AIGO — EU AI Act Evidence and Assurance Mapping
1. Document Purpose
This document establishes the AIGO evidence and assurance mapping for Regulation (EU) 2024/1689, the European Union Artificial Intelligence Act, as amended by Regulation (EU) 2026/1744. It provides the evidence and assurance layer connecting:2. Mapping Information
Regulation (EU) 2026/1744 is the current amendment baseline for this mapping. It was published on 24 July 2026 and entered into force on 27 July 2026.
3. Evidence Governance Principle
Evidence should demonstrate the operation and outcome of governance activities. AIGO should distinguish:4. Evidence Relationship Types
AIGO should classify evidence relationships using:PRIMARY
Evidence directly demonstrating satisfaction or implementation of the mapped control.SUPPORTING
Evidence supporting a decision or conclusion.DERIVED
Evidence generated from another authoritative record.CROSS_REFERENCE
Evidence held elsewhere and referenced rather than duplicated.REGULATORY
Evidence supplied to or received from a competent authority.TECHNICAL
Evidence concerning system, model, data, testing, or infrastructure.OPERATIONAL
Evidence generated during normal system operation.ASSURANCE
Evidence generated by independent or objective assessment.HISTORICAL
Evidence retained for previous versions, decisions, or regulatory states.5. Evidence Status
Evidence records should support:6. Evidence Quality Model
AIGO evidence should be evaluated against:7. Evidence Integrity
Evidence supporting material EU AI Act governance decisions should be protected against unauthorized alteration. Potential controls include:- version control;
- timestamps;
- access control;
- immutable or controlled repositories;
- checksums where appropriate;
- audit logs;
- controlled deletion;
- chain of custody.
8. Evidence Attribution
Every material evidence record should identify:- evidence ID;
- source;
- owner;
- creation date;
- relevant system;
- version;
- related control;
- related requirement;
- review status.
9. Evidence Currency
Evidence should be considered current only when its validity period or review state supports the applicable decision. Examples:10. Evidence and Versioning
AIGO should preserve version relationships:11. Evidence Traceability Principle
Every material EU AI Act requirement should be traceable through:NO_DIRECT_AIGO_EQUIVALENT
rather than creating a false control relationship.
12. Master Evidence Chain
The AIGO evidence architecture is:13. Evidence Categories
Evidence should be organized into controlled categories:14. Applicability Evidence
Control Relationship
EUAI-CTRL-APP-001
Purpose
Demonstrate how the organization determined whether the AI Act applies.Evidence
Potential evidence:- AI System Profile;
- actor determination;
- intended-purpose record;
- territorial analysis;
- AI-system definition analysis;
- regulatory classification;
- exception analysis;
- transition analysis;
- legal review.
Assurance
Assurance should verify:- source currency;
- factual basis;
- logical reasoning;
- reviewer;
- date;
- change triggers.
15. Classification Evidence
Control Relationship
EUAI-CTRL-CLS-001
Evidence
Potential evidence:- Article 5 screening;
- Article 6 assessment;
- Annex I analysis;
- Annex III analysis;
- GPAI classification;
- systemic-risk assessment;
- technology classification;
- intended purpose;
- technical capabilities.
Assurance
The reviewer should verify that classification is supported by the current legal baseline and actual system characteristics.16. Prohibited-Practice Evidence
Control Relationship
EUAI-CTRL-PROH-001
Evidence should demonstrate:
- use-case description;
- intended purpose;
- system capabilities;
- relevant Article 5 categories screened;
- conditions considered;
- exceptions considered;
- decision;
- reviewer;
- date.
- technical testing;
- UX design;
- model evaluation;
- safety testing;
- legal assessment.
17. Article 5 Evidence Standard
A prohibited-practice screening should not be treated as complete merely because a questionnaire was completed. For material use cases, evidence should allow an independent reviewer to understand:18. Risk Evidence
Control Relationship
EUAI-CTRL-RISK-001
Evidence may include:
- risk assessment;
- risk register;
- risk analysis;
- risk evaluation;
- treatment;
- residual risk;
- acceptance;
- monitoring;
- reassessment.
19. Risk Evidence Quality
Risk evidence should identify:- risk owner;
- assessment method;
- assumptions;
- evidence used;
- probability;
- impact;
- treatment;
- residual risk;
- approval where applicable.
20. Data Governance Evidence
Control Relationship
EUAI-CTRL-DATA-001
Potential evidence:
- data inventory;
- provenance;
- lineage;
- quality assessment;
- representativeness analysis;
- bias assessment;
- data-preparation records;
- validation/testing datasets;
- approvals;
- data-change records.
21. Technical Documentation Evidence
Control Relationship
EUAI-CTRL-DOC-001
Potential evidence:
- technical documentation;
- architecture;
- model description;
- system description;
- development information;
- data documentation;
- testing;
- validation;
- cybersecurity;
- human oversight;
- limitations;
- change history.
22. Technical Documentation Completeness
AIGO should assess:23. Record-Keeping Evidence
Control Relationship
EUAI-CTRL-REC-001
Evidence may include:
- logs;
- retention records;
- record inventories;
- access logs;
- log configurations;
- integrity information;
- retention actions;
- audit trails.
24. Logging Evidence
AIGO should distinguish:25. Transparency Evidence
Control Relationships
EUAI-CTRL-TRANS-001EUAI-CTRL-TRANS-002EUAI-CTRL-TRANS-003EUAI-CTRL-TRANS-004EUAI-CTRL-TRANS-005EUAI-CTRL-TRANS-006
- user notices;
- interface evidence;
- machine-readable markings;
- content samples;
- label tests;
- disclosure configuration;
- editorial-review records;
- publication records;
- biometric/emotion-recognition notices.
26. Transparency Technical Evidence
For machine-readable AI-content marking, evidence should include:- marking method;
- implementation;
- detection test;
- interoperability;
- persistence test;
- failure analysis;
- configuration;
- version.
27. Human-Oversight Evidence
Control Relationship
EUAI-CTRL-HUM-001
Evidence may include:
- assigned oversight role;
- competence evidence;
- instructions;
- intervention procedures;
- override tests;
- intervention logs;
- escalation records;
- training.
28. Accuracy Evidence
Control Relationship
EUAI-CTRL-PERF-001
Evidence may include:
- test methodology;
- datasets;
- validation results;
- performance metrics;
- acceptance criteria;
- limitations;
- monitoring results;
- version-specific results.
29. Robustness Evidence
Control Relationship
EUAI-CTRL-ROB-001
Evidence may include:
- stress tests;
- failure-mode analysis;
- robustness evaluation;
- adversarial testing;
- resilience tests;
- degradation behavior;
- remediation.
30. Cybersecurity Evidence
Control Relationship
EUAI-CTRL-SEC-001
Potential evidence:
- threat model;
- secure-design evidence;
- vulnerability assessments;
- penetration tests;
- adversarial testing;
- security controls;
- incident results;
- remediation;
- update records.
31. Quality-Management Evidence
Control Relationship
EUAI-CTRL-QMS-001
Evidence may include:
- policies;
- procedures;
- organizational roles;
- design controls;
- testing procedures;
- data governance;
- risk management;
- corrective action;
- management review.
32. Conformity Evidence
Control Relationships
EUAI-CTRL-CONF-001EUAI-CTRL-CONF-002EUAI-CTRL-CONF-003EUAI-CTRL-CONF-004EUAI-CTRL-CONF-005EUAI-CTRL-CONF-006
- conformity applicability decision;
- assessment plan;
- conformity assessment;
- notified-body information;
- assessment reports;
- findings;
- corrective actions;
- certificate;
- declaration;
- CE marking evidence;
- registration.
33. Conformity Evidence Boundary
AIGO assurance evidence must distinguish:34. Notified-Body Evidence
Where required, evidence should establish:- identity;
- notification;
- current scope;
- relevant AI-system category;
- applicable Annex XIV code where relevant;
- assessment engagement;
- assessment output;
- certificate.
35. Declaration of Conformity Evidence
Evidence should include:- declaration;
- AI-system identifier;
- provider;
- applicable legislation;
- authorized signatory;
- date;
- version;
- relationship to conformity assessment.
36. Registration Evidence
Potential evidence:- registration assessment;
- submitted dataset;
- submission;
- registration identifier;
- acknowledgment;
- updates;
- change history.
37. GPAI Evidence Architecture
GPAI evidence should support distinct obligations:38. GPAI Regulatory Submission Evidence
The Commission currently requires applicable GPAI providers to use the EU SEND platform for specified submissions, including systemic-risk notifications, reassessment requests, serious-incident reports, and certain safety/security or Code-of-Practice-related documents. AIGO should retain:- submission;
- submission type;
- model;
- submitter;
- date;
- receipt/acknowledgment;
- response;
- follow-up.
39. GPAI Safety and Security Evidence
For systemic-risk GPAI models, evidence may include:- safety and security framework;
- model report;
- systemic-risk assessment;
- evaluation;
- red-team testing;
- mitigation;
- security testing;
- incident records;
- monitoring.
40. AI Literacy Evidence
Control Relationship
EUAI-CTRL-LIT-001
Evidence may include:
- literacy-needs assessment;
- learning plan;
- training records;
- practical exercises;
- role-specific guidance;
- awareness activities;
- competence evidence where used.
41. Fundamental-Rights Evidence
Control Relationship
EUAI-CTRL-FR-001
Evidence may include:
- Fundamental-Rights Impact Assessment;
- affected-person analysis;
- rights mapping;
- bias assessment;
- mitigation;
- residual-risk assessment;
- monitoring;
- complaints;
- remediation.
42. Rights and DPIA Evidence
Where Article 27 overlaps with a GDPR or law-enforcement data-protection impact assessment, AIGO should cross-reference, rather than duplicate unnecessarily, overlapping evidence. The amended Article 27 expressly supports cross-referencing the relevant sections of applicable data-protection impact assessments. AIGO should identify:- source DPIA;
- relevant sections;
- Article 27 requirement;
- additional rights analysis;
- remaining evidence gaps.
43. Complaint Evidence
Control Relationship
EUAI-CTRL-FR-003
Evidence should establish:
- complaint received;
- affected system;
- issue;
- rights claimed;
- triage;
- investigation;
- decision;
- communication;
- remedy;
- escalation.
44. Regulatory Complaint Evidence
Where a complaint reaches an external authority, evidence should additionally include:- authority;
- complaint reference;
- correspondence;
- submissions;
- findings;
- corrective action;
- closure.
45. Monitoring Evidence
Control Relationships
EUAI-CTRL-MON-001EUAI-CTRL-MON-002
- performance reports;
- risk indicators;
- control metrics;
- incident trends;
- transparency monitoring;
- post-market information;
- system changes;
- user complaints.
46. Incident Evidence
Control Relationships
EUAI-CTRL-INC-001EUAI-CTRL-INC-002EUAI-CTRL-INC-003EUAI-CTRL-INC-004EUAI-CTRL-INC-005
- detection;
- event record;
- severity;
- affected system;
- impact;
- investigation;
- containment;
- notification analysis;
- regulatory report;
- corrective action;
- verification.
47. Change Evidence
Control Relationships
EUAI-CTRL-CHG-001EUAI-CTRL-CHG-002EUAI-CTRL-CHG-003EUAI-CTRL-CHG-004EUAI-CTRL-CHG-005
- change request;
- reason;
- impact assessment;
- classification impact;
- risk impact;
- conformity impact;
- evidence impact;
- approval;
- testing;
- implementation;
- verification.
48. Significant-Change Evidence
For transitional high-risk systems, evidence should demonstrate:49. Regulatory-Authority Evidence
Control Relationships
EUAI-CTRL-AUTH-001EUAI-CTRL-AUTH-002EUAI-CTRL-AUTH-003EUAI-CTRL-AUTH-004EUAI-CTRL-AUTH-005
- authority identification;
- request;
- response;
- submission;
- inspection;
- investigation;
- commitment;
- finding;
- corrective action;
- fine;
- closure.
50. Evidence Preservation During Investigations
When an investigation occurs, AIGO should activate a preservation process. Potential evidence controls:51. Evidence Chain of Custody
Where evidence may be used in a regulatory investigation, the record should capture:- evidence ID;
- source;
- collector;
- collection date;
- method;
- original location;
- hash or integrity control where appropriate;
- transformations;
- transfers;
- recipient;
- submission.
52. Regulatory Commitment Evidence
Where an AI Office or other competent authority establishes a regulatory commitment, evidence should include:- commitment;
- authority;
- legal basis;
- owner;
- milestone;
- completion;
- verification;
- correspondence.
53. Enforcement Evidence
Evidence supporting an enforcement event may include:- authority decision;
- finding;
- legal provision;
- penalty;
- corrective measures;
- response;
- remediation;
- assurance.
54. Assurance Governance Principle
Assurance should answer:Can the organization reasonably demonstrate that its AIGO control framework is designed, implemented, evidenced, monitored, and functioning as intended for the mapped requirement?It should not answer:
Is the organization legally compliant in all respects?The latter may require legal, regulatory, conformity, and factual determinations beyond AIGO assurance.
55. Assurance Types
AIGO should recognize:56. Design Assurance
Design assurance evaluates:- control objective;
- applicability;
- control design;
- ownership;
- evidence requirements;
- monitoring;
- dependencies.
57. Implementation Assurance
Implementation assurance evaluates whether the designed control has actually been deployed. Examples:- configuration;
- workflow;
- documentation;
- system settings;
- assigned roles;
- evidence repository.
58. Operating-Effectiveness Assurance
Operating-effectiveness assurance evaluates whether a control:- operated;
- operated consistently;
- produced expected outputs;
- was performed by the correct owner;
- generated evidence;
- handled exceptions.
59. Technical Assurance
Technical assurance may examine:- model performance;
- testing;
- robustness;
- cybersecurity;
- content marking;
- logs;
- model documentation;
- data.
60. Legal / Compliance Review
Legal/compliance review may evaluate:- legal interpretation;
- applicability;
- exception;
- regulatory scope;
- amendment impact.
61. Evidence Assurance
Evidence assurance should evaluate:- authenticity;
- completeness;
- integrity;
- currency;
- traceability;
- consistency.
62. Conformity Readiness Assurance
AIGO may provide a readiness review covering:- documentation;
- controls;
- risk management;
- evidence;
- QMS;
- conformity pathway.
CONFORMITY_READINESS_ASSURANCE
unless it is a statutory conformity assessment.
63. Regulatory-Readiness Assurance
Regulatory-readiness assurance evaluates whether the organization can respond effectively to:- information requests;
- investigations;
- inspections;
- complaints;
- submissions;
- enforcement findings.
64. Independent Assurance
Independent assurance should be used where:- risk is high;
- rights impact is material;
- regulatory significance is high;
- systemic risk exists;
- control independence is required.
65. Assurance Planning
Each assurance activity should have:66. Assurance Criteria
Criteria should come from:- binding legal text;
- applicable official implementation material;
- approved AIGO controls;
- organizational policies;
- technical requirements;
- conformity requirements where relevant.
67. Assurance Testing
Potential methods:68. Sampling
Sampling may be used for recurring evidence or control operations. The assurance record should state:- population;
- sampling approach;
- sample size;
- sample selection;
- exceptions;
- conclusion.
69. Assurance Findings
Findings should distinguish:70. Assurance Finding Lifecycle
71. Corrective-Action Evidence
Evidence should demonstrate:- action completed;
- responsible owner;
- implementation;
- testing;
- validation;
- effectiveness;
- closure approval.
72. Assurance and Continuous Improvement
The assurance loop is:73. Assurance and Management Review
Management review should receive:- critical findings;
- overdue actions;
- evidence gaps;
- recurring findings;
- regulatory issues;
- systemic-risk findings;
- material rights findings;
- conformity-readiness issues.
74. Evidence and Management Review
Management review should have evidence that supports:- current control coverage;
- evidence coverage;
- assurance status;
- regulatory status;
- incidents;
- changes;
- upcoming deadlines.
75. Evidence and AI Act Timeline
Evidence should carry applicability context. For example:76. Evidence and Transitional Rules
Evidence for a transitional system should contain:- original market date;
- transitional legal basis;
- system version;
- current state;
- significant-change analysis;
- deadline;
- implementation progress.
77. Evidence and Article 50 Transition
For certain pre-existing synthetic-content systems, AIGO should retain:- market-placement date;
- transition eligibility;
- content capability;
- Article 50(2) implementation;
- deadline;
- technical marking evidence.
78. Evidence and GPAI Enforcement
As of 2 August 2026, the Commission’s enforcement powers concerning GPAI provider obligations apply. GPAI evidence should therefore be treated as a current enforcement-readiness matter.79. Evidence and EU SEND
Where EU SEND submission is required, the submission record should be treated as authoritative regulatory evidence. AIGO should retain:80. Regulatory Evidence and Confidentiality
Evidence may contain:- trade secrets;
- model architecture;
- security information;
- personal data;
- legal advice;
- business-sensitive information.
- role-based access;
- classification;
- encryption;
- restricted repositories;
- legal holds;
- controlled disclosure.
81. Evidence Minimization
Evidence retention does not mean retaining unlimited information. The organization should retain what is:- legally required;
- necessary to demonstrate governance;
- necessary for assurance;
- necessary for investigation;
- proportionate.
82. Evidence Retention
Retention should consider:- AI Act requirements;
- applicable sectoral requirements;
- data-protection law;
- litigation holds;
- regulatory investigations;
- contractual obligations;
- organizational retention policy.
83. Evidence Disposal
Disposal should be controlled. Potential evidence:- disposal authorization;
- retention expiry;
- destruction method;
- repository;
- date;
- responsible person.
84. Evidence and Historical State
Historical evidence should remain associated with:- historical system version;
- historical legal baseline;
- historical control;
- historical decision.
85. Evidence and Regulatory Amendments
When law changes:86. Evidence and Source Currency
Every legal-source evidence record should identify:- source;
- version;
- date accessed;
- amendment;
- applicability;
- reviewer.
87. Assurance Source Currency
Assurance criteria should be verified against current legal and official sources before each assurance cycle. The Commission’s high-risk classification guidance remains subject to regulatory development, while the final transparency guidelines were adopted in July 2026. This difference in source maturity should be reflected in assurance criteria.88. Evidence and Official Guidance
Official guidance can support evidence and interpretation, but AIGO must distinguish:89. Code-of-Practice Evidence
Where an organization relies on an EU AI Act Code of Practice, evidence should include:- code version;
- signatory status where relevant;
- applicable measures;
- implementation;
- mapping;
- deviations;
- alternative measures;
- assurance.
90. Assurance of Code Implementation
Assurance may test:- whether the organization actually implemented the Code measures it claims;
- whether the relevant scope is correct;
- whether deviations are controlled;
- whether evidence exists;
- whether alternative measures are documented.
91. Evidence of Regulatory Monitoring
The regulatory-change control should retain:- monitored source;
- date;
- change identified;
- legal impact;
- affected mappings;
- affected controls;
- decisions;
- implementation evidence.
92. Regulatory-Change Assurance
Assurance should test whether:- regulatory changes are identified;
- relevant changes reach owners;
- affected controls are updated;
- timeline changes propagate;
- evidence is updated;
- obsolete documents are controlled.
93. AI Act Evidence Coverage
A future coverage model may calculate:94. Evidence Coverage Categories
AIGO may report:95. Evidence Gaps
Potential findings include:96. Critical Evidence Gaps
Potential critical evidence gaps include:- no evidence for prohibited-practice screening;
- no evidence for required high-risk risk management;
- no technical documentation for an applicable high-risk system;
- no required conformity evidence;
- no GPAI systemic-risk documentation;
- no required regulatory submission evidence;
- no evidence of mandatory rights assessment;
- material evidence destroyed during regulatory proceedings.
97. Assurance Coverage
AIGO should report:98. Assurance Prioritization
Assurance priority should consider:- legal criticality;
- safety;
- fundamental-rights impact;
- system scale;
- systemic risk;
- control criticality;
- incident history;
- regulatory attention;
- evidence weaknesses.
99. High-Risk Assurance
For high-risk AI, assurance may prioritize:- classification;
- risk management;
- data governance;
- technical documentation;
- human oversight;
- accuracy;
- robustness;
- cybersecurity;
- conformity;
- monitoring.
100. GPAI Assurance
For GPAI providers, assurance may prioritize:- model classification;
- technical documentation;
- downstream information;
- copyright policy;
- training summary;
- systemic-risk determination;
- safety/security;
- incident management;
- regulatory submissions.
101. Transparency Assurance
For Article 50, assurance may prioritize:- applicability;
- direct interaction disclosure;
- machine-readable marking;
- deepfake disclosure;
- public-interest text disclosure;
- biometric/emotion notification;
- testing;
- evidence.
102. Rights Assurance
Rights assurance may prioritize:- affected-person identification;
- Article 27 applicability;
- fundamental-rights impact;
- bias;
- human oversight;
- complaints;
- remediation;
- evidence.
103. Regulatory-Readiness Assurance
Regulatory-readiness assurance should evaluate:- authority register;
- regulatory monitoring;
- submission controls;
- deadlines;
- evidence retrieval;
- incident escalation;
- investigation readiness.
104. Assurance Independence
The organization should define independence requirements. Potential levels:105. Assurance Conflicts of Interest
Where possible, the assurance reviewer should not be the person solely responsible for operating the control being assessed. Material assurance activities should document independence considerations.106. Assurance Evidence
The assurance file should contain:- scope;
- criteria;
- source;
- evidence reviewed;
- methodology;
- tests;
- findings;
- conclusion;
- reviewer;
- date;
- approval.
107. Assurance Conclusion Types
AIGO may use:108. Assurance Findings and Corrective Action
Every major or critical assurance finding should have:- owner;
- action;
- deadline;
- evidence requirement;
- verification;
- closure.
109. Assurance Follow-Up
Follow-up should verify:110. Management Assurance Dashboard
Management may receive:
These are governance metrics rather than statutory compliance percentages.
111. Evidence and Repository Health
The Repository Health Checker should inspect:- missing evidence;
- broken references;
- stale evidence;
- duplicate records;
- missing owners;
- inconsistent system versions;
- orphaned assessments;
- orphaned assurance records.
112. Evidence and Framework Consistency
The Framework Consistency Checker should identify contradictions among:- AI System Profile;
- classification;
- risk;
- controls;
- assessments;
- technical documentation;
- approvals;
- monitoring;
- incidents;
- changes;
- assurance.
113. Evidence and Reference Validation
The Reference Validator should verify that:- legal sources resolve;
- AIGO control IDs resolve;
- system IDs resolve;
- evidence IDs resolve;
- assessment IDs resolve;
- assurance IDs resolve.
114. Evidence and Traceability Validation
The Traceability Validator should detect broken chains such as:115. Evidence and Schema Validation
The Schema Validator should verify that evidence records conform to:- Evidence Schema;
- related AI System Schema;
- Risk Schema;
- Control Schema;
- Assessment Schema;
- Assurance Schema;
- Incident Schema;
- Change Schema.
116. Regulatory Evidence Pack
For a material AI system, AIGO should be capable of producing a controlled evidence pack containing:117. Evidence-Pack Version
Every evidence pack should identify:- pack ID;
- generated date;
- legal baseline;
- AIGO version;
- system version;
- included evidence versions;
- exclusions;
- reviewer.
118. Evidence-Pack Integrity
Where a pack may be submitted externally, the organization should preserve:- generation event;
- content manifest;
- evidence IDs;
- file integrity;
- access history;
- submission record.
119. Regulatory Submission Evidence Pack
For regulatory submissions, AIGO should maintain:120. Evidence and Corrective Action
When evidence reveals a gap:121. Evidence and Continual Improvement
The evidence model should support organizational learning:- recurring failures;
- evidence-quality trends;
- control gaps;
- assurance findings;
- regulatory developments;
- incident patterns.
122. Evidence Retention and Retirement
When an AI system is retired, evidence should not automatically be deleted. AIGO should determine:- legal retention;
- regulatory retention;
- assurance retention;
- incident retention;
- contractual retention.
123. Retirement Evidence
Potential records:- retirement decision;
- final system version;
- final risk state;
- final monitoring;
- incidents;
- conformity;
- registration;
- authority communication;
- evidence-retention decision.
124. Historical Assurance
Historical assurance should remain associated with:- historical system;
- historical control;
- historical legal baseline;
- historical evidence.
125. Evidence and Legal Amendments
When the legal framework changes:126. Evidence and Current Legal Baseline
This mapping uses:127. Current Timeline Evidence
The central timeline source is:11-AIGO-EU-AI-Act-Applicability-and-Timeline-v0.1.md
Evidence records should identify whether the applicable requirement was:
128. Future Requirement Evidence
Evidence collected before legal application should be labelled clearly. Example:129. Evidence and Annual Regulatory Review
The Commission’s 2026 report on Article 5 and Annex III demonstrates ongoing annual review of prohibited practices and high-risk use cases. AIGO should retain evidence of:- annual regulatory review;
- affected system analysis;
- mapping update;
- control impact;
- management review.
130. Assurance and Regulatory Change
Assurance should test whether regulatory reviews actually produce changes where required. Recommended test:131. Assurance and Official Guidance
Where official guidance is not legally binding, assurance criteria should identify it as implementation guidance rather than legal text. For high-risk classification, current Commission guidance remains identified as draft/non-binding in the current Commission materials. For transparency, final Commission guidelines were adopted in July 2026. This difference should be reflected in the source metadata.132. Assurance and Code of Practice
A Code of Practice may support implementation but should not be treated as identical to binding law. Assurance should evaluate:- which Code measures were adopted;
- whether they are implemented;
- whether alternative measures are used;
- whether evidence supports the claim.
133. Evidence and External Assessment
When an external auditor, notified body, assessor, or authority requests evidence: AIGO should provide the evidence through controlled access and preserve the interaction record.134. Evidence Disclosure Control
Control Name: EU AI Act Evidence Disclosure Governance The control should determine:- requested evidence;
- authority;
- legal basis;
- confidentiality;
- personal-data implications;
- trade secrets;
- approved disclosure;
- submission channel;
- evidence of disclosure.
135. Evidence Redaction
Where lawful and necessary, evidence may require controlled redaction. The record should preserve:- original evidence;
- redacted version;
- reason;
- authority request;
- reviewer;
- approval.
136. Assurance Report Integrity
Assurance reports should be controlled evidence. Each should have:- report ID;
- scope;
- date;
- reviewer;
- version;
- conclusion;
- findings;
- approval.
137. Evidence Control Matrix
138. Evidence Coverage Model
AIGO should ultimately support:139. Assurance Coverage Model
140. Evidence and Assurance Metrics
Potential management metrics:141. Critical Evidence and Assurance Threshold
AIGO should define a rule that certain critical governance controls cannot be treated as assured where material evidence is absent. Potential critical areas include:- prohibited practices;
- high-risk risk management;
- human oversight;
- cybersecurity;
- systemic-risk GPAI;
- fundamental rights;
- regulatory submissions;
- conformity.
142. Evidence and Control Coverage Validator
The Control Coverage Validator should consume this mapping to determine:- which controls are applicable;
- which are critical;
- which are implemented;
- which have evidence;
- which have assurance.
143. Evidence Coverage Validator
The Evidence Coverage Validator should consume this mapping to determine:- evidence requirement;
- evidence ID;
- current status;
- system version;
- completeness;
- validation;
- review.
144. Traceability Validator
The Traceability Validator should verify:145. Framework Consistency Checker
The checker should detect:- inconsistent legal references;
- mismatched system IDs;
- conflicting versions;
- contradictory classification;
- conflicting evidence status;
- stale control relationships;
- inconsistent assurance conclusions.
146. Document Integrity Checker
The checker should verify:- file existence;
- file readability;
- required sections;
- metadata;
- version;
- references;
- links;
- document status.
147. Repository Health Checker
The repository health layer should aggregate:148. Evidence Findings
Potential findings:149. Assurance Findings
Potential findings:150. Critical Findings
Potential critical evidence/assurance findings:- statutory requirement has no identifiable evidence;
- critical control has no operating evidence;
- evidence required by a regulator cannot be produced;
- evidence integrity is compromised;
- material regulatory submission cannot be verified;
- critical assurance finding remains unresolved;
- conformity evidence cannot be linked to the correct system version;
- systemic-risk GPAI safety/security evidence is materially incomplete.
151. Evidence and Risk Acceptance
Evidence gaps should not automatically be accepted as ordinary residual risk when the evidence is required by law or needed to demonstrate a mandatory control. The organization should distinguish:152. Assurance and Risk Acceptance
An assurance reviewer may identify that risk acceptance was used incorrectly. For example:153. Evidence and Exceptions
Evidence for an exception should include:- legal basis;
- applicability;
- approving authority;
- conditions;
- expiry;
- compensating controls;
- evidence;
- review.
154. Assurance of Exceptions
Assurance should test:- whether the exception actually applies;
- whether conditions are satisfied;
- whether expiry is controlled;
- whether compensating controls exist.
155. Evidence and Third Parties
Third-party evidence should identify:- provider;
- source;
- contract;
- system;
- date;
- version;
- validation;
- responsibility.
156. Assurance of Third-Party Evidence
Assurance may sample:- supplier documentation;
- certificates;
- provider claims;
- security reports;
- testing;
- change notices.
157. Evidence and GPAI Downstream Providers
Where a GPAI provider supplies downstream documentation, the downstream organization should preserve:- received package;
- model version;
- date received;
- provider;
- changes;
- review;
- integration impact.
158. Assurance of GPAI Downstream Information
The downstream organization may assess:- completeness;
- usability;
- currency;
- consistency;
- known limitations;
- change notifications.
159. Evidence and Transparency Code
Where the transparency Code of Practice is adopted, evidence should identify:- adopted measures;
- implementation;
- version;
- exclusions;
- alternative measures.
160. Evidence and High-Risk Guidelines
Where the organization’s classification decision relies on Commission guidance, evidence should label it as:OFFICIAL_NON_BINDING_GUIDANCE
until a legally binding source establishes otherwise.
Current Commission high-risk classification guidance was still described as draft in the latest available Commission publication during this mapping cycle.
161. Assurance Source Hierarchy
Assurance criteria should follow:162. Assurance Planning by Risk
The assurance programme should allocate more resources to:- prohibited practices;
- high-risk AI;
- systemic-risk GPAI;
- fundamental-rights impacts;
- safety;
- cybersecurity;
- material conformity;
- regulatory submissions.
163. Assurance and Materiality
Materiality factors may include:- potential harm;
- number of affected persons;
- legal significance;
- regulatory significance;
- financial significance;
- safety significance;
- rights significance;
- likelihood.
164. Assurance and Lifecycle
Assurance should occur at multiple stages:165. Assurance Release Gate
Before an AI system is released into an assurance-relevant operational state, the organization should verify:- required evidence exists;
- critical gaps are addressed;
- required assurance is complete;
- unresolved issues are formally governed;
- applicable legal status is clear.
166. Evidence and Deployment Approval
The approval process may require:167. Evidence and Post-Market Monitoring
Evidence should be continuously generated during operation. Potential sources:- model performance;
- user feedback;
- incidents;
- complaints;
- security events;
- rights impacts;
- provider notifications.
168. Assurance and Post-Market Monitoring
Assurance may test:- monitoring design;
- monitoring execution;
- threshold accuracy;
- escalation;
- corrective action.
169. Regulatory Evidence Pack Readiness
An organization should periodically test whether it can retrieve the evidence needed for a material regulatory inquiry. A readiness test may ask:170. Regulatory Evidence Retrieval Test
A future AIGO assurance procedure may use:171. Evidence Response Time
Organizations may monitor:- evidence retrieval time;
- regulatory response time;
- evidence validation time;
- approval time.
172. Evidence and Management Review
Management should review:- evidence gaps;
- assurance gaps;
- regulatory requests;
- recurring evidence failures;
- system-version inconsistencies;
- retention issues.
173. Evidence and Continuous Improvement
Evidence quality should improve through:- metadata standards;
- central identifiers;
- controlled repositories;
- automated validation;
- evidence templates;
- clear ownership;
- periodic assurance.
174. Machine-Readable Evidence Relationship
A future machine-readable mapping may represent:175. Evidence Registry Integration
The evidence registry should support relationships:176. Assurance Registry Integration
The assurance registry should support:177. Evidence and Assurance Versioning
When a control changes:178. Evidence and Regulatory Baseline Versioning
An evidence record should optionally identify:179. Evidence and Current Date
Because AI regulation changes over time, evidence should preserve the date on which the legal applicability determination was made. This prevents an organization from applying today’s legal interpretation retrospectively without a documented basis.180. Evidence Review Frequency
Evidence should be reviewed:- according to control frequency;
- after material change;
- after regulatory amendment;
- before assurance;
- before regulatory submission;
- when evidence becomes stale.
181. Evidence Revalidation
Revalidation should determine:- still applicable?
- still current?
- still attributable?
- still complete?
- still aligned to the system version?
- still aligned to the legal baseline?
182. Evidence Supersession
When new evidence replaces older evidence:183. Evidence Correction
If an evidence record contains an error:- do not silently overwrite where historical integrity matters;
- create corrected version;
- record correction reason;
- preserve previous version where appropriate;
- reassess linked assurance.
184. Assurance Reperformance
Assurance should be repeated where:- material evidence changes;
- control changes;
- legal requirement changes;
- material incident occurs;
- assurance finding remains unresolved.
185. Assurance and Regulatory Amendments
A legal amendment should trigger assessment of:186. Evidence and Annual Regulatory Review
The organization should preserve evidence of the annual regulatory review process. The Commission’s 2026 review of prohibited practices and Annex III demonstrates that the regulatory environment is subject to periodic review and future modification.187. Evidence and Official Consultation
Where an organization contributes to:- public consultation;
- regulatory sandbox;
- standards development;
- AI Office consultation;
188. Assurance and Regulatory Learning
Regulatory sandboxes and implementation experience may generate evidence useful for future assurance and improvement. The evidence should identify:- experiment;
- scope;
- result;
- limitations;
- regulatory interpretation;
- lessons learned.
189. Assurance and Emerging Technology
For emerging technologies such as agentic AI, assurance should focus on:- autonomy;
- control boundaries;
- human intervention;
- logging;
- security;
- model/system interactions;
- unintended actions.
190. Evidence and Agentic Systems
Where relevant, evidence should include:- agent architecture;
- tool access;
- authorization boundaries;
- intervention;
- action logs;
- safety tests;
- failure modes;
- shutdown;
- monitoring.
191. Assurance and Agentic Systems
Assurance may test:- authorization controls;
- action boundaries;
- human intervention;
- logging;
- tool use;
- failure handling.
192. Evidence and Systemic Risk
Systemic-risk GPAI evidence should receive enhanced protection and review because it may contain highly sensitive technical, safety, or security information. The Commission’s current GPAI framework identifies systemic-risk obligations including risk assessment, incident reporting, and cybersecurity.193. Systemic-Risk Evidence Pack
Potential content:194. Systemic-Risk Assurance
Assurance should consider:- systemic-risk classification;
- safety;
- security;
- evaluation;
- incident handling;
- regulatory reporting;
- evidence completeness.
195. Evidence and Transparency Risk
Transparency evidence should be tested for actual user exposure. A hidden configuration value may not demonstrate that users were informed. The evidence model should therefore distinguish:196. Evidence and Human Oversight
Similarly:197. Evidence and Control Effectiveness
For every critical control, the preferred evidence sequence is:198. Evidence and Risk Treatment
A risk treatment should identify:- treatment action;
- control;
- evidence;
- expected effect;
- residual risk;
- verification.
199. Assurance and Residual Risk
Assurance may evaluate whether:- residual risk is supported by evidence;
- treatment was implemented;
- monitoring is active;
- acceptance authority was appropriate.
200. Assurance Conclusion
AIGΟ assurance should conclude on the defined criteria, not on a broader undefined claim of “AI Act compliance.” Example:201. Evidence and Legal Compliance Claims
The repository should avoid unsupported claims such as:- “fully AI Act compliant”;
- “certified by AIGO”;
- “approved under the AI Act”;
- “conformity achieved” without the applicable statutory process.
202. Evidence and Audit Trail
The AIGO audit trail should allow reconstruction of:- requirement;
- decision;
- control;
- evidence;
- reviewer;
- assurance;
- finding;
- action;
- closure.
203. Evidence and Auditability
The audit trail should be:- chronological;
- attributable;
- versioned;
- tamper-resistant;
- searchable;
- retrievable.
204. Evidence Accessibility
Evidence should be accessible to authorized:- governance;
- legal/compliance;
- assurance;
- technical;
- regulatory-response personnel.
205. Evidence and Security
Evidence repositories should be protected against:- unauthorized access;
- unauthorized modification;
- deletion;
- leakage;
- ransomware;
- accidental loss.
206. Evidence and Privacy
Evidence may contain personal data. The organization should apply:- data minimization;
- purpose limitation;
- access restriction;
- retention;
- secure deletion;
- applicable data-protection law.
207. Assurance Data Protection
Assurance teams should only obtain the evidence needed for the review and should control copies of sensitive evidence.208. Evidence and Third-Party Confidentiality
Supplier evidence may contain trade secrets or confidential information. The repository should maintain:- classification;
- access restrictions;
- contractual rights;
- disclosure rules.
209. Evidence and Regulatory Disclosure
Before regulatory disclosure, the organization should assess:- requested scope;
- confidentiality;
- personal data;
- trade secrets;
- legal basis;
- applicable disclosure obligation.
210. Evidence and Notified Bodies
Where a notified body requests evidence, the organization should maintain:- request;
- scope;
- evidence package;
- response;
- findings;
- corrective action;
- closure.
211. Assurance and Notified Bodies
AIGO assurance can assess readiness for notified-body engagement but must not represent itself as a notified body.212. Evidence and Market Surveillance
Where market-surveillance authorities request information, AIGO should support:- rapid evidence retrieval;
- legal review;
- integrity;
- submission;
- tracking.
213. Assurance and Market Surveillance
Regulatory-readiness assurance can test whether the evidence package can be retrieved and produced within required timelines.214. Regulatory Evidence Response
The recommended workflow is:215. Evidence and Enforcement
If an enforcement decision is received:216. Evidence and Commitments
Regulatory commitments should generate a dedicated evidence trail.217. Evidence and Fines
A fine should generate evidence of:- decision;
- amount;
- legal basis;
- payment;
- corrective action;
- governance response.
218. Evidence and Periodic Penalty Payments
Where periodic penalty payments are imposed, AIGO should track:- authority decision;
- daily amount;
- compliance condition;
- start date;
- end date;
- evidence of compliance;
- cessation decision.
219. Assurance of Enforcement Response
An assurance review should determine whether:- the enforcement issue was understood;
- corrective actions were implemented;
- evidence exists;
- recurring risk remains;
- management addressed root causes.
220. Evidence and Continuous Improvement
Regulatory and assurance findings should feed the AIGO Improvement process. The loop is:221. Master Evidence Matrix
222. Evidence Prioritization
Evidence should be prioritized based on:- legal criticality;
- safety;
- fundamental rights;
- regulatory exposure;
- system impact;
- control criticality;
- incident history.
223. Evidence Review Frequency
Evidence review should follow the corresponding control. Possible frequencies:224. Evidence Owner
Every material evidence category should have an accountable owner. Potential owners:- AI System Owner;
- Control Owner;
- Risk Owner;
- Evidence Owner;
- Technical Owner;
- Compliance Owner;
- Assurance Owner.
225. Evidence Escalation
Evidence gaps should escalate when:- evidence is legally required;
- evidence supports a critical control;
- regulator request exists;
- assurance cannot conclude;
- evidence integrity is compromised;
- deadline is approaching.
226. Evidence Review Board
The organization may establish a cross-functional evidence review mechanism involving:- AI Governance;
- Legal/Compliance;
- Risk;
- Technical;
- Assurance;
- Records Management.
227. Evidence and AIGO Schemas
228. Evidence and Existing Templates
The following existing templates should support evidence production:- AI System Registration;
- AI System Profile;
- AI Classification;
- AI Risk Assessment;
- AI Approval;
- AI Monitoring;
- AI Incident;
- AI Change Management;
- AI Assurance;
- AI Management Review;
- AI Continuous Improvement;
- AI Retirement;
- AI Evidence Record.
229. Evidence and AIGO Tools
This mapping should be consumed by:- Schema Validator;
- Reference Validator;
- Traceability Validator;
- Control Coverage Validator;
- Evidence Coverage Validator;
- Framework Consistency Checker;
- Document Integrity Checker;
- Repository Health Checker.
230. Evidence Registry Requirements
The machine-readable evidence registry should eventually support:231. Assurance Registry Requirements
The machine-readable assurance registry should support:232. Evidence and Assurance Relationship
The primary relationship is:233. Evidence Reuse
Evidence may be reused when:- it remains current;
- it applies to the same system/version;
- the legal context is compatible;
- the evidence scope is sufficient.
234. Evidence Duplication
AIGO should prefer controlled cross-reference over unnecessary duplication. Example:235. Evidence Supersession
When evidence is replaced:- new evidence becomes current;
- old evidence becomes superseded;
- history remains traceable;
- linked assurance should be reassessed where material.
236. Assurance Reuse
Prior assurance may be reused only when:- scope remains valid;
- legal baseline remains valid;
- system remains materially unchanged;
- evidence remains current.
237. Evidence and Change Impact
Changes should automatically identify affected evidence. Potential impacts:238. Assurance and Change Impact
Assurance should assess whether material changes have been correctly reflected in evidence and controls.239. Evidence and Retirement
The retirement process should include:240. Evidence and Lessons Learned
Retirement may generate evidence used for future improvement:- incidents;
- performance;
- assurance findings;
- user feedback;
- regulatory findings.
241. Evidence Quality Dashboard
AIGO may provide a dashboard showing:242. Evidence Health Categories
Potential health status:243. Assurance Health Categories
Potential assurance status:244. Evidence Governance Minimum Standard
For material AI systems, AIGO should be able to answer:- What system is this?
- Which legal requirements apply?
- Why do they apply?
- Which controls address them?
- What evidence demonstrates implementation?
- Is the evidence current?
- Has the evidence been assessed?
- What findings exist?
- What remediation is underway?
- Who reviewed it?
245. Assurance Governance Minimum Standard
For material controls, AIGO should be able to answer:- What was reviewed?
- Against what criteria?
- What evidence was examined?
- Who performed the assurance?
- Was the reviewer independent?
- What was concluded?
- What findings were identified?
- What remediation is required?
- Was remediation verified?
- When is reassessment required?
246. Critical Evidence Assurance Rule
Where evidence is unavailable for a critical control, the assurance conclusion should normally be:INSUFFICIENT_EVIDENCE
unless sufficient alternative evidence exists and the alternative is documented.
247. Alternative Evidence
Alternative evidence may be accepted where:- the primary evidence type is unavailable;
- the alternative is sufficiently reliable;
- the legal requirement does not mandate the primary form;
- the alternative is documented.
248. Legal Evidence Versus Governance Evidence
AIGO should distinguish:249. Statutory Evidence Boundary
Examples of statutory or externally issued evidence may include:- certificate;
- declaration;
- registration acknowledgment;
- authority decision;
- regulatory submission receipt.
- internal approval;
- internal assessment;
- control record;
- internal assurance report.
250. Evidence and Legal Source
Every material evidence claim should identify its relationship to a legal or governance requirement. For example:251. Evidence and Regulatory Source Currency
Evidence should identify the legal baseline under which the decision was made. This is particularly important after amendments such as Regulation (EU) 2026/1744.252. Evidence Assurance Matrix
253. Current Regulatory Source Baseline
This version should be reviewed against:- Regulation (EU) 2024/1689;
- Regulation (EU) 2026/1744;
- current Commission AI Act framework material;
- current GPAI guidance;
- current transparency guidance;
- current official implementation material.
254. Current GPAI Baseline
GPAI obligations are currently applicable, and Commission enforcement powers entered into application on 2 August 2026. Providers of GPAI models placed on the market before 2 August 2025 have until 2 August 2027 to comply. AIGO should therefore treat GPAI evidence and assurance as current governance requirements.255. Current Transparency Baseline
Article 50 transparency obligations apply from 2 August 2026 under the current Commission implementation framework. The transparency Code of Practice is a voluntary adequate implementation tool, but adherence does not constitute conclusive proof of compliance.256. Current High-Risk Baseline
The current implementation schedule provides:257. Regulatory Review Baseline
The Commission’s 2026 review of Article 5 and Annex III confirms that those lists remain subject to ongoing regulatory review. AIGO should therefore consider regulatory currency itself an assurance criterion.258. Evidence and Regulatory Change Control
A material legal change should generate:259. Evidence and Mapping Version
Every assurance activity should identify the mapping version used. Example:260. Evidence and Assurance Release Gate
The EU AI Act mapping package should not be marked ready for operational release unless:- critical evidence requirements are defined;
- critical controls are mapped;
- assurance expectations are defined;
- timeline is current;
- references resolve;
- evidence identifiers are stable;
- document integrity checks pass.
261. Evidence Quality Standard
A high-quality evidence framework should be:- authoritative;
- attributable;
- versioned;
- traceable;
- current;
- complete;
- protected;
- reviewable;
- proportionate.
262. Assurance Quality Standard
A high-quality assurance framework should be:- criterion-based;
- evidence-based;
- appropriately independent;
- repeatable;
- documented;
- proportionate;
- transparent about limitations;
- linked to remediation.
263. Evidence and Assurance Coverage
The complete governance chain is:264. Evidence Findings
Potential findings include:265. Assurance Findings
Potential findings include:266. Critical Findings
Potential critical findings include:- legally required evidence unavailable;
- required conformity evidence unavailable;
- critical system version cannot be established;
- regulatory submission cannot be evidenced;
- critical control cannot be assured;
- evidence integrity compromised;
- regulatory preservation obligation breached.
267. Validation Requirements
The evidence and assurance mapping should pass:Legal Source Validation
Every material evidence requirement maps to an applicable source.Control Validation
Every material evidence requirement maps to an AIGO control.Evidence Validation
Evidence types are defined.Traceability Validation
Requirement → control → evidence → assurance chain exists.Version Validation
System, control, evidence, and legal versions are consistent.Timeline Validation
Evidence status respects application dates and transitions.Assurance Validation
Critical controls have defined assurance expectations.Repository Validation
Identifiers resolve throughout the repository.268. Limitations
This document cannot independently determine:- whether evidence is legally sufficient in a specific proceeding;
- whether a regulator will accept an evidence package;
- whether a notified body will accept an artifact;
- whether a control is legally compliant;
- whether a specific assurance conclusion establishes conformity;
- whether evidence satisfies all requirements of another applicable legal regime.
269. Relationship to Other EU AI Act Mappings
This document closes the evidence and assurance layer of the EU AI Act mapping package.
270. Relationship to AIGO Schemas
No additional generic evidence or assurance schema is required at this stage.
271. Relationship to AIGO Templates
Relevant templates include:- AI System Registration Template;
- AI System Profile Template;
- AI Classification Template;
- AI Risk Assessment Template;
- AI Approval Template;
- AI Monitoring Template;
- AI Incident Template;
- AI Change Management Template;
- AI Assurance Template;
- AI Management Review Template;
- AI Continuous Improvement Template;
- AI Retirement Template;
- AI Evidence Record Template.
272. Relationship to AIGO Tools
The evidence and assurance mapping should be consumed by:- Schema Validator;
- Reference Validator;
- Traceability Validator;
- Control Coverage Validator;
- Evidence Coverage Validator;
- Framework Consistency Checker;
- Document Integrity Checker;
- Repository Health Checker.
273. Future Automation Model
A future automated validation flow may execute:274. Final Governance Model
The intended AIGO evidence and assurance lifecycle is:275. Document Control
276. Document Status
Document: AIGO — EU AI Act Evidence and Assurance Mapping Version: 0.1 Status: Draft Working Name: AIGO Full Name: AI Governance Operating Framework Document Identifier:AIGO-MAP-EUAI-013
Document Type: EU AI Act Mapping
This document establishes the evidence and assurance layer for the AIGO EU AI Act mapping package, linking legal requirements to controls, evidence, assessments, monitoring, assurance, findings, corrective actions, improvement, and reassessment.
End of Document