EU AI Act Article 13 — Transparency and Instructions for Use

What Article 13 actually requires

Article 13 of Regulation (EU) 2024/1689 obliges providers of high-risk AI systems to design those systems so their operation is sufficiently transparent to enable deployers to interpret the output and use it appropriately. The principal vehicle is the instructions for use (IFU) — a document accompanying the system that contains concise, complete, correct and clear information that is relevant, accessible and comprehensible to deployers.

Reg text — Article 13(1): "High-risk AI systems shall be designed and developed in such a way as to ensure that their operation is sufficiently transparent to enable deployers to interpret a system's output and use it appropriately."

Required IFU content — Article 13(3)

The IFU must include at least:

• (a) Provider identity and contact details (and EU representative under Article 22 if non-EU).
• (b) System characteristics, capabilities and limitations of performance, including intended purpose, accuracy levels, foreseeable circumstances that may lead to risks, performance for specific persons or groups, technical capabilities, training-data provenance, and known/foreseeable circumstances of use that may produce risks.
• (c) Any pre-determined changes to the system and its performance.
• (d) Human-oversight measures referred to in Article 14, including the technical measures to facilitate the interpretation of outputs.
• (e) Computational and hardware resources needed, expected lifetime and any necessary maintenance and care measures.
• (f) Where relevant, the mechanisms allowing deployers to properly collect, store and interpret the Article 12 logs.

Who is covered

Providers design the IFU. Deployers must use the system in accordance with the IFU (Article 26(1)). Deviations may trigger Article 25 promotion if they amount to a substantial modification.

What to do

• Write the IFU as a deployer-facing document, not a marketing brochure.
• Include performance disaggregated by intended-population sub-groups (Article 13(3)(b) read with Article 15(3)).
• Version the IFU and notify deployers of material updates at least 14 days in advance.
• Reference the IFU by stable identifier in Annex IV §1.

Inline crosswalk

• ISO/IEC 42001:2023 Annex A.8.2 — Information for interested parties.
• NIST AI RMF MEASURE 2.9 — The AI model is explained, validated, and documented.

Common mistakes

• Marketing-prose IFU. Useless to deployers and to regulators.
• Missing sub-group performance.
• IFU version drift against the deployed system.

Penalties

Article 99(4) — up to €15 million or 3% of worldwide annual turnover.

---

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