Automatic logging for high-risk AI systems from August 2026

Record-Keeping Obligations Under Article 12 AI Act

Article 12 of the EU AI Act requires providers and deployers of high-risk AI systems to implement automatic logging of all system-relevant events throughout the lifecycle.

  • 01Implement automatic logging per Article 12 AI Act requirements
  • 02Meet retention periods for providers (10 years) and deployers (6 months)
  • 03Build audit trail structures for traceability and post-market monitoring
  • 04GDPR-compliant logging strategy with data minimisation and purpose limitation
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540+Projects
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What record-keeping obligations apply under Article 12 AI Act for high-risk AI systems?

Article 12 of the EU AI Act requires high-risk AI systems to have automatic logging capabilities that capture events throughout the entire lifecycle. These logs serve traceability, risk detection and post-market monitoring under Article 72. Providers must implement logging before placing on the market; deployers must retain logs for at least six months.

We provide comprehensive support for the implementation of EU AI Act-compliant record-keeping systems, from strategic planning through to technical implementation and ongoing operational support.

2 service modules

Service scope

01

Record-Keeping System Design

Development of a comprehensive documentation strategy and technical architecture for EU AI Act-compliant records.

  • Analysis of specific documentation requirements
  • Design of automated logging architectures
  • Data modelling for structured records
  • Integration into AI development workflows
02

Technical Implementation

Implementation of solid and flexible record-keeping infrastructures with automated processes.

  • Automated data capture and storage
  • Secure and immutable audit trails
  • Real-time monitoring and alerting
  • Compliance dashboard and reporting

5 phases

Our Approach

We develop tailored record-keeping solutions that meet regulatory requirements and can be integrated into your existing systems.

  1. Assessment of your AI systems and record-keeping requirements

  2. Design of a comprehensive documentation strategy

  3. Implementation of automated record-keeping systems

  4. Integration into existing IT infrastructures

  5. Testing, validation, and continuous monitoring

Asan Stefanski

Your contact

Asan Stefanski

Head of Digital Transformation

11+ years of experience, Applied Computer Science degree, Strategic planning and management of AI projects, Cyber Security, Secure Software Development, AI

Our Expertise

  • 01Specialised knowledge of EU AI Act record-keeping requirements
  • 02Experience in the technical implementation of compliance systems
  • 03Comprehensive approach covering legal through to technical aspects
  • 04Proven implementation strategies and best practices

Compliance Notice

Incomplete or inadequate records can lead to significant fines under the EU AI Act. A proactive record-keeping strategy is essential for compliance.

7 QUESTIONS, BRIEFLY ANSWERED

Frequently asked questions about EU AI Act Record Keeping

What record-keeping obligations does the EU AI Act impose?

Article 12 requires high-risk AI systems to have automatic logging capabilities that capture events throughout the entire lifecycle. Records serve traceability, risk detection, and post-market surveillance. They must be implemented by default and function without external modification.

What must an AI system automatically log?

Automatic logging must capture at minimum: usage periods (start and end timestamps), input data leading to matches, reference databases used, and identity of verifying persons. Biometric identification systems under Annex III point 1(a) face enhanced logging requirements.

How long must AI records be retained?

Retention periods differ by role: providers must retain technical documentation and quality management records for at least 10 years. Deployers must store automatically generated logs for at least 6 months under Article 26(6). Sector-specific regulations may require longer periods for certain high-risk systems.

What are AI records used for?

Records serve three core functions: risk detection (identifying events indicating emerging risks), post-market monitoring under Article 72 (assessing system behaviour after deployment), and operational oversight under Article 26(5) (facilitating monitoring by deployers and authorities).

What standards exist for AI system logging?

The final draft ISO/IEC FDIS 24970 (as of May 2026) standardises AI system logging and helps providers integrate Article 12 into development and design processes. Additionally, EN 18229‑1 defines requirements for internal logging mechanisms. The European Commission is developing harmonised standards that will serve as presumption of conformity with logging requirements.

How do AI record-keeping duties relate to GDPR?

AI logs may contain personal data subject to GDPR. Storing records must be compatible with data protection principles, particularly data minimisation and purpose limitation. An integrated logging strategy addressing both the AI Act and GDPR frameworks is essential for compliance.

When do EU AI Act record-keeping obligations take effect?

The Digital Omnibus on AI, adopted in June 2026, moved the record-keeping obligations for standalone high-risk AI systems under Annex III from 2 August 2026 to 2 December 2027. For high-risk AI embedded in products covered by Annex I product-safety law, the date is 2 August 2028. The Article 50 transparency obligations were not deferred and have applied since 2 August 2026. Providers should still build logging into development now, because retrofitting existing systems is significantly more complex and costly.

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