Auditors, customers and regulators increasingly ask for documentation of an AI model and the system built around it, and most teams have only a README and a slide deck. A model card describes one trained model: what it is for, how it was trained and evaluated, and where it fails. A system card describes the deployed AI system: the model plus prompts, tools, data connections, identities, safeguards and human oversight. This template gives you both, as numbered sections you can copy into a repository or GRC tool, with a cross-reference to the EU AI Act Annex IV and Annex XI documentation points and to the machine-readable formats (Hugging Face metadata and CycloneDX modelCard). It is for ML engineers, AI governance leads and security assurance teams.
How to use this template
- Pick the card type: complete sections 1 to 7 and 10 for a model card. Complete all sections for a system card. A system that uses a third-party model links to the supplier's model card rather than copying it.
- Replace placeholders: text in square brackets, such as [Organisation], [System name] and [AI governance lead], is yours to fill. Write "Not applicable" with a reason rather than deleting a field, so reviewers can see it was considered.
- Keep it versioned: store the card alongside the model or system configuration, ideally as Markdown in the same repository, so every release has a matching card.
- "Must" and "should": "must" marks fields your assurance process requires; "should" marks recommended fields. Adjust to your policy.
- Link, do not duplicate: point to the risk assessment, test reports and AI register entry instead of pasting them. See the AI Register and AI Inventory Template.
1. Document control
| Field | Entry |
|---|---|
| Card type | [Model card / System card] |
| Name and identifier | [Model or system name], [AI register ID] |
| Version of model or system described | [Version, commit or release tag]; relation to previous versions |
| Card version and date | [1.0], [date] |
| Accountable owner | [Named person and role] |
| Provider / deployer role | [Organisation] acts as [provider / deployer / both] for this system |
| Classification and audience | [Internal / Customer-shareable / Public]; redactions applied: [list] |
| Approvals | [AI governance lead], [Security lead], [Legal / Privacy], dates |
2. Overview and intended purpose
- Summary: [Two or three sentences on what the model or system does and for whom.]
- Intended purpose: [The specific task, the context and conditions of use, and the users or affected persons.]
- Risk classification: [Internal risk tier]; EU AI Act category, if applicable: [prohibited check done / high-risk under Annex III point X / transparency obligations / minimal]. See the EU AI Act High-Risk AI Systems Guide.
- Form of release: [Internal API / embedded in product / downloadable weights / SaaS feature]; hardware or runtime requirements.
3. Uses and out-of-scope uses
- Direct use: [Supported uses without further adaptation.]
- Downstream use: [Fine-tuning or integration into other systems that [Organisation] supports.]
- Out-of-scope and prohibited use: [Uses that are unsupported or forbidden, including any acceptable use policy terms.] Out-of-scope use must be stated explicitly; silence is read as permission.
- User and deployer instructions: [Link to instructions for use, including how outputs should be interpreted.]
4. Model details and provenance
| Field | Entry |
|---|---|
| Developer and supplier | [Organisation or third party]; supplier model card link if third-party |
| Model type and architecture | [e.g. decoder-only transformer, gradient-boosted trees]; parameter count where known |
| Base model and relation | [Base model ID]; relation: [fine-tune / adapter / merge / quantised] |
| Input and output modalities | [Text, image, audio, tabular]; formats and limits |
| Licence | [SPDX identifier or licence link] |
| Artefact integrity | [SHA-256 hash or signature of weights]; registry location; signing identity. See the Model Signing Guide |
| Dependencies | [Frameworks, tokenisers, libraries]; link to AI-BOM. See the AI Supply Chain and AI-BOM Guide |
| Compute and energy | [Training compute, training time, estimated energy] where known or required |
5. Training and evaluation data
- Data sources: [Datasets with identifiers, origin, and how they were acquired: licensed, collected, synthetic, scraped.]
- Preparation: [Selection, labelling, cleaning and filtering steps, including removal of unsuitable sources.]
- Personal and sensitive data: [Categories present, lawful basis reference, minimisation applied, link to DPIA.]
- Bias checks: [How representativeness and identifiable biases were examined.]
- Data integrity: [Dataset hashes or versions, who can write to training stores, and how poisoning risk is controlled.]
- Evaluation data: [Held-out sets, how they differ from training data, and leakage checks.]
6. Evaluation and testing results
| Test | Method and dataset | Metric | Result | Threshold | Date and signed off by |
|---|---|---|---|---|---|
| Task performance | [Benchmark or internal set] | [Accuracy, F1, error rate] | [ ] | [ ] | [ ] |
| Performance by group | [Groups or factors tested] | [Metric per group] | [ ] | [Maximum gap] | [ ] |
| Robustness | [Perturbation or adversarial set] | [Degradation] | [ ] | [ ] | [ ] |
| Prompt injection and jailbreak (LLM systems) | [Red team or tool, scope] | [Attack success rate] | [ ] | [ ] | [ ] |
| Data leakage | [Extraction and memorisation probes] | [Leak rate] | [ ] | [ ] | [ ] |
| Tool and agent misuse (system card) | [Scenarios attempting unauthorised actions] | [Blocked rate] | [ ] | [ ] | [ ] |
Record test logs with dates and sign-off; regulators and auditors look for evidence that tests ran on the version described, not an earlier one. See the AI Red Teaming Guide.
7. Risks, limitations and safeguards
- Known limitations: [Conditions where performance drops: languages, input types, edge cases.]
- Foreseeable misuse and unintended outcomes: [Risks to health, safety, fundamental rights, security and the organisation.]
- Security threats considered: [Poisoning, evasion, extraction, prompt injection, supply chain]; link to threat model.
- Safeguards: [Filters, guardrails, rate limits, output checks, approval steps], with the residual risk accepted and by whom.
- Recommendations for deployers: [What a user of this model or system must do to stay within safe operation.]
8. System architecture, integrations and identities
System cards only. This is the section most often missing, and the one security reviewers need most.
| Component | Description | Identity used | Permissions | Owner |
|---|---|---|---|---|
| Model endpoint | [Provider, model version, region] | [API key / workload identity] | [Scope] | [ ] |
| System prompt and configuration | [Location, version control] | [Who can change it] | [ ] | [ ] |
| Retrieval sources | [Indexes, document stores] | [Service account] | [Read scope] | [ ] |
| Tools, plugins and MCP servers | [Each tool and what it can do] | [OAuth client, token, service account] | [Actions allowed] | [ ] |
| Memory and logs | [Stores, retention] | [ ] | [ ] | [ ] |
- Delegation model: [Does the system act with its own identity, on behalf of the user, or both? How is the user context passed?]
- Credential handling: [Where secrets are stored, rotation period, whether credentials are short-lived.] See the Agentic AI Identity Guide.
- High-impact actions: [Actions requiring human approval.]
9. Human oversight and operation
- Oversight measures: [Who reviews outputs or approves actions, how they can override or stop the system, and what training they receive.]
- Monitoring: [Metrics, drift checks, logging of prompts, tool calls and decisions, retention period.]
- Incident handling: [How issues are reported, the contact, and the link to the AI incident procedure.] See the AI Incident Reporting Guide.
- Post-market or post-deployment review: [Review frequency and triggers.]
- Decommissioning: [How the system is retired, credentials revoked and data disposed of.]
10. Change log and review
| Card version | Date | Model or system version | Change | Re-tested? | Approved by |
|---|---|---|---|---|---|
| [1.0] | [ ] | [ ] | [Initial card] | [Yes / No] | [ ] |
The card must be reviewed on every release that changes the model, system prompt, tools or data sources, and at least [annually].
Implementation guidance
Model card or system card?
| Question | Model card | System card |
|---|---|---|
| What it describes | One trained model artefact | The deployed system: model, prompts, tools, data, identities, oversight |
| Who writes it | Model developer or provider | System owner with security and governance input |
| Main readers | Integrators, downstream developers, model risk | Auditors, customers, security reviewers, regulators |
| Changes when | The weights or training data change | Any component, prompt, tool or permission changes |
| Machine-readable form | Hugging Face YAML metadata; CycloneDX modelCard | AI-BOM plus the card in Markdown |
Cross-reference to EU AI Act documentation
For high-risk AI systems, Article 11(1) and Annex IV of Regulation (EU) 2024/1689 set the content of technical documentation. For general-purpose AI models, Annex XI sets the content. A well-kept card covers much of it, but it is not the full technical file.
| Template section | Annex IV (high-risk systems) | Annex XI (GPAI models) |
|---|---|---|
| 2. Overview and intended purpose | Point 1(a) intended purpose, provider, version; 1(d) forms of release; 1(e) hardware | Section 1, point 1: intended tasks, release date and distribution |
| 3. Uses | Point 1(h) instructions for use | Section 1, point 1: acceptable use policies |
| 4. Model details | Point 2(a) development methods including third-party pre-trained tools; 2(b) design specifications | Section 1, points 1 and 2: architecture, parameters, modalities, licence, compute, energy |
| 5. Data | Point 2(d) data requirements and datasheets | Section 1, point 2: training, testing and validation data |
| 6. Evaluation | Point 2(g) validation and testing with dated, signed logs; point 4 appropriateness of metrics | Section 2: evaluation strategies, adversarial testing (systemic-risk models) |
| 7. Risks and safeguards | Point 3 capabilities, limitations, foreseeable risks; point 5 risk management system (Article 9); point 2(h) cybersecurity measures | n/a |
| 8. Architecture and identities | Points 1(b) interaction with other systems; 2(c) system architecture | Section 2, point 3: system architecture (systemic-risk models) |
| 9. Oversight and operation | Point 2(e) human oversight (Article 14); point 9 post-market monitoring (Article 72) | n/a |
| 10. Change log | Point 6 lifecycle changes | n/a |
Annex IV also requires the list of harmonised standards applied (point 7) and a copy of the EU declaration of conformity (point 8); keep those in the technical file, not the card. See the EU AI Act Provider vs Deployer Obligations Guide and the EU General-Purpose AI (GPAI) Code of Practice Guide.
Rolling it out
- Start with the riskiest systems: pick the three highest-tier entries in the AI register and write system cards for them first.
- Request supplier model cards: add a model card or equivalent documentation requirement to AI procurement and vendor questionnaires. See the AI Vendor Security Questionnaire Template.
- Automate what you can: generate sections 4 and 5 from the training pipeline and registry metadata, and section 8 from infrastructure-as-code and identity inventories, so cards do not drift.
- Gate releases: make an up-to-date card a release criterion in the deployment pipeline, starting in warning mode before blocking.
- Prepare a shareable version: derive a redacted card for customers that removes internal hostnames, identity names and detailed safeguards an attacker could use.
Measuring it
- Card coverage: percentage of AI register entries above the lowest risk tier with a current card.
- Freshness: percentage of cards whose model or system version matches production.
- Identity completeness: percentage of system cards whose section 8 names every credential and owner.
- Supplier documentation rate: percentage of third-party models with a supplier model card on file.
Common mistakes
- Cards written once at launch and never updated after prompt, tool or model changes.
- Model card used as a system card: the model looks safe, but the risk sits in the tools and permissions the system adds.
- Benchmark scores without context: results with no dataset, date or threshold cannot support an assurance decision.
- Publishing internal detail: a public card that lists service account names, endpoints or bypassable filters helps attackers.
Related documents
- AI inventory: AI Register and AI Inventory Template
- Transparency to users: AI Transparency Notice Template
- Risk method: AI Risk Assessment Guide
- Management system: ISO/IEC 42001 Guide
- Source formats: Mitchell et al.: Model Cards for Model Reporting · Hugging Face: Model cards · CycloneDX: Machine Learning Bill of Materials · EU AI Act Explorer: Annex IV · EU AI Act Explorer: Annex XI
This template is provided for guidance and must be adapted to your organisation. It is not legal advice. Related NHI Mgmt Group resources: AI Register and AI Inventory Template · EU AI Act Compliance Guide · AI Supply Chain and AI-BOM Guide · Model Signing Guide