Not legal advice. Answers describe what the sample documentation states and where it has gaps. They don't say whether an obligation applies.
Ask the evidence corpus
The corpus is the Gemma evidence set in dita-corpus, the source that Manifest migrates: 21 evidence topics adapted from the Gemma 4 and Gemma 3 model cards, and 26 requirement topics for EU AI Act Annexes XI and XII and the NIST AI RMF. Each point of an answer cites a topic, with the commit that last changed it, its revised date, who approved it, and the requirements it answers in the trace. Plain checks drop any point whose quote or numbers aren't in its source.