Initial Report Content (Art. 73(5)) The initial report is prepared using the Commission’s September 2025 draft template. It contains the provider’s identity, the system’s identity and EU database registration details, a description of what happened (when, where, who was affected), the suspected causal link between the AI system and the harm, and the immediate actions taken to prevent further harm. A pre-templated notification package reduces the time between triage determination and regulatory submission. The template has fields pre-populated from the AISDP and the incident management system. Structured incident timeline tools (Incident.io, FireHydrant) can export chronologically ordered narratives into the template, ensuring accuracy under time pressure. The initial report explicitly acknowledges that the investigation is ongoing and that supplementary information will follow. Incomplete but timely reporting is far preferable to delayed but comprehensive reporting; the timelines are strict, and failure to report within the required period is itself a compliance violation. Key outputs

• Commission template adopted as reporting baseline
• Pre-templated fields populated from AISDP and incident management
• Explicit acknowledgement that investigation is ongoing
• Timely submission prioritised over comprehensiveness