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Regulation Tracker / EU AI Act / Chapter III · Section 2

Article 12
Record-keeping

Chapter III — Classification rules for high-risk AI systems, Section 2 — Compliance with the requirements. 3 distinct duties, powers or definitions are coded from this article, applying from 2027-12-02. 2 reach legal practice directly.

official text: EUR-Lex (consolidated 27 Jul 2026) · text © European Union (Decision 2011/833/EU) · coding CC BY 4.0 · data: obligations.json · Hugging Face · GitHub

The text

1. High-risk AI systems shall technically allow for the automatic recording of events (logs) over the lifetime of the system.

2. 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:

  1. (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;
  2. (b)facilitating the post-market monitoring referred to in Article 72; and
  3. (c)monitoring the operation of high-risk AI systems referred to in Article 26(5).

3. For high-risk AI systems referred to in point 1 (a), of Annex III, the logging capabilities shall provide, at a minimum:

  1. (a)recording of the period of each use of the system (start date and time and end date and time of each use);
  2. (b)the reference database against which input data has been checked by the system;
  3. (c)the input data for which the search has led to a match;
  4. (d)the identification of the natural persons involved in the verification of the results, as referred to in Article 14(5).

What it requires, coded

SafeLegalAI's reading of each duty in this article: who, what, from when, under which fine tier, and whether it reaches a firm, chambers, court or legal-AI vendor. Descriptive, not advice; the quoted words are the Regulation's.

  1. Art. 12(1)Record keepingHigh-risklegal practice

    High-risk AI systems must technically allow automatic recording of events over the lifetime of the system.

    "High-risk AI systems shall technically allow for the automatic recording of events (logs) over the lifetime of the system."
    Who
    Provider
    From
    (Regulation (EU) 2026/1744 (Digital Omnibus on AI), Art. 1(40), amending Art. 113(c)(i): Art. 6(2)/Annex III high-risk)As enacted in 2024: (Art. 113 second subparagraph); deferred by Regulation (EU) 2026/1744 (Digital Omnibus on AI).Art. 111(2): high-risk AI systems placed on the market or put into service before 2026-08-02 are covered only if they are subject to significant design changes from that date; providers and deployers of high-risk AI systems intended for public authorities must take necessary steps to comply by 2030-08-02. Art. 113(c) separately applies Article 6(1) and corresponding obligations from 2027-08-02. Date deferred by Regulation (EU) 2026/1744 (in force 27 July 2026); as enacted: 2026-08-02 (Art. 113 second subparagraph).
    Fine tier
    Art. 99(4)
    Legal practice
    Reaches legal practice directly — Important for legal-AI vendors and deployers because logs support traceability, audits, complaints and incident analysis.
    See
    Art. 16(a) · Art. 26(6) · Annex III point 8

  2. Art. 12(2)Record keepingHigh-risklegal practice

    Logging capabilities must enable recording of events relevant to risk or substantial modification, post-market monitoring and deployer monitoring under Article 26(5).

    "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:"
    Who
    Provider
    From
    (Regulation (EU) 2026/1744 (Digital Omnibus on AI), Art. 1(40), amending Art. 113(c)(i): Art. 6(2)/Annex III high-risk)As enacted in 2024: (Art. 113 second subparagraph); deferred by Regulation (EU) 2026/1744 (Digital Omnibus on AI).Art. 111(2): high-risk AI systems placed on the market or put into service before 2026-08-02 are covered only if they are subject to significant design changes from that date; providers and deployers of high-risk AI systems intended for public authorities must take necessary steps to comply by 2030-08-02. Art. 113(c) separately applies Article 6(1) and corresponding obligations from 2027-08-02. Date deferred by Regulation (EU) 2026/1744 (in force 27 July 2026); as enacted: 2026-08-02 (Art. 113 second subparagraph).
    Fine tier
    Art. 99(4)
    Legal practice
    Reaches legal practice directly — Logs are central for law firms or courts to monitor high-risk legal AI and for vendors to support post-market obligations.
    See
    Art. 26(5) · Art. 72 · Art. 79(1)

  3. Art. 12(3)Record keepingHigh-risk

    For Annex III point 1(a) high-risk biometric systems, logs must at least record use periods, reference databases, matched input data and persons verifying results.

    "For high-risk AI systems referred to in point 1 (a), of Annex III, the logging capabilities shall provide, at a minimum:"
    Who
    Provider
    From
    (Regulation (EU) 2026/1744 (Digital Omnibus on AI), Art. 1(40), amending Art. 113(c)(i): Art. 6(2)/Annex III high-risk)As enacted in 2024: (Art. 113 second subparagraph); deferred by Regulation (EU) 2026/1744 (Digital Omnibus on AI).Art. 111(2): high-risk AI systems placed on the market or put into service before 2026-08-02 are covered only if they are subject to significant design changes from that date; providers and deployers of high-risk AI systems intended for public authorities must take necessary steps to comply by 2030-08-02. Art. 113(c) separately applies Article 6(1) and corresponding obligations from 2027-08-02. Date deferred by Regulation (EU) 2026/1744 (in force 27 July 2026); as enacted: 2026-08-02 (Art. 113 second subparagraph).
    Fine tier
    Art. 99(4)
    Legal practice
    Reaches legal-AI vendors or public bodies — Relevant to court or public-authority review of biometric identification systems, less direct to ordinary law-firm legal AI.
    See
    Annex III point 1(a) · Art. 14(5)

Cite

Regulation (EU) 2024/1689, Article 12 (Record-keeping), as amended by Regulation (EU) 2026/1744, consolidated text of 27 July 2026, https://eur-lex.europa.eu/eli/reg/2024/1689/2026-07-27/eng#art_12 — text © European Union; only the Official Journal is authentic. Coding: SafeLegalAI (published by Cognesio LLP), "EU AI Act, structured", safelegalai.com/regulation/eu-ai-act/article-12, accessed 2026-09-08, CC BY 4.0.