation vs. third-party audit

● CAPA 1

What AICheck does

Generates the technical documentation for each system under Art. 11 and Annex IV of Regulation (EU) 2024/1689. Structures the 9 points of Annex IV individually per system. 12 PDF documents per system.

∅ CAPA 2

What AICheck does NOT do

Does not audit your systems. Does not evaluate whether your training data is adequate. Does not validate that your model performs correctly. That is your responsibility and, if needed, that of a notified body under Art. 43.

AICheck solves Layer 1 so your team can focus on Layer 2. At €249 per system, documentation stops being the bottleneck.

Enforcement regime

Article 99 of Regulation (EU) 2024/1689.

🇪🇺
Non-compliance with prohibited practices
€35M / 7%

Art. 99.3. Up to €35 million or 7% of worldwide annual turnover, whichever is higher. For SMEs: the lower of the two.

🇪🇺
Non-compliance with high-risk obligations
€15M / 3%

Art. 99.4. Includes failure to produce technical documentation per Art. 11 and Annex IV.

🇪🇺
Supply of false or incomplete information
€7.5M / 1%

Art. 99.5.

Alternatives

AlternativeCostWhat you get
Big Four consultancy€10,000–€25,000Full audit + documentation. 3–6 months.
VerifyWise deployer policy packFreeTemplates. No documentation generation.
Wait for provider to comply€0No documentation. No control.
AICheck × 10 systems€249120 documents, 1 week, no consultancy

Deploying HR AI from multiple providers across your organisation?

If your company has an extensive AI system portfolio, we offer Volume Packs with discounts from 10 licences. Write to hello@solidwaretools.com and we'll send you a proposal within one business day.

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What AICheck guarantees and what it does not

AICheck 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.

Frequently asked questions — Deployer obligations for HR AI

What is a fundamental rights impact assessment (FRIA) under Art. 27?
Article 27 requires deployers of high-risk AI systems in the employment domain to conduct a fundamental rights impact assessment before deploying the system. This assesses the impact on workers' rights: non-discrimination, privacy, freedom of association. The FRIA is a deployer obligation separate from the provider's Annex IV documentation.
If I generate documentation with AICheck because my provider hasn't, does that make me the provider?
Not necessarily. Generating documentation as a due diligence measure does not make you the provider. Article 25 defines provider status change: if you place the system on the market under your own name, make substantial modifications, or change the intended purpose. Generating documentation for your own deployment context is deployer diligence, not provider assumption.
Can I use the AICheck deployer instructions (Art. 13) to train our HR team?
Yes. The Art. 13 deployer instructions generated by AICheck describe the system's intended purpose, capabilities, limitations, human oversight requirements, and risks. They are designed to inform the deployer. Use them as a training resource for your HR team and as documentation for Art. 26.7 worker information obligations.
Does Art. 26.7 require us to inform candidates in recruitment, or only employees?
Article 26.7 requires informing workers and their representatives. For recruitment, Article 50.1 creates a separate transparency obligation: natural persons must be informed they are interacting with an AI system. Candidates are not workers yet, but they are natural persons subject to the system — both Art. 26.7 (if applicable) and Art. 50.1 transparency apply.
Is this a subscription?
No. One-time payment. The licence includes 30 days of editing and 10 regenerations. The downloaded PDF is yours to keep.
Can I request a refund?
Under Article 16.m of Directive (EU) 2011/83 on consumer rights, by activating the licence you give express consent for the immediate generation of the digital content and waive the 14-day withdrawal period. Refunds are accepted only for verifiable reproducible technical failures.
What if the regulation changes?
If the regulation changes during the validity of your licence, you may regenerate the document with the updated version of the generator at no additional cost.
⚠️ Important notice: AICheck is a self-assessment documentation tool, not legal advice and not a third-party audit. The document under Article 11 and Annex IV of Regulation (EU) 2024/1689 is generated from your input data. You are responsible for the accuracy of the data you provide. AICheck does not replace a qualified professional assessment.

Your HR AI provider has not delivered the documentation. Generate it yourself. Twelve documents. 45 minutes. €249.

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.

€249 one-time
12 professional documents · 45 minutes · No subscription · 100% in your browser
Generate Annex IV dossier — €249
✓ Last regulatory check: 28 April 2026 · No substantive changes detected · View history