Minimum Viable Evidence Architecture for SME Providers of High-Risk AI Systems under the EU AI Act
Year: 2026
Type: article
Abstract: Article 11(1) of the EU AI Act, as amended by Regulation (EU) 2026/1744, lets SMEs provide Annex IV technical documentation in a simplified manner. This research note argues that simplification changes how information is presented, not the provider’s responsibility to maintain the evidence behind it. It proposes a minimum viable evidence architecture in which each technical-file claim is linked to an evidence source, version, date, accountable owner and human review state, with missing, stale or conflicting evidence blocking approval. A prototype for Annex IV Section 1, using a fictional provider and simulated evidence, demonstrates the pattern. It does not demonstrate legal compliance. Produced as part of the AIGN Junior AI Governance Fellowship (2026), mentored by Patrick Upmann. This revised version has not been re-reviewed by AIGN. The author is developing Emetis, the software used for the prototype, as a commercial product.
Author: Engelbrecht, Larissa
Language: English
Subfield: Law
Field: Social Sciences
Domain: Social Sciences
Open Access status: green
OpenAlex ID: W7223654906