Human oversight log for high-risk AI: a one-page weekly sheet for small EU deployers (2026)
What you get: a finished one-page weekly human oversight log you can print or keep in a sheet: who oversaw which high-risk AI tool, what they reviewed, any override or stop, and what to escalate. Fill one row per oversight action (or one summary row per day). File it with the tool's instructions for use. Aimed at Article 26 deployer duties in Regulation (EU) 2024/1689 — especially Article 26(2) (assign competent people) and the monitoring / inform duties in Article 26(5).
When this sheet applies
| Situation | Use this weekly log? | Why |
|---|---|---|
| You use a high-risk AI system (Annex III), e.g. CV filter, staff performance rating, credit scoring | Yes | Article 26(2) requires assigned human oversight with competence, training, authority and support |
| You only use ChatGPT or Copilot to draft emails and docs | Usually no | Not high-risk if it does not decide about people; cover in your staff AI use policy |
| You build and sell the AI yourself (you are the provider) | Different duties | Providers design human-oversight measures under Article 14; this sheet is for deployers who use someone else's high-risk system |
| You have not yet checked if the tool is high-risk | Check first | Run the 10-minute Annex III check, then start the log if the answer is yes (or "treat as high-risk until sure") |
Most high-risk deployer obligations apply from 2 December 2027. Building the habit now is cheap; scrambling later is not.
What Article 26 asks of you (plain English)
- Art. 26(1): use the system according to the provider's instructions for use.
- Art. 26(2): assign oversight to named people who have the competence, training, authority and support to do it.
- Art. 26(4): if you control the input data, keep it relevant and representative for the intended purpose.
- Art. 26(5): monitor operation; if the use may present a risk under Art. 79(1), inform the provider/distributor and the market surveillance authority and suspend use; if you identify a serious incident, inform the provider first, then importer/distributor and authorities (Art. 73 applies if you cannot reach the provider).
- Art. 26(6): keep automatic logs under your control for at least six months (or longer if the purpose needs it).
This weekly sheet does not replace the automatic logs or the instructions for use. It shows that a real person was on the job.
The weekly sheet (copy and fill in)
Human oversight log · Tool: [name / version] · Week starting: [dd/mm/yyyy] · Overseer(s) this week: [name, role]
Instructions for use on file: [yes / location] · Last training date of overseer: [dd/mm/yyyy] · Authority to override or stop: [yes / limited to …]
| Date | What was reviewed (sample / batch / alerts) | Volume or period | OK / override / stop | Notes (bias, error, odd output) | Escalated to |
|---|---|---|---|---|---|
| [dd/mm] | [e.g. shortlist of 40 CVs for sales role] | [n or "Mon–Fri"] | [OK] | [none] | [—] |
| [dd/mm] | [e.g. 3 flagged low scores] | [3] | [override] | [score ignored; human shortlist kept] | [Head of HR] |
| [dd/mm] | [e.g. unexplained spike in rejections] | [day] | [stop] | [paused tool; emailed provider] | [provider + MSA if needed] |
Week summary: overrides this week: [n] · stops: [n] · open issues: [list] · next review: [date]
Signed: [overseer name] · Date: [dd/mm/yyyy]
Print it, keep it in a shared folder, or paste the table into Google Sheets / Excel. One sheet per high-risk tool. Keep filled sheets for at least as long as you keep the related automatic logs (six months minimum under Art. 26(6), longer if your purpose or national rules need it).
How to fill each column without fluff
- Date — the day oversight happened, not the day you wrote it up.
- What was reviewed — a concrete sample: "all shortlists for role X", "every alert over threshold Y", "random 20 outputs".
- Volume or period — enough that someone else can see you did not only check one case.
- OK / override / stop — pick one. Override means a human changed or rejected the AI output. Stop means you paused or switched the tool off.
- Notes — one line on what looked wrong (wrong category, odd score, missing data, possible bias). Empty notes on an "OK" day are fine.
- Escalated to — named role or "provider email on [date]". If you think Art. 79 risk or a serious incident, follow Art. 26(5) timelines, not just this sheet.
Checklist before you rely on the log
- The tool is in your AI inventory (SME AI inventory template)
- Annex III result written down with a date (Annex III check)
- Provider's instructions for use on file; oversight measures from those instructions named (12 vendor questions)
- Named overseer has training and authority to override or stop (Art. 26(2)); AI-literacy duty under Art. 4 applies since 2 February 2025
- Automatic logs under your control are being kept (≥ 6 months): record-keeping guide
- If the tool touches staff or applicants, the notice and workers' representatives steps are done: staff / applicant notice template
This sheet is a starting point, not a legal opinion or proof of compliance. Sector rules (finance, health, employment) and national labour law can add more. Spot an error in this guide? Write to mininglife7@gmail.com.
For accountants and tax advisers
Clients who hire, score staff, grant credit or use AI for access to essential services are the ones most likely to need this. Ask "who reviews the AI output each week, and can they override it?", note the answer with a date, and hand them this sheet. Fit it next to the client AI inventory workshop. Stay inside your professional rules and pass legal questions to a lawyer.
Keep the log with your AI register
The EURO AI Register free edition runs in your browser with no account and no upload. It covers your first 10 AI systems and 10 evidence records, the screening questions, duties by role with dates, and a printable Article 4 AI-literacy record. Add each high-risk tool, name the overseer, and store the weekly sheet date as an evidence record.
When you need more than 10 systems, the EURO AI Register membership starts at $19 a month and adds unlimited systems, rule updates and email help. Neither tool is legal advice or proof of compliance.
Partner programme opening soon
Partner programme opening soon: join the free waitlist. Planned terms are 50% of each referred sale (75% once you have 5+ paying customers), single level, paid through Gumroad only from revenue received.
Free start: list each high-risk tool and its overseer in the EURO AI Register free edition, then attach this week's log date. Related: Record-keeping for SME deployers · Annex III check · 12 vendor questions.
Sources
- Regulation (EU) 2024/1689 (AI Act): Articles 4, 14, 26(1)–(6), 72, 73, 79 and Annex III
- European Commission AI Act Service Desk: Article 26 (deployer obligations summary)
- European Commission: AI Act regulatory framework
Unadhi Guides are free, independent explainers. We correct errors as soon as we find them: write to mininglife7@gmail.com.