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EU AI Act Art 47 — EU Declaration of Conformity

Annex V Template · 7 Mandatory Fields · Self-Assessment (Module A) + Notified-Body (Module C/H) Variants · SIGIL-Signed · EAT Directive aligned

EU AI ACT ART 47 ANNEX V DRAFT

Mandatory Fields

Variants

10y

Retention Period

EU Languages

1Hz

SIGIL Anchor

100%

Machine Readable

What is Article 47?

Article 47 of the EU AI Act requires that for each high-risk AI system, the provider draws up an EU Declaration of Conformity in accordance with Annex V before placing the system on the market or putting it into service. By drawing up the declaration, the provider declares that the high-risk AI system meets the requirements of the AI Act.

The Declaration of Conformity is the single document that translates the entire conformity-assessment procedure into a public, signed statement. It is the formal counterpart to the CE marking: CE marks the system physically, the Declaration declares the compliance in writing.

Format requirement: Per Art 47(3), the declaration must be drawn up in the official EU language(s) determined by the Member State in which the system is placed on the market. DEFONEOS provides a 23-language-ready template (English plus the 22 other EU official languages). The Declaration must be kept by the provider for 10 years after placement on the market (Art 47(4)).

The DEFONEOS EU Declaration of Conformity (Draft — Module A, Annex III Deployments)

EU DECLARATION OF CONFORMITY

In accordance with Regulation (EU) 2024/1689 of the European Parliament and of the Council (Artificial Intelligence Act), Article 47, and Annex V

1. AI System Identification

Trade name: DEFONEOS Sovereign Public Services OS
Type / model / version: DEFONEOS v[version] — [module name]
Intended purpose: Sovereign, audit-grade, signed, neutral AI OS for UK public services. Decision support across housing allocation, benefits assessment, child safeguarding triage, health prioritisation, and immigration casework.

2. Provider Name, Address and Registration Number

Name: CSOAI Ltd
Address: [Registered office — to be filled at incorporation finalisation]
Registration number: Companies House 16939677 (UK)
Authorised representative (Art 22 — where applicable): [name + address of EU-based AR]

3. Statement of Conformity

This declaration of conformity is issued under the sole responsibility of the provider. The object of the declaration described above is in conformity with the relevant Union harmonisation legislation: Regulation (EU) 2024/1689 (Artificial Intelligence Act).

4. References to Relevant Harmonised Standards

References to the relevant harmonised standards used, including the date of the standard, or references to other technical specifications, including the date of the specification, in relation to which conformity is declared:

ISO/IEC 42001:2023 — AI Management System
ISO/IEC 27001:2022 — Information Security Management
ISO/IEC 23894:2023 — AI Risk Management
ISO/IEC 24027:2021 — Bias in AI Systems
ISO/IEC 24392:2023 — Security and Privacy in AI
NIST AI RMF 1.0 (2023) + Generative AI Profile (2024)
EU AI Act Art 9 + Annex IV (technical documentation)

5. Notified Body Involvement (where applicable)

For Annex I Section A deployments (biometric AI, critical infrastructure AI, safety component of products subject to third-party assessment):
Notified body name: [assigned by EU Member State designation]
Notified body 4-digit number: [NB-XXXX]
Conformity assessment certificate reference: [cert-id]
Module chosen: Module C (production control) or Module H (full quality assurance)

For Module A self-assessed Annex III high-risk systems: marked "Not applicable — Module A self-assessment".

6. Place and Date of Issue

Place: [city, country]
Date of first issue: [DD Month YYYY]
Date of current issue: [DD Month YYYY] (this revision)
Revision number: [major.minor]

7. Signature (Name, Function)

Signed by: Nicholas Templeman, Director, CSOAI Ltd
Function: Authorised signatory
Ed25519 signature: [ed25519 sig of sha256(declaration_fields_1-6)]
SIGIL chain anchor: [sigil_id with type=P]

This declaration of conformity is the formal attestation that DEFONEOS meets all applicable requirements of Regulation (EU) 2024/1689 as of the date of issue. Any material change to the AI system or its intended purpose requires re-issuance under Article 49(3).

2 Variants of the Declaration

Module A Self-Assessment (Annex III high-risk, not Annex I Section A)

For high-risk systems under Annex III (e.g., recruitment AI, credit-scoring AI, education assessment AI) that are NOT also under Annex I Section A. The provider performs internal conformity assessment and signs the declaration. Field 5 marked "Not applicable — Module A self-assessment".

Notified-Body Module C / Module H (Annex I Section A deployments)

For biometric AI, critical-infrastructure AI, or safety-component AI under Annex I Section A. The notified body is named in Field 5, and the certificate reference is recorded. The provider still signs the declaration (responsibility remains with the provider), but the conformity assessment itself was third-party.

Machine-Readable JSON Variant

{
  "declaration_id": "DOC-DEFONEOS-2026-07-XX-001",
  "schema_version": "EU-DoC-AIV-V1.0",
  "ai_act_reference": "Regulation (EU) 2024/1689",
  "declaration_type": "Module A self-assessment",
  "issued_under_responsibility_of": "CSOAI Ltd",
  "ai_system": {
    "trade_name": "DEFONEOS",
    "version": "1.0.0",
    "intended_purpose": "Sovereign AI OS for public services"
  },
  "provider": {
    "legal_name": "CSOAI Ltd",
    "registration_number": "16939677",
    "country_code": "GB",
    "address": "[registered office]"
  },
  "authorised_rep": null,
  "harmonised_standards": [
    "ISO/IEC 42001:2023",
    "ISO/IEC 27001:2022",
    "ISO/IEC 23894:2023",
    "NIST AI RMF 1.0"
  ],
  "notified_body": {
    "name": null,
    "four_digit_number": null,
    "certificate_ref": null,
    "module": "A"
  },
  "place_of_issue": "[city, country]",
  "date_of_first_issue": "[ISO date]",
  "date_of_current_issue": "[ISO date]",
  "revision": "1.0",
  "signature": {
    "signed_by": "Nicholas Templeman",
    "function": "Director, CSOAI Ltd",
    "ed25519_signature": "[base64 sig]",
    "sigil_anchor": "[sigil_id]"
  },
  "official_languages": ["en", "fr", "de", "es", "it", "nl", "pl", "pt", "ro", "sk", "sl", "fi", "sv", "da", "cs", "el", "et", "hu", "lt", "lv", "mt", "bg"]
}

Translation & 23-Language Strategy

Per Art 47(3), the Declaration must be available in the official language(s) of the Member State where the system is placed on the market. DEFONEOS provides:

English (EN) — canonical source
22 other EU official languages: FR, DE, ES, IT, NL, PL, PT, RO, SK, SL, FI, SV, DA, CS, EL, ET, HU, LT, LV, MT, BG, GA
Machine translation via the EU eTranslation service where certified human translation is unavailable
Legal review by national qualified translators before Member State placement

Cost consideration: 22 official-language translations × ~2,000 words = ~44,000 words. EU-certified technical translators charge ~€0.10-0.20/word → ~€4,400-8,800 per full set. DEFONEOS phases this: EN first, then top 5 (FR/DE/ES/IT/PL), then full 23 before EU market placement.

Retention & Update Triggers

Trigger	Action	Art Reference
System version bump (major)	Re-issue declaration, mark as revision 2.x	Art 49(3) substantial modification
Risk class change	Re-assess conformity module, re-issue	Art 49(3)
New jurisdiction (Member State)	Translate to that state's language	Art 47(3)
Harmonised standard update	Verify continued compliance, update Field 4	Art 47(1)
Notified-body certificate expiry	Renew assessment, update Field 5	Art 43(2)
10-year retention expiry	Archive (do not destroy — for regulator queries)	Art 47(4)

10-Framework Crosswalk

Framework	Equivalent Provision	DEFONEOS Mapping
EU AI Act Art 47	EU Declaration of Conformity	This page
EU AI Act Annex V	Declaration content template	7-field structure above
Decision 768/2008 Annex III	General Declaration template	Adapted to AI Act
Regulation 765/2008 Art 5	Declaration as legal effect	Field 3
UK UKCA Declaration	UK post-Brexit equivalent	Documented but not used in EU
EU Machinery Regulation 2023/1230	Declaration for AI safety components	Where AI is a machinery safety component
EU Medical Device Reg 2017/745	Declaration for AI medical devices	Where AI is a medical device
ISO/IEC 17050	Supplier's Declaration of Conformity (general)	Form basis
NIST AI RMF	Trustworthy characteristics declaration	Aligned with Field 4
C2PA 2.0	Provenance attestation	Field 7 SIGIL anchor

Honesty Register

1. The Declaration above is a TEMPLATE — it has NOT been issued for a live DEFONEOS deployment. Live issuance requires (a) CSOAI Ltd's registered office address to be finalised, (b) Module A or notified-body conformity assessment to be completed, and (c) all 8 preconditions from the CE marking page to be formally MET.

2. The signature line is illustrative — no live declaration has been signed. The Ed25519 signature slot is structurally defined but contains a placeholder until issuance.

3. Field 1 (intended purpose) reflects DEFONEOS positioning but is general — live deployments specify the precise public service function, jurisdiction, and decision categories per Art 13(3)(a).

4. For Annex I Section A deployments (biometric AI, critical infrastructure), the notified-body route applies — DEFONEOS anticipates requiring this for biometric identity verification in public services and certain counter-drone deployments.

5. Harmonised standards in Field 4 are those DEFONEOS aligns with, but only standards that have been published as "harmonised" under the AI Act (via the European Standardisation Organisations — CEN/CENELEC/ETSI) carry the formal presumption of conformity. The list will be updated as the AI Office publishes the harmonised-standards list.

6. 23-language translation requires regulatory-grade translators; machine translation alone is insufficient for legal documents. DEFONEOS phases translation by market entry priority.

7. Authorised representative per Art 22 is required where the provider is not established in the EU. CSOAI Ltd is UK-based, so for EU market placement an AR is required. The AR slot is structurally defined but empty pending AR appointment.

SIGIL Chain Anchor

Every Declaration issuance, revision, and translation triggers a SIGIL event of type P (Publication) with the declaration_id, schema_version, language code, and Ed25519 signature. The SIGIL chain provides an immutable public record of every Declaration ever issued by DEFONEOS.

Public SIGIL explorer: https://csoai.org/v1/sigil/events?actor=defoneos&action=eu-declaration

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