You know what is required. Where it sits is the real question.
The technical documentation demonstrates that a machine meets the essential health and safety requirements. Annex IV of Machinery Regulation (EU) 2023/1230 names the components: a full description of the machinery, the risk assessment documentation including protective measures and residual risks, design and manufacturing drawings including circuit diagrams, and reports and results of design calculations, tests and inspections. It must be kept for at least ten years after the last unit was made available, and produced to the authorities on request.
What belongs in the technical documentation is set out in the regulation, and a dozen pages online reproduce it correctly. This one asks the second question: where does each of those components sit in your company, in which version, and who maintains it? In practice that answer comes harder than the first.
Purpose, retention period and audience
The technical documentation is not a folder for the archive, it is evidence. It demonstrates that the machine meets the essential health and safety requirements, in a form an authority can follow without calling you.
Three points drive the effort. First the period: at least ten years after the last unit was made available. That is considerably longer than most project archives are maintained, and usually longer than the responsible engineer stays with the company. Second the duty to produce: on request, within a reasonable time. Anyone who starts searching at that point has the wrong problem at the wrong moment. Third the scope: the documentation covers the whole life of a design, not only its state at delivery.
From 20 January 2027 this falls under Machinery Regulation (EU) 2023/1230. For machinery placed on the market before that, Machinery Directive 2006/42/EC remains the reference.
Eight components, eight locations
On the left, what is required. On the right, you write down where it sits in your company and who maintains it. The right-hand field is the actual point of this list: in most companies it is harder to fill in than the left.
Full description of the machinery and related products
The starting point for any assessment. Must reflect the state as delivered, not as planned.
In our company: location and ownerRisk assessment documentation with the list of health and safety requirements applied
The core of the evidence. Without this list there is no way to check which requirements were considered at all.
In our company: location and ownerDescription of the protective measures taken and the residual risks
Justifies why the chosen solution is sufficient. The part that most often exists only in someone's head.
In our company: location and ownerDesign and manufacturing drawings including circuit diagrams
Usually sits in the PDM system, but rarely in the version that was actually shipped.
In our company: location and ownerReports and results of design calculations, tests, inspections and examinations
In practice this spreads across most drives and mailboxes.
In our company: location and ownerInstructions in the version as delivered
Digital is permitted from 2027 provided they can be downloaded and printed. A printed version must be supplied on request.
In our company: location and ownerEU declaration of conformity
The document that summarises everything else. Without the underlying documentation it is only a sheet of paper.
In our company: location and ownerCertificates from a notified body where the machinery falls under Annex I Part A
Mandatory only for the regulation's high-risk categories, but with no alternative there.
In our company: location and owner
This list summarises the core components and is a working aid, not a reproduction of the regulation. Annex IV of the regulation is what binds.
Three places where it regularly breaks down
- The documentation is complete but scattered
- Drawings in the PDM system, calculations on a project drive, test reports in the inspector's mailbox, the instructions with a service provider. Formally nothing is missing. In practice nobody can say within a day whether something is missing, and that is exactly the question an authority asks.
- The referenced standard is out of date
- A drawing from 2019 cites a version of a standard that has since been superseded. That is not automatically a defect, but it has to be assessed. Only someone who knows the reference is there can assess it. The Commission is currently reviewing the harmonised standards to establish whether they still confer presumption of conformity under the new regulation.
- The person is gone and so is the knowledge
- A ten-year retention period outlasts staff changes, reorganisations and at least one system migration. Whatever was not in the documents but in the engineer's head cannot be reconstructed. That hits hardest on the question of why a protective measure was chosen the way it was.
Complete is not the same as findable
If you have worked through the list above, you probably have a tick against every item and a question mark against several of the locations. That is the normal case and not an organisational failure: engineering archives grow over decades and across several systems.
The question that follows is no longer a legal one. It is a question put to a body of documents: which standards do our documents cite, in which version, and in which place? That is what KoAssist answers, with file, page and section as evidence.
This page reflects research as of 25 August 2026 and does not replace legal advice. Only the text of the regulation is binding.
What gets asked most while pulling it together
The answers refer to machinery and related products within the scope of the regulation.
How long must the technical documentation be kept?
At least ten years after the day the last unit was made available. The period therefore does not run from design, nor from first delivery, but from the last machine built in the series.
Does everything have to sit in one place?
No. What is required is that it can be produced to the authorities within a reasonable time on request. Distributed storage is permitted as long as somebody knows where everything is. In practice that is what fails more often than missing documents.
Is the declaration of conformity sufficient as evidence?
No. It is the summary, not the evidence. The evidence is the underlying documentation, above all the risk assessment with the protective measures taken.
What applies to machinery placed on the market before 2027?
Machinery Directive 2006/42/EC remains the reference for it. The retention obligation does not end any earlier as a result, and a substantial modification after the cut-off date can change the assessment.
We found an outdated version of a standard in a drawing. Is that a defect?
Not automatically. It has to be assessed whether the reference still supports the presumption of conformity. The practical bottleneck is rarely the assessment. It is finding every place such a reference appears.
Less searching.
More engineering.
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