Article 12: logging and traceability
Automatic recording of events over the lifetime of a high-risk AI system.
The official source remains authoritative. This general interpretation is not legal advice.
- Status
- Upcoming
- Application date
- 2 December 2027
- Version
- 1.0.0
- Last reviewed
- 8 August 2026
Who this is relevant to
When this applies
Deployer
An organisation using an AI system under its authority, excluding personal non-professional use.
Provider of an AI system
A party that develops or has an AI system developed and places it on the market under its own name.
- 1The system is high-risk; the provider designs the logging, provider and deployer retain the logs under their control.
What the official source establishes
Article 12 requires high-risk AI systems to be technically capable of automatically recording events over their lifetime, for traceability, risk signalling and post-market monitoring; Article 19 and Article 26(6) govern log retention.
For the Annex III route this requirement applies from 2 December 2027; for high-risk AI in regulated products (Annex I) from 2 August 2028.
Our interpretation
Logging is the backbone of all other evidence: without logs an incident cannot be reconstructed and a monitoring duty cannot be fulfilled. Buyers should already test whether a system is technically capable of this.
What you can do now
Include logging capability and log access as a requirement in every AI purchase and assign the retention regime (who, where, how long) per system.
- 01
Design logging into the system
Ensure the system automatically records events relevant to risk identification and post-market monitoring.
What to retain
Logs and retention regime
Log files with a retention period appropriate to the purpose and at least six months for deployers (Articles 19 and 26).
Control and reassessment
Periodic log review
Periodically verify that logging works, is complete and is retained according to the regime.
Public tools
Full text of Article 12
The full legal text in the public AI Act Explorer.
Conditions and exceptions
- The retention period may be limited by Union or national law, including data protection.
Official sources and locators
EU Artificial Intelligence Act 2024/1689
European Parliament and Council | original-oj-2024-07-12
Source locator: Article 12, Article 19 and Article 26(6)
Digital Omnibus on AI 2026/1744
European Parliament and Council | official-journal-2026-07-24
Source locator: Amended Article 113 application dates
Version history
v1.0.0
27 July 2026
Article 12: logging and traceability
Automatic recording of events over the lifetime of a high-risk AI system.
Execution
From obligation to arranged and demonstrable
Knowing where you stand is step one. Embed AI translates this obligation into a concrete approach for your organisation: scope, ownership, register and evidence.
See the Embed AI approachFor AI agents and integrations
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