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EU AI ACT · RECORD KEEPING · ARTICLE 12

STORING LOGS IS NOT THE SAME
AS PRESERVING EVIDENCE.

High-risk AI record keeping is useful only when events remain connected to the system, time, context, source and accountable action they represent. TA-14 treats logging as part of a governed evidence chain rather than an archive of unexplained machine events.

BOUNDARYThis page is educational and operational guidance. It is not legal advice, certification, conformity assessment or regulatory approval.
CURRENT SOURCE ANCHOR

EUR-Lex · Regulation (EU) 2024/1689 · Articles 12, 19 & 26

Use the current consolidated Regulation as the controlling source. Article 12 addresses high-risk system record-keeping capability, while provider and deployer retention responsibilities are addressed in related provisions including Articles 19 and 26.

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WHAT BUSINESSES NEED TO ESTABLISH

Do not start with a generic checklist.

Start with the actual system, role, use case and evidence boundary. The same regulation can produce different obligations for different actors and systems.

01

A LOG ENTRY IS NOT SELF-EXPLAINING EVIDENCE

A timestamp and event can be meaningless without system identity, version, context, source and the operational state in which the event occurred. Preserve the relationship between the record and the reality it represents.

02

HIGH-RISK SYSTEMS NEED LOGGING CAPABILITY

Article 12 requires high-risk AI systems to technically allow automatic recording of events over the system lifetime, with logging capabilities appropriate to traceability and risk monitoring under the applicable provisions.

03

PROVIDERS AND DEPLOYERS HOLD DIFFERENT RECORDS

The system may generate logs, while providers and deployers can have distinct retention and access responsibilities. Map the record to the actor who actually controls it rather than assuming one universal owner.

04

RETENTION WITHOUT INTEGRITY IS NOT ENOUGH

Records should preserve chronology, provenance, access, material changes and relevant human interventions so later review can distinguish an authentic historical state from a reconstructed story.

THE TA-14 OPERATING ROUTE

Turn the question into a governed record.

The goal is not merely to reach an answer. It is to preserve what facts, evidence, scope and limitations supported that answer at that time.

01

Define what event must be reconstructable

Identify the system, version, use context, risk, decision or incident that the record needs to support before choosing what to log.

02

Preserve source, time and system context

Connect each relevant event to its origin, timestamp, system state, input/output context where appropriate and accountable actors so the record can be interpreted later.

03

Map retention to operator responsibility

Determine which provider or deployer records are under the organization’s control, the applicable retention rule and how integrity and authorized access will be maintained.

04

Connect logs to consequence and revalidation

When records reveal drift, risk, misuse, incident conditions or material change, route the signal to investigation, authority, corrective action and renewed governance rather than leaving it trapped in storage.

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COMMON QUESTIONS

Questions businesses are asking now.

What does Article 12 of the EU AI Act require?

Article 12 requires high-risk AI systems to technically allow automatic recording of events over the system lifetime. The logging capability must support the traceability and monitoring purposes described in the applicable provision.

How long must EU AI Act logs be kept?

Retention depends on the actor and applicable provision. The Regulation contains specific provider and deployer record-retention duties, including deployer retention of automatically generated logs under their control for an appropriate period and at least six months unless other applicable Union or national law provides otherwise. Check the current consolidated text for the exact case.

Are logs the same as technical documentation?

No. Logs are operational records of events. Technical documentation is a broader evidence package describing the system and its compliance-relevant characteristics. They should connect, but one does not replace the other.

Do deployers have to retain high-risk AI logs?

Article 26 contains a deployer duty concerning logs automatically generated by a high-risk AI system to the extent those logs are under the deployer’s control, subject to the applicable retention conditions and other law.

Why does provenance matter for AI logs?

Without provenance, a reviewer may not be able to establish where a record came from, which system version generated it, whether it was altered, or what operational context it represented. Those relationships affect whether the record can support a consequential conclusion.

Can TA-14 serve as our statutory logging system?

TA-14 can structure evidence records, provenance, chronology, accountable action, gaps and revalidation state. Whether a particular implementation satisfies a statutory technical logging or retention requirement depends on the system, actor, applicable provision and technical architecture.

EU AI ACT WORLD · TA-14 AUTHORITY GOVERNANCE INSTITUTION

Understand the requirement. Preserve the evidence. Revalidate when reality changes.

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