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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.

  1. 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.

  1. 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

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

  1. 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 approach

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