EU AI Act Article 12: What It Actually Says
Article 12 is short, dense, and quietly reshapes how you build. A plain-English walkthrough for engineers shipping high-risk AI.
Article 12 of the EU AI Act requires providers of high-risk AI systems to enable "automatic recording of events" — logs — throughout the lifetime of the system.
The three obligations
1. Traceability. Every relevant event must be recorded automatically, without operator intervention. 2. Retention. Logs must be kept for the lifetime of the system, appropriate to its intended purpose. 3. Post-market monitoring. Providers must use the logs to detect risks and non-conformities as the system runs.
What "automatic" means in practice
Not "we ask engineers to log it." Automatic means the recording is a property of the system, not of the operator's discipline. If disabling the log requires code changes and leaves an audit trail of its own, you are close.
Where teams underestimate the scope
Most teams focus on model outputs. Article 12 is broader: inputs, model versioning, human-in-the-loop actions, and system-state changes are all "relevant events" depending on the workflow.