Spain's AESIA Publishes Technical Guides 13 and 14 for EU AI Act Compliance

The Agencia Española de Supervisión de la Inteligencia Artificial (AESIA), Spain's national AI supervisory authority, has published Specialised Technical Guides 13 and 14 as part of the second block of guides developed under the Spanish AI regulatory sandbox pilot. Guide 13 addresses post-market monitoring obligations for providers of high-risk AI systems, and Guide 14 addresses the serious incident reporting regime. Both guides are available on the AESIA official website and form part of a series spanning Guides 3 through 15. They are non-binding guidance but carry persuasive authority as outputs of the competent national authority designated to support application of Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 on artificial intelligence (the EU AI Act).

The relevant controlling provisions are Chapter III of the EU AI Act (obligations for high-risk AI systems), specifically Article 72, which requires providers of high-risk AI systems to establish and document post-market monitoring systems, and Article 73, which requires providers and deployers to report serious incidents to national competent authorities without undue delay. AESIA notes that these guides are subject to ongoing review and will be updated once the Digital Omnibus amending the AI Act is adopted. The guides were developed collaboratively within the Spanish AI regulatory sandbox, involving participants, technical assistants, potential competent national authorities, and an expert advisory group.

Providers placing high-risk AI systems on the EU market must now contend with the combined requirements of Articles 72 and 73 supplemented by these AESIA guides. Article 72 post-market monitoring applies to providers who must collect, document, and analyse data on the performance of their systems throughout the lifecycle. Article 73 serious incident reporting applies where an AI system causes or contributes to death, serious injury, serious damage to property, or a serious breach of fundamental rights. Spain's sandbox-developed guidance provides concrete implementation checklists and examples that other EU member states and the European Commission may draw upon when developing harmonised guidance.

AESIA makes clear that these guides do not replace the applicable Regulation and are subject to amendment following adoption of European Commission standards. Providers should treat them as interim operational guidance pending the publication of harmonised technical standards by standardisation bodies designated under Article 40 of the AI Act. The guides are part of the Spanish contribution to the Commission's AI Office working groups on harmonised guidance.

Prokopiev Law Group advises on EU AI Act compliance, high-risk AI system classification, and cross-border AI regulatory strategy; our dedicated partner network extends to Spanish and EU-qualified AI regulatory specialists. We advise AI system providers, deployers, and importers on meeting Article 72 post-market monitoring and Article 73 incident reporting obligations. Our work includes: EU AI Act compliance assessments, high-risk AI system classification, post-market monitoring system design, serious incident reporting procedures, AI regulatory sandbox participation, technical documentation requirements, and multi-jurisdiction AI compliance programmes.

Source: Agencia Española de Supervisión de la Inteligencia Artificial (AESIA), Guides 13 and 14 (Post-market monitoring guideline and Serious Incident guideline), https://www.aesia.gob.es/en/guides. Confirmed 28 April 2026.

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