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Guide for Auditors of AI Systems Under EU Rules

Verification required. EU claims on this page were compiled on 7 October 2026 from secondary sources and from memory of the legal text. The Official Journal text was not read, and each claim is tagged [Reported], [Recalled], [Conflict] or [Unverified] as explained on the section home page. Check the primary text on EUR-Lex before relying on any of them. This is not legal advice.

For internal audit, external assurance and readiness reviewers. EU claims carry the tags used in the EU AI Regulatory Hub. A readiness audit is not a conformity assessment by a notified body.

1. Set the audit criteria honestly

Criteria Examples Caution
Binding law AI Act, GDPR, NIS2, DORA, CRA Read the Official Journal text; it was not read for this section
Guidance Commission guidelines, EDPB opinions Some are drafts only [Reported]
Standards EN 18286:2026 (OJ citation pending) and drafts [Reported]; ISO/IEC 42001 A standard gives a presumption of conformity only after OJ citation
Internal policy Client AI policy Always in scope

State in the engagement letter which criteria are law and which are reference. Because the high-risk dates have moved [Reported], also state the assessment date logic: "tested against requirements as if applicable" or "tested against requirements currently applicable".

2. Scoping

  1. Obtain the inventory (T09). If none exists, report that.
  2. Check the classification and role decisions (T01) for each system. Retest a sample independently. The common failure is classifying a system into a lower tier than it belongs in.
  3. Identify the jurisdictions and competent authorities (T11).
  4. Pick the sample: all high-risk systems and all systems close to a prohibited practice, plus a risk-weighted selection of the others.
  5. Confirm the evidence period.

3. Control families and tests

Family Wiki controls Test Evidence
Governance AI-CTRL-011, AI-CTRL-012, AI-CTRL-037 Policy, roles, board reporting, AI literacy Policy, minutes, T07
Classification AI-CTRL-011 Each system has a role and a tier with reasoning; Art. 6(3) cases documented T01
Prohibited practices AI-CTRL-012 Screening against Art. 5 is documented T01
Risk management AI-CTRL-037 Lifecycle risk process; residual risk accepted by a named owner Risk records
Data governance AI-CTRL-013, AI-CTRL-041 Provenance, bias examination, special category necessity T10
Technical documentation AI-CTRL-038 Annex IV content complete and current T10
Logging AI-CTRL-008, AI-CTRL-038 Logs reconstruct a decision; retention set Log samples
Human oversight AI-CTRL-023, AI-CTRL-025 Oversight design; reviewers trained; overrides evidenced; kill switch tested Review logs
Accuracy and cyber AI-CTRL-005, AI-CTRL-034, AI-CTRL-039 Declared metrics tested; adversarial testing Test reports
Transparency AI-CTRL-039 Disclosures, marking and notices work (T06) Screenshots, tests
Privacy AI-CTRL-013, AI-CTRL-007, AI-CTRL-017 DPIA, lawful basis, rights, transfers (T02, T04) Records
Supplier AI-CTRL-014 Due diligence, contract, sub-processors (T03) Records
Incident AI-CTRL-035 Playbook with AI Act, GDPR, NIS2 and DORA paths; exercise (T05) Records
Post-market AI-CTRL-035 Monitoring plan and results Reports
Deployer duties AI-CTRL-023, AI-CTRL-038 Use per instructions; log retention; worker information T02, T08

Use T08 for line-by-line testing and the EU Evidence Register to track requests.

4. Sampling

These are suggested defaults and have no regulatory status.

  • All high-risk systems.
  • Of the lower tiers, at least 25 percent or five systems, whichever is greater.
  • Ten decisions per high-risk system, to trace explanation and oversight.
  • All incidents in the period.

5. Techniques

  • Re-performance of bias and accuracy tests.
  • Configuration inspection: hosting region, retention, model version.
  • Walkthrough of one decision from end to end.
  • Interviews.
  • Document inspection, for example that approval predates go-live.
  • Log reconstruction test: pick a decision and rebuild its inputs and model version from the logs.

6. Common findings

  • High-risk systems classified as minimal without documented reasoning.
  • An organisation treated as a deployer only, although it fine-tunes the model.
  • Technical file started after launch.
  • Logs missing the model version or the input reference.
  • Oversight reviewers who approve without time to review.
  • No FRIA where the deployer category needs one [Recalled; Art. 27 scope to verify].
  • AI literacy limited to a slide deck with no role-based content.
  • Transfers to non-EU AI APIs that were never assessed.
  • Sub-processors unknown.

7. Rating and wording

Rate each test Effective, Partially effective, Ineffective or Not tested. Write each finding as criteria, condition, cause, effect and recommendation.

Limitation sentence: "Criteria were taken from the client's regulatory register dated [date], compiled from secondary sources and not verified against the Official Journal. This report is not a legal opinion or a conformity assessment."

8. Report checklist

  • Scope, period, criteria and their verification status
  • Systems and sample
  • Limitations
  • Findings with references
  • Management responses with dates
  • Follow-up

9. Handling

Keep evidence that contains personal data under production controls. Do not paste it into external AI tools.