EU AI Act Article 12: automatic logging, and how to check it.
Article 12 has applied to high-risk AI systems since 2 August 2026. It requires automatic event logging over the system's lifetime, retained at least six months, sufficient to trace what the system did and why. Penalties reach €15,000,000 or 3% of worldwide annual turnover.
Below is a clause-by-clause map of what the Article asks for, what Runback supplies, and the command that verifies each claim. Where we supply nothing, the row says so — an obligation we do not help with is still yours, and a vendor page that blurs that becomes a liability for whoever relied on it.
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| Clause | What it requires | Who supplies it | Mechanism |
|---|---|---|---|
| Art. 12(1) | High-risk systems shall technically allow for the automatic recording of events (logs) over the lifetime of the system. | Runback supplies this | The SDK records every model call, tool call, and agent step from inside your process — automatic, not manual documentation. Capture is a single import, or OpenTelemetry if you already emit spans.npx @runback/verify <your-export>.json |
| Art. 12(2)(a) | Logs shall enable identification of situations that may result in the system presenting a risk, or a substantial modification. | Runback supplies this | Policy rules evaluate on every gated tool call and record the decision — allowed or blocked — as part of the run. A blocked action carries the rule that blocked it, so a risk situation is a queryable event rather than something inferred from prose.GET /api/compliance/report?from=…&to=… |
| Art. 12(2)(b) | Logs shall facilitate post-market monitoring (Art. 72). | Runback supplies this | Runs aggregate into a period report — volumes, error rates, policy evaluations and blocks, redaction counts — computed in the database rather than sampled, so the numbers in the report are the numbers in the data.GET /api/compliance/report |
| Art. 12(2)(c) | Logs shall enable monitoring of operation by deployers (Art. 26(5)). | Runback supplies this | Per-agent coverage reconciles the agents you declared against the ones actually reporting: declared but never instrumented, reporting then gone silent, or running while absent from your register.GET /api/app/coverage |
| Art. 12(3) | Logs shall include the period of each use, the reference database checked against, the input data, and the identity of the persons verifying results. | Partial — read the detail | Start and end timestamps, the exact inputs, retrieved context and tool results are captured per run. Human verification is captured where an approval gate is used. If your process has a reviewer step outside Runback, that identity is not in our record and you must record it yourself. |
| Art. 19 / 26(6) | Logs shall be kept for a period appropriate to the intended purpose, at least six months. | Runback supplies this | Retention is configured per plan and enforced by a scheduled sweep. Legal hold suspends deletion for runs under a preservation obligation, and if the holds table cannot be read the sweep is skipped rather than proceeding — the failure mode favours keeping data. |
| Art. 12 — implied | Logs must be reliable as evidence. The Act does not use the word 'tamper-proof', but a record that can be edited without anyone noticing is not evidence of anything. | Runback supplies this | Every run is hash-chained and signed; each org's runs are sealed into an append-only ledger with signed checkpoints. Checkpoints are additionally time-stamped by independent RFC 3161 authorities and published to a public append-only log — so the record is not merely signed by us, it is anchored outside our control.openssl ts -reply -in <checkpoint>.tsr -token_in -text |
| Art. 9, 11, 17 | Risk management system, technical documentation, quality management system. | Your obligation | Runback supplies evidence that feeds these; it does not produce them. A conformity assessment is an organisational process. Any vendor claiming to deliver Article 9 or 17 compliance as a product feature is overselling. |
No account. No Runback software beyond one npx command.
A compliance claim you cannot check is a marketing claim. Every statement above resolves to something you can run:
bash
# 1. Verify a record's integrity and origin — no account required
npx @runback/verify audit-export.json
# exit 0 = intact AND signed by our published key
# exit 2 = intact, but origin unproven
# exit 1 = a check failed
# 2. Check our published signing key out of band
curl https://runback.dev/.well-known/runback-audit-key.pem
# 3. Confirm a checkpoint was time-stamped by an authority we do not control
openssl ts -reply -in runback-checkpoint-4-freetsa.org.tsr -token_in -text
# 4. Read the public transparency log and archive it
curl https://runback.dev/api/transparencySteps 2–4 use no Runback software at all. That is deliberate: an auditor should not have to run our verifier to check our tamper-evidence.
What this page does not claim.
- No regulator certifies a file format. Whether your deployment satisfies Article 12 is a determination for your assessor. What we supply is the evidence that argument needs.
- The harmonised standards are not final. ISO/IEC 24970 (AI system logging) is at FDIS and prEN 18229-1 is at DIS ballot. Nobody can claim conformance to an unpublished standard, including us. We track both and will publish a clause map when they land.
- Runback is not certified. No SOC 2 report, no ISO 42001, no third-party penetration test yet. The security page states exactly what is shipped and what is not.
- Article 12 is one clause. Articles 9, 11 and 17 are organisational processes. Evidence helps; it is not the same thing.