Chapter III · High-risk AI systems
Article 12 — Record-keeping
Article 12 is the shortest requirement in Section 2 and the one the whole enforcement chain reads from. Three paragraphs: the system must be able to record events, the recording must serve three named purposes, and for one category of system — remote biometric identification — four things must be in the record as a minimum. Everything else about a log is written somewhere else. Who keeps it is in Articles 19 and 26(6). How long is in both, in the same undefined words. Whether the deployer is ever told what is logged is in Article 13(3)(f), conditionally. Who may demand it is in Article 74. Penalties are in Article 99(4)(a). Line those provisions up in order and one step is missing. Article 12 says the system must be able to record. Articles 19 and 26(6) say the provider and the deployer must keep the records the system makes. No article says anyone must turn the recording on. If nobody does, there is nothing to keep, and nothing has been breached?
Official text
Each paragraph records where its wording comes from. This site reproduces the text; the authentic publication is the Official Journal. Text checked as byte-identical to the Official Journal is marked as reproduced from it; consolidated text is editorial and has no legal value. Paragraphs, subparagraphs and points each have their own link.
High-risk AI systems shall technically allow for the automatic recording of events (logs) over the lifetime of the system.
Reproduced from the Official Journal · Regulation (EU) 2024/1689 · EN
In order to ensure a level of traceability of the functioning of a high-risk AI system that is appropriate to the intended purpose of the system, logging capabilities shall enable the recording of events relevant for:
- (a)
identifying situations that may result in the high-risk AI system presenting a risk within the meaning of Article 79(1) or in a substantial modification;
- (b)
facilitating the post-market monitoring referred to in Article 72; and
- (c)
monitoring the operation of high-risk AI systems referred to in Article 26(5).
Reproduced from the Official Journal · Regulation (EU) 2024/1689 · EN
For high-risk AI systems referred to in point 1 (a), of Annex III, the logging capabilities shall provide, at a minimum:
- (a)
recording of the period of each use of the system (start date and time and end date and time of each use);
- (b)
the reference database against which input data has been checked by the system;
- (c)
the input data for which the search has led to a match;
- (d)
the identification of the natural persons involved in the verification of the results, as referred to in Article 14(5).
Reproduced from the Official Journal · Regulation (EU) 2024/1689 · EN
The formal analysis of Article 12
Article 6 is formalised first. The remaining articles follow.
Article 12 is formalised node by node: each rule as a deontic position with its operator, each exception with its rank, each predicate resolved against the definitions in Article 3.
What members get, per article
- the rule logic: every norm as a formal position, with the defeater chain that decides which exception wins
- the competency questions and their answers, every unanswered one marked as a gap and named
- the ontology: predicates bound to AISV (AI Standardisation Vocabulary) and to the definitions they depend on, exportable as JSON-LD and OWL
- the documentation: the Article 6(4) assessment record generated from a fact set, with its derivation and the version of the law it was decided against
Built for providers claiming the 6(3) derogation, for the counsel who has to defend that claim, and for the auditor who reads it afterwards.
Access is invite-only and opening in stages. Article 6 is formalised first; the remaining articles follow.
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Commentary in preparation
The official text above is complete. The editorial layer for this article — duties, the roles bound by them, the AISV concepts that model them, and the European standards written to support them — is in preparation, in the same form as the articles already published.
See the published articles