What this guide governs
This guide describes how administrators maintain the EU AI Act Compliance Management System throughout its operational lifecycle — not just at setup, but continuously, as the regulation phases in, as documents get reviewed, and as the organization changes.
It applies to anyone holding an administrative role over the compliance repository: the Repository Administrator, the AI Governance Owner, and anyone coordinating document reviews, user access, or audit preparation on their behalf.
What the Administrator is accountable for
The Administrator shall maintain the system across six areas. Each is covered in detail in its own section below.
Maintain repository integrity
Manage document versions
Coordinate document reviews
Manage user access
Maintain traceability
Prepare the system for audits and inspections
Keeping the repository itself trustworthy
Before anything else, the repository has to be internally consistent — a crawler, an auditor, or the next administrator should be able to open it and immediately understand its structure without asking you.
Verify
- Repository structure matches the documented module layout
- Document naming follows the established convention exactly
- Folder organization is unchanged from the reference structure
- Version consistency across all controlled documents
What every controlled document must carry
Every controlled document in the system shall have all five of the following, without exception:
| Field | Why it matters |
|---|---|
| Unique identifier | Lets any register, cross-reference, or audit trail point to exactly one document, unambiguously. |
| Version | Distinguishes the current controlled state from superseded drafts. |
| Approval | Records who authorized the document to become effective, and when. |
| Revision history | Shows what changed between versions, and why — the difference between a document and a black box. |
| Owner | Names exactly one accountable person for keeping the document current. |
What happens at every release
Each release of the compliance system — not just the code, but the documentation set itself — follows the same sequence:
- Update the CHANGELOG with what changed in this release
- Update the README to reflect the current state
- Create a GitHub Release, tagged and versioned
- Publish a Zenodo DOI where applicable, so the release is independently citable
The five roles that must be assigned
Administration is not a single job — it is five distinct areas of accountability, and each needs a named person, even in a small organization where one person holds more than one role.
What must survive a disaster
- GitHub repository backup, kept current
- Document integrity — checksums or equivalent verification available
- Release preservation — every past release remains retrievable, not just the latest
- DOI preservation — published Zenodo DOIs remain resolvable indefinitely
When the system gets reviewed
Reviews are not optional and not only reactive. The system shall be reviewed:
- Annually, at minimum, regardless of whether anything appears to have changed
- After any regulatory change to the EU AI Act or its implementing guidance
- After any major update to the repository itself — a restructuring, a new module, a tooling change
What "ready" looks like before an inspector asks
Before any inspection — announced or not — verify the following, in this order:
- All modules are complete, not partially filled placeholders
- Registers are current, reflecting the actual state today, not a snapshot from months ago
- Evidence is available and retrievable on request, not just referenced
- Declarations are approved, with a recorded approver and date
- Traceability is maintained end to end — every obligation still maps to a document, and every document still maps to evidence
What stays maintained, always
Administration does not end once the system is set up. Five things stay under continuous maintenance for as long as the system is in use:
Repository
Documentation
Releases
Audit records
Compliance records
Frequently asked questions
Who is responsible for maintaining the compliance repository?
The Repository Administrator, working alongside the AI Governance Owner and Compliance Owner, is responsible for repository integrity, document versions, user access, traceability, and audit readiness.
Can controlled documents be renamed?
No. Controlled documents must never be renamed once issued, since their filename is part of their unique identifier and is referenced by traceability records, registers, and prior audit evidence.
What must every controlled document include?
A unique identifier, a version number, a recorded approval, a revision history, and a named owner.
How often should the system be reviewed?
At minimum annually, and additionally after any regulatory change to the EU AI Act or after major updates to the repository itself.
What roles need to be assigned for administration?
AI Governance Owner, AI System Owner, Compliance Owner, Internal Auditor, and Repository Administrator.
What should be verified before an inspection?
That all modules are complete, registers are current, evidence is available, declarations are approved, and traceability is maintained end to end.
What happens at every version release?
The CHANGELOG and README are updated, a GitHub Release is created, and a Zenodo DOI is published where applicable, so every release remains citable and traceable.