Annex IV §1(a)

Annex IV §1(a) — Intended Purpose Statement (EU AI Act)

How to write the intended-purpose statement for Annex IV §1(a) under Regulation (EU) 2024/1689. Excluded uses, scope-bounding, and the link to Article 25 promotion risk.

Source: Regulation (EU) 2024/1689 on EUR-Lex · Last published 2026-04-28 · Draft pending human review

What §1(a) actually requires

Annex IV §1(a) of Regulation (EU) 2024/1689 requires the technical documentation to state the intended purpose of the AI system, the name of the provider, and the version of the system reflecting its relation to previous versions.

The intended purpose is the most important sentence in the entire Article 11 file. It defines:

  • Scope of obligation. What the system is for determines whether the Article 6 high-risk classification applies.
  • Scope of foreseeable harm. What the system is not for narrows the Article 9 risk register.
  • Article 25 promotion risk. A deployer who changes the intended purpose to a high-risk use case becomes a provider under Article 25(c).

Article 3(12) definition

Article 3(12) defines intended purpose as "the use for which an AI system is intended by the provider, including the specific context and conditions of use, as specified in the information supplied by the provider in the instructions for use, promotional or sales materials and statements, as well as in the technical documentation."

So the intended purpose is not just the §1(a) sentence. It is the consistent statement across:

  • The Annex IV §1(a) entry.
  • The Article 13 instructions for use.
  • Marketing collateral and sales materials.
  • The Article 49 EU Database registration.

Inconsistencies are non-conformity evidence.

What to write

A defensible intended-purpose statement has four elements:

  1. The use case, named precisely. Not "decision support" — "real-time scoring of consumer-loan applications between PLN 5,000 and PLN 80,000 in retail banking, returning approve/decline/human-review."
  2. The deployer profile. EU law firms, public hospitals, regulated banks. Restricting deployer type narrows the risk surface.
  3. Geographic scope. Trained and validated in/for which jurisdictions, languages, populations.
  4. Excluded uses. This is the load-bearing element. Exclusions narrow the Article 9 foreseeable-harm scope.

A worked example

"DriverScore v2.4 is a supervised-learning classifier that ranks long-haul drivers on a 0–100 safety score using telematics features. Intended purpose: internal shift allocation and voluntary safety coaching within Rondom Logistiek B.V. and its Group entities, deployed by safety-certified shift coordinators. Validated for Dutch and German operations; not validated for any other geography. Excluded uses: dismissal decisions, contractual penalty calculation, insurance-premium pricing, cross-employer benchmarking, and any insurance-underwriting purpose. Provider: Rondom Tech B.V. Version: v2.4.1 (released 2026-03-12; replaces v2.4.0 of 2026-02-04 — see Annex IV §5 for change details)."

That paragraph is two-thirds of an Annex IV §1(a) entry. The remaining third ties to the §1(c) version-update procedure.

Inline crosswalk

  • ISO/IEC 42001:2023 Clause 4.1 — Understanding the organisation and its context.
  • NIST AI RMF MAP 1.1 — Intended purposes, potentially beneficial uses, context-specific laws and norms are understood.

Common mistakes

  • Marketing-prose intended purpose. The audience is a regulator, not a buyer.
  • No exclusion list. A high-risk system with no excluded uses signals an unbounded risk surface.
  • Inconsistency between Annex IV §1(a), the Article 13 IFU, the EU Database registration, and marketing.
  • Updating the intended purpose informally without §5 entry.

Disclaimer. Reference; not legal advice. Verify with counsel. Reg text from Regulation (EU) 2024/1689.

Reference checklist

From the Governancer 30-item EU AI Act checklist. Each item joins to the ISO 42001 + NIST AI RMF crosswalk table below.

  • Article 11 · Starter tier · critical

    Draft technical documentation (system purpose, design, risk)

    Required for all high-risk AI systems before market placement. Our template covers the eight mandatory sections in one .docx.

ISO 42001 + NIST AI RMF crosswalk

Pulled live from the Governancer crosswalk module. Mapping reference; not a substitute for ISO 42001 certification audit or NIST AI RMF self-attestation.

ISO/IEC 42001:2023

Checklist itemISO 42001 controlRationale
art11-tech-docsISO/IEC 42001:2023 Clause 7.5 — Documented informationArticle 11 technical file is the AIMS-required documented information evidencing AI system design, purpose, and risk decisions.
art11-tech-docsISO/IEC 42001:2023 Annex A.6.2 — AI system life cycle documentationAnnex A.6.2 requires lifecycle documentation; the Article 11 technical file is its EU AI Act manifestation.

NIST AI RMF 1.0

Checklist itemNIST AI RMF subcategoryRationale
art11-tech-docsNIST AI RMF MAP 4.1 — Approaches and metrics for measurement of AI risks are followed; documentation includes purpose, intended use, users, and limitationsArticle 11 technical file documents purpose, design and limitations — the system-context output expected by MAP 4.1.
art11-tech-docsNIST AI RMF GOVERN 1.4 — The risk management process is documented and is regularly reviewedMaintaining a living technical file is the documented and regularly reviewed risk-management evidence under GOVERN 1.4.

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15-page Article 27 FRIA template (.docx) with the six elements pre-structured and a worked example.

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Reference; not legal advice. Verify with qualified counsel before relying on it for compliance decisions. Reg text quoted from the Official Journal version of Regulation (EU) 2024/1689. Published by Agonist Development AB.