EU AI Act Article 12 logging: what it requires and when

Article 12 of the EU AI Act requires certain AI systems to automatically record events (“logs”) over their lifetime. Here's the plain-language version — and the honest timeline.

What Article 12 asks for

For high-risk AI systems, Article 12 requires the technical capability to automatically record events (logs) across the system's lifetime, at a level of detail sufficient for traceability, risk identification, and post-market monitoring. Related provisions (Articles 19 / 26) generally require logs to be kept for at least six months, subject to applicable law.

The timeline — deferred, and stated honestly

The obligation was originally tied to 2 August 2026. It has since been deferred: the Digital Omnibus on AI (Regulation (EU) 2026/1744, adopted 8 July 2026, published in the Official Journal on 24 July 2026, in force) moves the high-risk obligations — Article 12 among them — to:

• 2 December 2027 for high-risk systems under Article 6(2) / Annex III;
• 2 August 2028 for high-risk systems under Article 6(1) / Annex I.

Sources

• Article 12 (record-keeping): artificialintelligenceact.eu/article/12
• Digital Omnibus deferral (Reg. (EU) 2026/1744): EUR-Lex

This is general information, not legal advice. Whether a system is “high-risk,” and which obligations apply, depends on the facts — consult a qualified professional.