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Article 12 — Record-Keeping

Article 12 requires high-risk AI systems to allow automatic recording of events (logs) over their lifetime, enabling traceability of system functioning throughout its lifecycle.

Art. 12(1)

Automatic recording of events (logs) over system lifetime

Artifacts: ARCH.md, MONITORING_PLAN.md, DEPLOYER_GUIDE.md

AI Attest itself is an event-sourced system — every action produces an immutable, hash-chained event. The engine’s own audit chain demonstrates the record-keeping pattern. Architecture and monitoring artifacts must document how the AI system implements logging.

Art. 12(2)

Logging must enable monitoring of system operation and post-market monitoring

Artifacts: MONITORING_PLAN.md §8

The monitoring infrastructure section documents log collection, storage, and analysis capabilities. It must specify what events are logged, retention periods, and how logs feed into monitoring dashboards.

Art. 12(3)

Traceability appropriate to intended purpose

Artifacts: ARCH.md, DEPLOY.md

Architecture documents the system’s logging architecture. The deployment plan specifies logging configuration including what is logged, what is excluded (PII), and retention schedules.

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