European Observatory on AI Standards
European Observatory on AI Standards emblem

Reading the AI Act's harmonised standards, clause by clause.

The EU AI Act writes its safety commitments as essential requirements. Harmonised standards turn them into things a person can check. That conversion is where the substance is decided — and it happens in rooms most people never see into.

The Observatory reads the drafts of the M/613 standards against the Regulation itself, in the open, while the enquiry windows are still open to comment.

What this is

An independent line of sight into European AI standardisation.

Compliance with the AI Act's requirements for high-risk systems runs, in practice, through a small set of technical standards drafted by CEN and CENELEC's Joint Technical Committee 21. Follow one, once its reference is cited in the Official Journal, and you are presumed to conform. The standards are therefore load-bearing law in the shape of voluntary technical documents — and they are being written now.

The Observatory tracks that drafting as it happens. Each brief takes a single requirement, or a single mechanism, and follows it from the words of the Regulation into the clause of the standard that is meant to make it checkable, showing what narrows, what gets reassigned, and who ends up holding the threshold. The work is free to read and exists as public evidence of competence, not as a sales channel.

The Observatory is independent. Its analysis is its own and does not represent the position of CEN, CENELEC, any national standards body, or the European Commission. The standards it discusses are drafts at working, enquiry or final-approval stage; clause numbers and definitions change between revisions and are treated as provisional.

The publication

Trustworthiness in Translation

Twenty-one briefs · publishing in waves

Twenty-one briefs on the drafting of the M/613 harmonised standards and the law they run on. The first, the Series Preface, is live now; the rest publish in waves as the drafts move through enquiry.

Series Preface: What Standards Do to IdeasArt. 40; Reg. 1025/2012; Blue Guide §1, §4
Live
Voluntary by DesignReg. (EU) 1025/2012, Arts. 2(1)(c), 3(6), 5, 10, 11, 22
Soon
The Text That Came BackReg. (EU) 2026/1744; consolidated 02024R1689; Arts. 4a, 6(1a)–(1c)
Soon
The Inspector Reads the Same StandardArts. 74–85; Reg. 2019/1020; Art. 99
Soon
The Measurement Nobody OwnsArt. 15(2)–(3); Reg. 765/2008; ISO/IEC 4213; ISO/IEC 17025
Soon
Conformity by Reference to Documents That Do Not ExistArt. 40, 41, 43(1)(d); HAS assessment outcomes
Soon
Two Meanings of RobustnessArt. 15(1), 15(4); Recital 75
Soon
The Second RequestArt. 40(2), 53–55, Annex XI; C(2025) 3871
Soon
Representative of What?Art. 10(3) vs 10(2)(f)–(g)
Soon
Fairness Becomes an Acceptance CriterionArt. 10(2)(f)–(g); Art. 9(5); Art. 4a
Soon
Human Oversight Is a Latency BudgetArt. 14(1)–(4)
Soon
The Loop, the Update, and the AgentArt. 15(4); Art. 3(23); Art. 25; Art. 96(1)(c)
Soon
The System That Changes After the ExamArt. 3(23); Art. 43(1)(d), 43(4); Blue Guide 3-point test
Soon
The Provider Writes the ExamArt. 3(12), 3(13); Art. 6(3); Art. 25; Art. 80
Soon
Words That Look AlikeArt. 3(20)–(22), 40, 43, 47–48; ISO/IEC 17000, 17029
Soon
Compliance Is a Property of Your OrganisationArt. 17; Art. 43(2); Annex VI; Module A
Soon
No Safety Property Is Self-JustifyingArt. 8(1); Art. 9(5)(a)
Soon
The HandoffArt. 14(3)(b); Art. 9(5); Art. 26
Soon
The Same Input, Two RegulationsArt. 15(4) vs 15(5); Recitals 75, 76
Soon
The Act's Answer to the Black Box Is LoggingArt. 12; Art. 19; Art. 26(6); Art. 72
Soon
Transparency Is a DocumentArt. 13 vs Art. 86
Soon
What the CE Mark Actually PromisesArt. 40; Art. 47–48; Art. 82
Soon

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New briefs as they publish.

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Entities and collaborators

The people and organisations behind the Observatory.