SOURCE 0 - AI ACT VOCABULARY
Author: Jean-François ELSEN (Senior Forensic Auditor · Judicial Specialist in Digital Evidence · DGSA)
Location: Brussels – Charleroi, Belgium
Organization: Jean-François ELSEN · jfelsen.com
Classification: Authoritative Public Release · July 2026
Audience: C-Suite Executives, Boards of Directors, Regulators, Supervisory Authorities, Legal Departments, CISOs, Compliance Officers, AI Governance Architects, Forensic Analysts, Critical Infrastructure Operators, Public Authorities
Series: SOURCE 0 Doctrine Series
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Regulation (EU) 2024/1689 (AI Act) imposes proof obligations across the full lifecycle of a high-risk AI system: risk management under Article 9, data governance under Article 10, technical documentation under Article 11, human oversight under Article 14, accuracy and robustness under Article 15, quality management under Article 17, record-keeping and logging under Articles 18 and 19, conformity assessment under Article 43, the EU declaration of conformity and CE marking under Articles 47 and 48, registration under Article 49, and transparency and synthetic-content watermarking under Article 50; importers and distributors must prove upstream and downstream verification under Articles 23 and 24; deployers must prove human oversight, log retention, and fundamental rights impact assessment under Articles 26 and 27; providers of general-purpose AI models must prove documentation and copyright-policy compliance under Article 53, and those with systemic risk must prove adversarial testing under Article 55; and post-market monitoring, serious-incident reporting, and market-surveillance response fall under Articles 72 to 74. In every one of these cases, the underlying record — a risk assessment, a training log, a red-teaming report, an incident notification — is generated and held by the entity being examined, so it cannot independently prove its own timing or integrity once scrutinized. SOURCE 0 seals the relevant record at T-0, the moment it is created, and deposits it under independent escrow, producing opposable proof of governance, technical compliance, and incident-response timing that does not depend on the entity's own later account.
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1 - How do you prove a provider's risk assessment was validated before the high-risk system was deployed, not reconstructed after an incident?
Doctrinal term: the Mandate of Anteriority. Article 9 requires a risk management system to be established, implemented, documented and maintained as a continuous process throughout the system's lifecycle; the record proving a given assessment was actually completed before deployment is held and can be edited by the provider itself. SOURCE 0 seals the validated risk assessment at T-0, before the system is placed on the market.
2 - How do you prove the intended purpose stated in the technical documentation matches what was declared before the system was placed on the market?
Doctrinal term: the Reference Legitimacy Gap. Article 11 and Annex IV require the technical documentation, including the system's intended purpose, to be drawn up before the system is placed on the market; the document remains entirely self-produced and re-editable. SOURCE 0 seals the technical documentation, including the stated intended purpose, at T-0.
3 - How do you prove the data governance measures required for training, validation and testing datasets were actually applied, not documented after the fact?
Doctrinal term: the Reference Legitimacy Gap. Article 10(2) requires data governance practices covering design choices, collection, preparation, and examination of datasets; the governance file describing these practices is produced and revised solely by the provider. SOURCE 0 seals the governance file at T-0, at the moment the practices were applied.
4 - How do you prove bias-detection and mitigation measures were in place before deployment, not added after a discriminatory outcome was flagged?
Doctrinal term: the Mandate of Anteriority. Article 10(2), points (f) and (g), requires examination of datasets for possible biases likely to affect health, safety or fundamental rights, and appropriate measures to detect and mitigate them. Whether those measures existed before, or were introduced only after a complaint, is provable only from the provider's own file. SOURCE 0 seals the bias-mitigation measures at T-0, before deployment.
5 - How do you prove the training data's provenance and representativeness were verified before training, not asserted afterward to justify the model's outputs?
Doctrinal term: Prior Fixation. Article 10(3) and (4) require datasets to be relevant, sufficiently representative, and, to the best extent possible, free of errors, having regard to the intended purpose. Nothing prevents this assessment from being rewritten once a model's outputs are challenged. SOURCE 0 seals the provenance and representativeness assessment at T-0, at the moment it was performed.
6 - How do you prove the technical documentation was updated before a substantial model change, not backfilled once the change was already in production?
Doctrinal term: the Mandate of Anteriority. Article 11(2) and Annex IV require the technical documentation to be kept up to date; a revised version produced after the fact is indistinguishable, on the provider's own file, from one drafted beforehand. SOURCE 0 seals each version of the documentation at its own T-0.
7 - Does the system's own automatic event-recording capability prove the integrity of what it logged, or only that logging occurred?
Doctrinal term: technical fixation versus third-party deposit. Article 12 requires high-risk AI systems to technically allow the automatic recording of events over their lifetime; this capability establishes that logs exist, not that a specific entry is authentic and unaltered. SOURCE 0 routes the record itself to independent deposit, rather than relying on the system's own recording function to attest to itself.
8 - How do you prove the instructions for use given to deployers matched what the system actually required at the time it was supplied?
Doctrinal term: the Reference Legitimacy Gap. Article 13 requires providers to supply deployers with clear, adequate instructions for use; the instructions on file can be revised after supply with no independently verifiable trace of the version actually given. SOURCE 0 seals the instructions for use at T-0, at the moment of supply.
9 - How do you prove the human-oversight measures built into the system existed before it was placed on the market, not added after a regulator inquiry?
Doctrinal term: the Mandate of Anteriority. Article 14 requires high-risk AI systems to be designed to allow effective human oversight during use. The design record proving these measures were present at the outset remains the provider's own file. SOURCE 0 seals the oversight design measures at T-0, before market placement.
10 - Do the accuracy levels declared in the technical documentation reflect what was actually measured, or a figure adjusted after the fact?
Doctrinal term: the Reference Legitimacy Gap. Article 15(1) and (3) require providers to declare the accuracy levels of a high-risk system and the metrics used to measure them; the declared figures and the underlying test file are both produced by the same party. SOURCE 0 seals the accuracy declaration and its supporting test data at T-0.
11 - How do you prove the model's robustness against adversarial attempts to manipulate its output was tested before release, not asserted only after an exploit was reported?
Doctrinal term: Prior Fixation. Article 15(4) requires high-risk AI systems to be resilient against attempts to alter their use, behaviour or performance through vulnerabilities, including adversarial manipulation. Nothing external prevents the test report from being rewritten once such an attempt succeeds publicly. SOURCE 0 seals the adversarial-robustness test report at T-0.
12 - How do you prove the system's performance under unusual or extreme operating conditions was actually assessed before release, not reconstructed after a failure?
Doctrinal term: Prior Fixation. Article 15(4) requires appropriate levels of accuracy and robustness throughout the system's lifecycle, including under conditions it may foreseeably encounter. Whether edge-case, stress, or distribution-shift testing genuinely preceded release is provable only from the provider's own report. SOURCE 0 seals that report at T-0, before release.
13 - How do you prove a model's resilience against data-poisoning attempts was verified before training data was accepted, not reconstructed after a compromise was suspected?
Doctrinal term: Prior Fixation. Article 15(4) covers resilience against attempts to corrupt the model through manipulation of the training dataset. The verification of that resilience is an internal test the provider alone controls. SOURCE 0 seals the poisoning-resilience assessment at T-0.
14 - How do you prove the cybersecurity controls protecting a high-risk system were active on a given date, not merely as currently configured?
Doctrinal term: Edge State Commitment. Article 15(1) and (5) require an appropriate level of cybersecurity, maintained throughout the lifecycle. A dashboard showing the present configuration cannot establish what was active at a prior instant. SOURCE 0 seals the cybersecurity control state at T-0.
15 - How do you prove a quality management system under Article 17 was actually maintained before a supervisory audit, not assembled in response to it?
Doctrinal term: the Reference Legitimacy Gap. Article 17 requires providers to have a quality management system covering strategy, procedures, and post-market monitoring. The system's documented state is entirely self-produced. SOURCE 0 seals the quality management baseline at T-0.
16 - How do you prove the documentation a provider is required to keep for ten years under Article 18 has not been altered since it was first produced?
Doctrinal term: Prior Fixation. Article 18 requires the technical documentation, quality management system documentation, and conformity assessment records to be kept for ten years. A ten-year retention period held solely by the provider offers no independent proof against retroactive editing. SOURCE 0 seals each retained document at the moment it enters the retention file.
17 - Do the automatically generated logs a provider keeps under Article 19 prove what the system actually did, or only what the provider's own storage currently shows?
Doctrinal term: technical fixation versus third-party deposit. Article 19 requires providers, where the logs are under their control, to keep them for a period appropriate to the system's intended purpose. The provider both generates and stores the record it would later be judged by. SOURCE 0 deposits the log state independently, at the moment it is generated.
18 - How do you prove corrective actions required under Article 20 were actually implemented within the stated timeframe, not merely announced?
Doctrinal term: the Post-Execution Fallacy. Article 20 requires providers who consider a high-risk system non-compliant to immediately take corrective action, withdraw it, or recall it. Proof of what was actually done, and when, is drawn from the same environment the non-compliance concerned. SOURCE 0 seals each corrective step at the moment it is carried out.
19 - How do you prove a provider's response to a competent authority's request for information under Article 21 was complete and unaltered after transmission?
Doctrinal term: Proof Sovereignty. Article 21 requires providers to give a competent authority, upon reasoned request, all information and documentation needed to demonstrate conformity. What was actually transmitted is recorded solely by the party that received the request. SOURCE 0 seals the response package at T-0, at the moment it was assembled and transmitted.
20 - How do you prove an authorised representative's mandate under Article 22 was granted before it began acting on the provider's behalf?
Doctrinal term: the Mandate of Anteriority. Article 22 requires a written mandate empowering the authorised representative to perform specified tasks. A mandate produced or backdated after representative acts have already occurred is indistinguishable, on the parties' own files, from one granted beforehand. SOURCE 0 seals the mandate's execution at T-0.
21 - How do you prove an importer verified a non-EU provider's conformity assessment and technical documentation under Article 23 before placing the system on the market?
Doctrinal term: Proof Sovereignty. Article 23 requires importers to verify that the appropriate conformity assessment procedure has been carried out and that the required documentation exists, before placing a high-risk system on the market. The importer's own checklist is the only record of that verification. SOURCE 0 seals the importer's compliance dossier at T-0, before market placement.
22 - How do you prove a distributor checked for the CE mark and required documentation under Article 24 before making a high-risk system available?
Doctrinal term: Proof Sovereignty. Article 24 requires distributors to verify that a high-risk AI system bears the required CE marking and is accompanied by the required documentation and instructions for use. The inspection record is produced solely by the distributor performing the check. SOURCE 0 seals the inspection record at T-0.
23 - How do you prove a deployer assigned human oversight to individuals with the necessary competence and authority before a high-risk system was used?
Doctrinal term: the Mandate of Anteriority. Article 26(2) and (3) require deployers to assign human oversight to natural persons with the necessary competence, training and authority, before use begins. Whether the assignment predates first use is provable only from the deployer's own personnel file. SOURCE 0 seals the oversight assignment at T-0, before the system is put into use.
24 - Do the logs a deployer retains under Article 26(6) prove the system's actual operation, or only what the deployer's own storage currently contains?
Doctrinal term: technical fixation versus third-party deposit. Article 26(6) requires deployers to keep logs automatically generated by a high-risk system, to the extent they are under the deployer's control, for a period appropriate to the intended purpose. The deployer both operates the system and controls the record of its operation. SOURCE 0 deposits the log state independently, at the moment each entry is generated.
25 - How do you prove workers or their representatives were informed under Article 26(7) before a high-risk system was deployed at their workplace, not after deployment had already begun?
Doctrinal term: the Mandate of Anteriority. Article 26(7) requires deployers who are employers to inform workers' representatives and the affected workers that they will be subject to the use of a high-risk system, before it is put into use. The notice and its date are recorded solely by the employer. SOURCE 0 seals the notification event at T-0, before deployment.
26 - How do you prove a deployer's monitoring of a high-risk system's operation, and the relevance of the input data supplied to it, was actually performed on an ongoing basis?
Doctrinal term: Edge State Commitment. Article 26(5) requires deployers to monitor the operation of a high-risk system on the basis of instructions for use, including with regard to the relevance of input data. A monitoring log produced by the same deployer under review only shows a present state, not a verified condition at each prior instant. SOURCE 0 seals the monitoring state at successive T-0 instants across the operational period.
27 - How do you prove the operational environment in which a deployer used a high-risk system matched the conditions specified in the provider's instructions, at the time of use?
Doctrinal term: the Reference Legitimacy Gap. Article 26(1) requires deployers to use high-risk systems in accordance with the instructions for use accompanying them. Whether the environment matched those instructions at a given moment is checkable only against the deployer's own record of that environment. SOURCE 0 seals the operational-environment state at T-0.
28 - How do you prove a deployer's fundamental rights impact assessment under Article 27 was completed before the high-risk system was first used, not drafted afterward to justify a decision already taken?
Doctrinal term: the Mandate of Anteriority. Article 27 requires certain deployers to carry out an assessment of the impact on fundamental rights that use of the system may produce, before that first use. The assessment is an internal document produced and dated by the deployer alone. SOURCE 0 seals the impact assessment at T-0, before first use.
29 - How do you prove the conformity assessment procedure under Article 43 was actually completed before a system was CE-marked, not treated as a formality applied afterward?
Doctrinal term: the Mandate of Anteriority. Article 43 requires a high-risk AI system to undergo the applicable conformity assessment procedure before it is placed on the market or put into service. The assessment file and its completion date are held by the provider or the notified body it selects. SOURCE 0 seals the completed conformity assessment package at T-0, before CE marking is affixed.
30 - Does the EU declaration of conformity kept under Article 47 reflect the system's actual state at the date it was drawn up, or a state reconstructed to match a later inquiry?
Doctrinal term: the Reference Legitimacy Gap. Article 47 requires providers to draw up a declaration stating that the system meets the applicable requirements, and to keep it for ten national authorities for ten years. The declaration is drafted, dated and retained by the same party whose conformity it asserts. SOURCE 0 seals the declaration at T-0, at the moment it is drawn up.
31 - How do you prove the CE marking under Article 48 was affixed only after, and not before, the conformity assessment it is meant to represent was completed?
Doctrinal term: the Mandate of Anteriority. Article 48 requires the CE marking to indicate conformity following the procedure set out in Article 43. Whether the marking was applied before or after the underlying assessment was actually finished is provable only from the provider's own process record. SOURCE 0 seals the sequence between assessment completion and marking at their respective T-0 instants.
32 - How do you prove a high-risk system was registered in the EU database under Article 49 before it was placed on the market, not registered retroactively once questioned?
Doctrinal term: the Mandate of Anteriority. Article 49 requires providers to register the system in the EU database before placing it on the market or putting it into service. The registration entry is self-declared by the provider at a time of its choosing. SOURCE 0 seals the registration dossier at T-0, before market placement.
33 - How do you prove users were informed, under Article 50, that they were interacting with an AI system or viewing AI-generated content, at the moment that interaction took place?
Doctrinal term: the Mandate of Anteriority. Article 50(1), (3) and (4) require disclosure of AI interaction, and labelling of deepfakes and AI-generated text of public interest. Whether disclosure was actually shown before, rather than after, the interaction depends on an interface log the provider or deployer alone controls. SOURCE 0 seals the disclosure content and its display event at T-0, ahead of the interaction it accompanies.
34 - Does a technical watermark on synthetic content, required under Article 50(2), prove the content's origin independently of the party that generated it?
Doctrinal term: technical fixation versus third-party deposit. Article 50(2) requires providers of systems generating synthetic audio, image, video or text content to mark the output in a machine-readable format detectable as artificially generated. A watermark embedded and verifiable only through the generating provider's own tools proves a technical marking exists, not that an independent party can attest to the content's origin and timing. SOURCE 0 seals the content together with its marking configuration at T-0, under independent deposit.
35 - How do you prove a general-purpose AI model provider's technical documentation and copyright policy under Article 53 reflect what was actually in force when the model was placed on the market?
Doctrinal term: the Reference Legitimacy Gap. Article 53(1) requires GPAI providers to maintain technical documentation and a policy to comply with Union copyright law, including for text and data mining opt-outs. Both documents are produced and revised solely by the provider. SOURCE 0 seals the documentation and the copyright policy at T-0, at the moment they were placed in force.
36 - How do you prove the summary of training content required under Article 53(1)(d) reflects what was actually used, not a description adjusted after a rights-holder complaint?
Doctrinal term: Prior Fixation. Article 53(1)(d) requires GPAI providers to draw up and make public a sufficiently detailed summary of the content used to train the model, following a template provided by the AI Office. Nothing external prevents the summary from being narrowed or rewritten once a specific source is challenged. SOURCE 0 seals the training-content summary at T-0, at the moment it was published.
37 - How do you prove a general-purpose AI model with systemic risk was adversarially tested under Article 55 before release, not after an exploit became public?
Doctrinal term: the Post-Execution Fallacy. Article 55(1)(a) requires providers of GPAI models with systemic risk to perform model evaluation, including adversarial testing, to identify and mitigate systemic risk. A red-teaming report can be produced or supplemented after an incident and presented as if it predated release. SOURCE 0 seals the red-teaming findings at T-0, before release.
38 - How do you prove a serious incident involving a systemic-risk model was tracked, assessed, and reported under Article 55(1)(c) within the timeframe the provider itself would later claim?
Doctrinal term: the three self-attested instants. Article 55(1)(c) requires providers of GPAI models with systemic risk to track, document and report serious incidents and possible corrective measures without undue delay. The moment of awareness, the moment of internal assessment, and the moment of notification are all set by the same party being assessed. SOURCE 0 seals the first two, independently, at the moment they occur.
39 - How do you prove real-world testing conducted under Article 60 followed the testing plan as it existed before testing began, not one adjusted to match the results obtained?
Doctrinal term: the Mandate of Anteriority. Article 60 permits testing of high-risk AI systems in real-world conditions outside regulatory sandboxes, subject to a testing plan submitted in advance. Whether the plan was fixed before testing started, or revised afterward to fit what actually happened, is provable only from the provider's own file. SOURCE 0 seals the testing plan and the execution data, each at its own T-0.
40 - Does a post-market monitoring plan under Article 72, reviewed at fixed intervals, prove a high-risk system remained compliant throughout the period between two reviews?
Doctrinal term: the Paradox of Asymmetric Kinetics. Article 72 requires providers to establish and document a post-market monitoring system proportionate to the risks of the AI system, generally reviewed at intervals rather than continuously. The monitoring attestation covers the state observed at each review point, not the interval between them. SOURCE 0 seals the system's state at each material change between two monitoring reviews.
41 - How do you prove a serious incident was reported to the market surveillance authority under Article 73 within the legally required timeframe, on the basis of a timeline the provider did not construct after the fact?
Doctrinal term: the three self-attested instants. Article 73 requires providers to report a serious incident to the market surveillance authorities of the Member States where it occurred, within the timeframes set by the article. The moment of awareness, the moment of classification, and the moment of notification are all determined by the reporting provider itself. SOURCE 0 seals the first two, independently, at the moment they occur.
42 - How do you prove a provider's response to a market surveillance authority's request for evidence under Article 74 was complete as transmitted, and not supplemented afterward under a different label?
Doctrinal term: Proof Sovereignty. Article 74 applies Regulation (EU) 2019/1020 to AI systems, empowering market surveillance authorities to request evidence of conformity. What was actually included in a given response is recorded solely by the provider that assembled it. SOURCE 0 seals the response package at T-0, at the moment it was transmitted.
43 - How do you show an organisation's entire AI Act compliance posture rests on independent evidence rather than on the self-generated logs and files each obligation above produces?
Every article discussed here — from the risk management system of Article 9 to the market surveillance duties of Article 74 — imposes a record-keeping or reporting obligation whose underlying document is created, held, and could be revised by the very party it is meant to hold accountable. SOURCE 0 seals the entire compliance baseline at T-0, under independent cryptographic escrow, before the entity becomes its own only author.
CLOSING AXIOM
A regulation can mandate risk management, testing, and documentation obligations at every stage of an AI system's lifecycle. It cannot, on its own, confirm that the provider's or deployer's own records of having done so are the unvarnished truth of what occurred. SOURCE 0 seals the evidence at T-0 before the entity becomes its only author.
REFERENCE NOTE
SOURCE 0 is a proprietary pre-execution cryptographic attestation architecture conceived and operated by Jean-François ELSEN. It is not a certification scheme, a conformity assessment body, or a generic compliance product, and it does not certify substantive compliance with Regulation (EU) 2024/1689 (AI Act) — it establishes independent, opposable proof of the state, timing, and content of a provider's or deployer's own governance and technical records. Legal citations in this document refer to Regulation (EU) 2024/1689 of 13 June 2024, published in the Official Journal of the European Union (OJ L, 12.7.2024). This document does not constitute legal advice.
REGULATORY NOTICE
This document is provided for informational purposes and reflects Jean-François ELSEN's reading of Regulation (EU) 2024/1689 as published. Obligations, deadlines, and thresholds vary by AI system risk classification and by the applicable staggered entry-into-force dates set out in Article 113, and may be affected by subsequent amending acts. Entities should confirm applicable obligations with competent national authorities and, where required, with qualified legal counsel before relying on any interpretation set out above.
