What the Article requires
Article 12 requires high-risk AI systems to technically record events relevant to identifying situations where the system could present risks, to facilitating post-market monitoring, and to enabling subsequent monitoring of operation. The logs must be retained appropriately considering intended purpose. For some applications (e.g., biometric identification) specific log content is mandated. The record-keeping must be designed into the system, not bolted on as an afterthought.
In engineering terms
Implies an observability substrate — Langfuse self-hosted or equivalent — that captures every inference, every decision, every escalation. Most customers log enough but few log in a format that survives audit review. The critical engineering controls: content-addressed audit storage (immutable, replayable by hash), structured event schemas (not free-form JSON dumps), and SIEM integration so the audit trail is part of the existing operational fabric.
Compliance checklist
- ✓Auto-generated event logs from the AI system
- ✓Log retention period defined and implemented
- ✓Tamper-evident or content-addressed log storage
- ✓SIEM integration for the operational audit trail
- ✓Replay capability for any historical decision
Terms used here
All Articles in the reference · The EU AI Act compliance architecture
Get the Article 12 checklist as a fill-in template
The EU AI Act Readiness Kit puts this checklist, and the other 13 Articles', into one fill-in PDF with room for an owner, evidence location and target date on every item. Plus an AI system inventory, a classification record, an Annex IV outline and a FRIA template.
- 01How to use this kit. Four steps, and which checklists apply to each classification result.
- 02AI system inventory. One row per AI system: owner, what it does, built or bought, your role and its classification.
- 03Classification record. The five questions from our applicability checker, with space for answers, notes and the result.
- 04Evidence checklists. 72 evidence items across Articles 9 to 15, 25, 26, 27, 50, 53, 55 and 72, each with an owner, evidence location and target date.
Need audit-survivable evidence for Article 12?
MindMap runs a 90-day path from standing start to audit-survivable evidence. Talk to the engineering team.