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Article 10: data and data governance

Quality and governance requirements for training, validation and test data of high-risk AI.

The official source remains authoritative. This general interpretation is not legal advice.

Status
Upcoming
Application date
2 December 2027
Version
1.0.0
Last reviewed
8 August 2026

Who this is relevant to

When this applies

  • Deployer

    An organisation using an AI system under its authority, excluding personal non-professional use.

  • Provider of an AI system

    A party that develops or has an AI system developed and places it on the market under its own name.

  1. 1The high-risk system is trained with data; the provider composes the datasets, the deployer controls relevant input data.

What the official source establishes

Article 10 requires datasets appropriate to the intended purpose, with governance over origin and composition, attention to representativeness, errors and completeness, and examination of possible bias with appropriate measures.

For the Annex III route this requirement applies from 2 December 2027; for high-risk AI in regulated products (Annex I) from 2 August 2028.

Our interpretation

Today’s dataset choices determine whether compliance is feasible later: data bought or collected today without provenance records cannot be repaired in 2027.

What you can do now

Record origin and assumptions per dataset and include data quality as a requirement in every AI or data procurement contract.

  1. 01

    Set up data governance per dataset

    Assess origin, representativeness, errors and completeness and examine possible bias with appropriate mitigation.

What to retain

Data governance file

Record per dataset of origin, choices, assumptions, bias examination and mitigations.

Control and reassessment

  • Data check before retraining

    Repeat the data quality assessment before every retraining or dataset change.

Public tools

Conditions and exceptions

  • For special categories of personal data the strict exception of Article 10(5) applies (bias detection and correction under conditions).

Official sources and locators

  • EU Artificial Intelligence Act 2024/1689

    European Parliament and Council | original-oj-2024-07-12

    Source locator: Article 10(1)-(6)

  • Digital Omnibus on AI 2026/1744

    European Parliament and Council | official-journal-2026-07-24

    Source locator: Amended Article 113 application dates

Version history

  1. v1.0.0

    27 July 2026

    Article 10: data and data governance

    Quality and governance requirements for training, validation and test data of high-risk AI.

Execution

From obligation to arranged and demonstrable

Knowing where you stand is step one. Embed AI translates this obligation into a concrete approach for your organisation: scope, ownership, register and evidence.

See the Embed AI approach

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