ChoreographWhat the Act requires. What Choreograph does for you. What stays yours.
Whether a given deployment is high‑risk at all is a legal determination under Annex III or Annex I: an accounts‑payable workflow at a café is not; credit decisions, insurance pricing of natural persons, HR screening and medical‑device‑adjacent uses are.
Covered structural in Choreograph Enabled we supply the evidence; you own the document or process Gap outside Choreograph: another tool, the model provider, or counsel
Base mapping rev 2, September 2026, validated with counsel. Evaluation-gate wording added for round 3; architect review pending. This is not legal advice. Obligations vary by role and category; validate with counsel.
What Choreograph covers.
| Article | Obligation | Status | How |
|---|---|---|---|
| Art. 12 | Record‑keeping: automatic, tamper‑resistant logging over the system’s lifetime; traceable; accessible to authorities. | Covered | Append‑only hash chain with database‑trigger immutability; byte‑exact turn transcripts; refusals audited too; replay verification; evidence bundles an authority re‑runs. Retention (six months minimum, Arts. 19 and 26) is an operator setting Choreograph makes structural, not optional. |
| Art. 14 | Human oversight: designed for effective oversight; humans can understand, monitor, decide not to use, override, intervene, stop. | Covered | Humans as first‑class actors (same Gate, same leases); review gates that physically withhold effects; request, await and escalation; per‑edge human‑only authority; no admin bypass; park and kill terminal classes. Stopping today is per task (park, kill) and per effect channel: the effects gate can be closed by an operator, which withholds every payout. A one‑command tenant‑wide stop is on the roadmap. |
| Art. 15 | Robustness and cybersecurity, system level: resilience to errors and faults; fail‑safe; protection against manipulation of inputs and outputs, poisoning, adversarial attacks. | Covered | Fail‑closed guards; idempotent post‑commit effects; crash‑exactly‑once; restore‑safety gate; prompt‑injection confinement on the live tool loop; per‑edge tool scope; tenant isolation; the knowledge ingestion gate (hostile documents cannot write themselves into memory). Model‑level robustness is a gap, below. |
| Art. 26 (5–6) | Deployer duties: keep logs at least six months; assign oversight to competent persons with authority. | Covered / Enabled | Retention is structural; oversight assignment is expressed as actor authority per edge. The competence and training of those persons is your process. |
What Choreograph enables.
| Article | Obligation | Status | What we give · what you add |
|---|---|---|---|
| Art. 15 (1–3) | Accuracy: declared levels and metrics; consistent performance. | Enabled | Choreograph does not measure a model’s accuracy; it makes an unmeasured or under-performing model unable to act. Evaluation results from your framework (PyEvals or another) are recorded as commits with the model and version, and a guard can refuse dispatch, or halt the workflow, when the pinned evaluation falls below the level you set. You add the evaluation suite and the threshold. |
| Art. 9 | Risk management system: continuous, iterative identification, estimation, evaluation, mitigation, testing. | Enabled | Counterfactual fork (replay under a stricter policy names what would now be refused) as a risk‑testing instrument; score and telemetry as indicators. You add the process and the risk register: a governance platform or documented procedures. |
| Art. 11 | Technical documentation (Annex IV): system description, design, development process, monitoring, changes. | Enabled | The typed declaration is the core of the system description; versions, hashes, validation results, CI gates and the test suite are the development record. You add the authored technical file and the model provider’s documentation. |
| Art. 13 | Transparency and instructions for use for deployers. | Enabled | Declared authority, tool scope and review gates per edge are the oversight‑measure description. You add the instructions‑for‑use document and the model provider’s capability and limitation statements. |
| Art. 17 | Quality management system: documented policies and procedures. | Enabled → Gap | CI gates, census‑gated migrations, conformance bench and test suite are evidence a QMS cites. The QMS itself (ISO 42001‑style) is a management system, not software we ship. |
| Art. 72 | Post‑market monitoring plan and system. | Enabled | OpenTelemetry metrics (queue depth, staleness, rejections), score, chain analytics in plain SQL. You add the monitoring plan and review cadence. |
| Art. 73 | Serious‑incident reporting within statutory deadlines. | Enabled | The evidence bundle is the incident package, sealed and re‑runnable. You add the detect, classify, report workflow and the submission. |
| Art. 25 (4) | Component‑supplier cooperation: information, access and cooperation for the provider’s compliance, by written agreement. | Enabled | Choreograph’s legal role in a high‑risk deployment is component supplier. Auto‑derivable component documentation and a standard cooperation agreement are on the roadmap. |
| Art. 86 | Right to explanation: an affected person may obtain a clear explanation of the AI system’s role in the decision. | Covered in substance | Chain, byte‑exact turn provenance, guards and reviewers reconstruct any decision’s role. A per‑commit explanation primitive is on the roadmap. |
| Arts. 43, 47–49 | Conformity assessment, declaration of conformity, CE marking, EU database registration. | Gap (process) | We give evidence. The assessment and filings are counsel’s, possibly a notified body’s. |
| Art. 27 | Fundamental‑rights impact assessment for public bodies and certain private deployers. | Gap (process) | Template, tool and counsel. The declaration and oversight design are inputs to it. |
| Art. 50 | Transparency to natural persons; labelling synthetic content. | Gap (UX) | If agents email vendors or customers externally, disclosure is a UX and process obligation, not one Choreograph can fulfil. |
What Choreograph cannot cover.
| Article | Obligation | Status | What fills it |
|---|---|---|---|
| Art. 10 | Data and data governance: training, validation and test data quality, relevance, bias examination. | Gap · model provider | Entirely about the model’s training data. With your own key you inherit this from the provider: their general‑purpose model documentation, plus your own use‑case data checks. |
| Art. 15 | Robustness, model level: adversarial robustness of the model itself, model poisoning. | Gap · provider and evaluations | Choreograph confines consequences (an injection cannot reach an effect); it cannot make the model itself robust. Provider documentation and red‑team evaluations fill it. |
| Chapter V | General‑purpose AI model obligations. | Dependency | Collect and file the provider’s documentation as part of the technical file. |
For high‑risk positioning the model is not a gap so much as a recorded dependency: pin the provider’s model card and your evaluation results as content‑hashed reference data, record model and version in every turn, and the technical file’s model section becomes provable. Choreograph still does not perform evaluations; it makes their absence impossible to hide.
We don’t make you compliant. We make compliance provable.
Choreograph makes the two hardest runtime articles structural, Art. 12 logging and Art. 14 human oversight, plus the system‑level half of Art. 15. These are the ones that cannot be retrofitted onto an agent framework after the fact, and the ones a market‑surveillance authority inspects first.
For the documentary and process articles (9, 11, 13, 17, 72, 73, 43) we are the evidence engine, not the management system. Pair us with a governance platform and counsel. For the model articles, Choreograph records what your evaluations establish and refuses to run a model that has not met your bar. You still supply provider documentation and evaluation tooling.
Adjacent regimes: DORA (the evidence bundle supports contractual audit rights), GDPR Art. 22 (the review gate is a designed human‑intervention point), NIS2 where applicable. GDPR Art. 17 erasure against an immutable chain is an open design question we answer before any HR, credit or insurance deployment.