Article 13 is the most consistently overlooked document in the EU AI Act compliance pack. Providers focused on the Article 11 Technical Documentation and Article 47 Declaration of Conformity often treat the Instructions for Use as an afterthought — a brief user manual rather than a legally mandated document with seven specific subsections.
That is a mistake. The Instructions for Use are a distinct legal obligation under Article 13 of Regulation (EU) 2024/1689, required to accompany every high-risk AI system placed on the market. They are not the same as the Technical Documentation — they serve a different purpose, are written for a different audience, and have their own mandatory content requirements.
Provider vs Deployer: If you built the AI system, you are the Provider and must produce the Instructions for Use. If you purchased or licensed a third-party AI system and use it in your business, you are the Deployer and should be receiving this document from your supplier. If your supplier cannot produce Article 13 Instructions for Use, that is a compliance red flag.
Article 13(1) states that high-risk AI systems shall be accompanied by instructions for use in an appropriate digital format — or, exceptionally, in non-digital format — that include concise, complete, correct, and clear information that is relevant to the deployment and use of the AI system.
The key phrase is "relevant to the deployment and use." The Instructions for Use are written for deployers — the organisations and individuals who will actually operate the system — not for regulators. They must give deployers enough information to use the system safely, within its intended purpose, with appropriate human oversight in place.
Article 13(3) specifies the mandatory content in seven subsections, each covering a distinct aspect of the system's deployment context.
The Instructions for Use must identify the provider by full legal name and address, and provide a point of contact for technical queries. If the provider has an EU authorised representative under Article 22, that representative's details must also be included. This subsection establishes accountability — a deployer experiencing a system failure needs to know exactly who to contact.
This is the most substantive subsection. It must cover the intended purpose of the system; the level of accuracy, robustness, and cybersecurity the system has been designed to achieve; and the known and foreseeable circumstances that may impact the system's performance. Critically, it must describe the performance metrics used and their values — not vague statements like "high accuracy," but specific figures such as F1 score, precision, recall, and any fairness metrics relevant to the system's domain.
For systems that process data relating to specific groups — for example, hiring systems that assess candidates across demographic groups — the Instructions for Use must include disaggregated performance metrics showing how the system performs across those groups. This requirement flows from Article 13(3)(d) and is frequently missed.
Any pre-determined changes to the system that the provider has planned post-deployment must be disclosed in the Instructions for Use. This includes planned model updates, retraining schedules, and changes to the system's intended purpose. Deployers need this information to assess whether future changes will affect their own compliance obligations under Article 26.
Article 14 of the EU AI Act mandates human oversight for high-risk AI systems. The Instructions for Use must specify the human oversight measures that deployers are required to implement — including the technical measures built into the system to support oversight, and the organisational measures that deployers must put in place themselves.
This subsection must describe how the system can be paused, overridden, or shut down by a human operator, and what the qualifications or training requirements are for the natural persons responsible for oversight. A hiring system, for example, must specify that no adverse decision should be communicated to a candidate without a qualified HR manager reviewing the system's output.
The expected lifetime of the system and any necessary maintenance or care needed to ensure it continues to function as intended must be disclosed. This includes hardware requirements, software dependencies, update schedules, and any conditions under which the system's performance may degrade. Deployers running the system on infrastructure that does not meet the specified requirements are creating compliance risk for themselves.
Article 12 of the EU AI Act requires high-risk AI systems to have automatic event logging capabilities. The Instructions for Use must describe those logging capabilities and explain how deployers should maintain and preserve those logs. Under Article 26(6), deployers are responsible for retaining logs for the applicable retention period — typically three years, unless sector-specific legislation requires longer.
If the safe and correct use of the system requires the deployer to take specific pre-installation measures — such as configuring access controls, integrating the system with specific data sources, or applying specific security settings — these must be described in the Instructions for Use. This subsection acts as a deployment checklist that, if ignored, shifts some compliance liability back to the provider.
The Article 11 Technical Documentation and the Article 13 Instructions for Use are distinct documents serving distinct legal purposes. The Technical Documentation is written for regulators and notified bodies — it proves that the provider has met the obligations of the regulation. The Instructions for Use are written for deployers — they enable safe and compliant operation of the system.
A provider cannot submit the Technical Documentation to a deployer in place of the Instructions for Use. The two documents have different audiences, different content requirements, and different legal functions. Conflating them is a common compliance error.
Both documents are required. The full EU AI Act compliance pack for a high-risk AI system consists of three documents: the Article 11 Technical Documentation, the Article 13 Instructions for Use, and the Article 47 Declaration of Conformity. Producing only one or two of them is non-compliance.
Article 13(1) specifies that the Instructions for Use must be provided in a digital format appropriate for the system's deployment context. For cloud-based AI systems, this typically means a PDF document delivered to deployers at the time of licensing or procurement. For embedded systems, it may mean physical documentation accompanying the hardware.
The Instructions for Use must be in the official language of the member states in which the system is made available. For EU-wide deployment, this means maintaining translations into all relevant EU languages, or at minimum the languages of your primary markets.
The EU AI Act Compliance Pack Generator produces Article 13 Instructions for Use as the second document in the full three-document compliance pack, alongside the Article 11 Technical Documentation and Article 47 Declaration of Conformity. The document is generated from your system-specific inputs — intended purpose, performance metrics, human oversight mechanism, logging capabilities, and deployment requirements — and formatted as a professional PDF.
The complete pack is $197 one-time. No account, no subscription. Every generated section includes a review label reminding you to verify it with qualified legal counsel before delivery to deployers.
All 7 subsections of Article 13(3), bundled with Article 11 Technical Documentation and Article 47 Declaration of Conformity — $197 one-time.
Generate My Compliance Pack — $197 →One-time fee. No account. No subscription. Art. 11/13/47 deadline: December 2, 2027.
Deployers do not produce the Instructions for Use — that obligation rests with the provider. However, Article 26 requires deployers to use high-risk AI systems in accordance with the Instructions for Use. A deployer who ignores the human oversight requirements specified in the Instructions for Use is in breach of their own obligations under the regulation, regardless of the provider's compliance.
If your organisation built the AI system and also operates it internally — for example, an HR department using an in-house hiring tool — you are both the provider and the deployer. You must still produce the Instructions for Use as a formal document, even if the primary audience is your own staff. The document serves as evidence that the required oversight measures and operational constraints have been formally defined.
Yes — and they must be updated whenever material changes to the system affect its performance characteristics, human oversight requirements, or logging capabilities. Any pre-planned updates must be communicated to deployers as they occur. Deployers should be notified of updates that affect their obligations under Article 26.
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