{"answer_id":"praxikon:eu:ai-act:answer:logs-bewaren","canonical_page":"https://www.praxikon.com/en/antwoord/logs-bewaren","query":"Do we have to keep logs of our AI system?","lang":"en","view":"full","mode":"scenario","question":"Do we have to keep logs of our AI system?","situation":"You want to know which events your high-risk AI system must record automatically, and how long you keep that record.","likely_role":"Provider (you place the system on the market)","note":"Logging is not a standalone IT measure but the evidence layer under everything else: without records you cannot reconstruct afterwards what happened, and therefore cannot substantiate an incident report or a complaint.","matched_terms":[],"dataset":{"id":"praxikon:sys:registry:dataset:ai-act-implementation-graph","version":"2.2.0","schema_version":"1.5.0","effective_at":"2026-08-08T00:00:00.000Z","known_at":"2026-09-06T00:00:00.000Z","last_reviewed_at":"2026-08-08T00:00:00.000Z","licence":"https://www.praxikon.com/nl/legal/terms","canonical_url":"https://www.praxikon.com/api/v1/entities"},"obligations":[{"slug":"article-12-logging","label":"Article 12: logging and traceability","summary":"Automatic recording of events over the lifetime of a high-risk AI system.","legal_status":"upcoming","deadline_at":"2027-12-02T00:00:00.000Z","high_risk_regime_from":null,"human_page":"https://www.praxikon.com/en/verplichtingen/article-12-logging","api":"https://www.praxikon.com/api/v1/obligations?lang=en","official_source":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","citations":[{"kind":"official_fact","statement":"Article 12 requires high-risk AI systems to be technically capable of automatically recording events over their lifetime, for traceability, risk signalling and post-market monitoring; Article 19 and Article 26(6) govern log retention.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 12, Article 19 and Article 26(6)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"official_fact","statement":"For the Annex III route this requirement applies from 2 December 2027; for high-risk AI in regulated products (Annex I) from 2 August 2028.","source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Amended Article 113 application dates","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"},{"kind":"editorial_interpretation","statement":"Logging is the backbone of all other evidence: without logs an incident cannot be reconstructed and a monitoring duty cannot be fulfilled. Buyers should already test whether a system is technically capable of this.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 12, Article 19 and Article 26(6)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"recommended_action","statement":"Include logging capability and log access as a requirement in every AI purchase and assign the retention regime (who, where, how long) per system.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 12, Article 19 and Article 26(6)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"}]},{"slug":"annex-iii-high-risk","label":"Annex III: high-risk AI","summary":"Classification route for standalone high-risk AI systems under Article 6(2) and Annex III.","legal_status":"upcoming","deadline_at":"2027-12-02T00:00:00.000Z","high_risk_regime_from":null,"human_page":"https://www.praxikon.com/en/verplichtingen/annex-iii-high-risk","api":"https://www.praxikon.com/api/v1/obligations?lang=en","official_source":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","citations":[{"kind":"official_fact","statement":"The core rules in Chapter III, Sections 1 to 3, for systems under Article 6(2) and Annex III become applicable on 2 December 2027.","source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Amended Article 113, Article 6(2) and Annex III application date","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"},{"kind":"editorial_interpretation","statement":"The later application date does not remove the classification question. An early classification record avoids design and procurement decisions without evidence.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 6 and Annex III","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"recommended_action","statement":"Document now the intended purpose, Annex III point, Article 6(3) assessment, profiling and selected registration path.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 6(2)-(4), Article 49 and Annex III","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"}]},{"slug":"article-72-post-market-monitoring","label":"Article 72: post-market monitoring","summary":"Systematic monitoring of high-risk AI in real use, after market placement.","legal_status":"applicable","deadline_at":"2026-08-02T00:00:00.000Z","high_risk_regime_from":"2027-12-02T00:00:00.000Z","human_page":"https://www.praxikon.com/en/verplichtingen/article-72-post-market-monitoring","api":"https://www.praxikon.com/api/v1/obligations?lang=en","official_source":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","citations":[{"kind":"official_fact","statement":"Article 72 obliges providers to operate a post-market monitoring system with a plan forming part of the technical documentation, collecting relevant real-world data to evaluate continued compliance with Section 2.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 72(1)-(4)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"official_fact","statement":"This provision is named in none of the three points of Article 113, third paragraph, and therefore falls under the general application date in the second paragraph: 2 August 2026. The move to 2 December 2027 and 2 August 2028 in point (c) concerns only Chapter III, Sections 1, 2 and 3, with the exception of Article 6(5). When a high-risk AI system that this provision addresses can practically exist is a second question: through Article 6(2) and Annex III that is 2 December 2027, and through Article 6(1) and Annex I 2 August 2028. That practical date sits in high_risk_regime_from and not in deadline_at. This is how decision D1 of 6 September 2026 is recorded; see data/ai-act/review/decision-d1-application-dates.json.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 113, second paragraph","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"official_fact","statement":"This provision is named in none of the three points of Article 113, third paragraph, and therefore falls under the general application date in the second paragraph: 2 August 2026. The move to 2 December 2027 and 2 August 2028 in point (c) concerns only Chapter III, Sections 1, 2 and 3, with the exception of Article 6(5). When a high-risk AI system that this provision addresses can practically exist is a second question: through Article 6(2) and Annex III that is 2 December 2027, and through Article 6(1) and Annex I 2 August 2028. That practical date sits in high_risk_regime_from and not in deadline_at. This is how decision D1 of 6 September 2026 is recorded; see data/ai-act/review/decision-d1-application-dates.json.","source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Article 1, point (40)(b), replacing Article 113, third paragraph, point (c)","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"},{"kind":"editorial_interpretation","statement":"Compliance does not stop at go-live: this article turns compliance into a continuous state. For deployers it is also the basis to force suppliers to act on deviations.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 72(1)-(4)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"recommended_action","statement":"Design the monitoring together with the Article 12 logging: the same data flows feed both duties.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 72(1)-(4)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"}]},{"slug":"article-73-incident-reporting","label":"Article 73: serious incident reporting","summary":"The duty to report serious incidents with high-risk AI, under strict deadlines.","legal_status":"applicable","deadline_at":"2026-08-02T00:00:00.000Z","high_risk_regime_from":"2027-12-02T00:00:00.000Z","human_page":"https://www.praxikon.com/en/verplichtingen/article-73-incident-reporting","api":"https://www.praxikon.com/api/v1/obligations?lang=en","official_source":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","citations":[{"kind":"official_fact","statement":"Article 73 obliges providers to report serious incidents to the market surveillance authority: immediately after establishing the causal link and at the latest within 15 days, shortened to 10 days in the event of death and to 2 days for widespread infringement or serious disruption of critical infrastructure. Deployers inform the provider without delay.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 73(1)-(11)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"official_fact","statement":"This provision is named in none of the three points of Article 113, third paragraph, and therefore falls under the general application date in the second paragraph: 2 August 2026. The move to 2 December 2027 and 2 August 2028 in point (c) concerns only Chapter III, Sections 1, 2 and 3, with the exception of Article 6(5). When a high-risk AI system that this provision addresses can practically exist is a second question: through Article 6(2) and Annex III that is 2 December 2027, and through Article 6(1) and Annex I 2 August 2028. That practical date sits in high_risk_regime_from and not in deadline_at. This is how decision D1 of 6 September 2026 is recorded; see data/ai-act/review/decision-d1-application-dates.json.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 113, second paragraph","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"official_fact","statement":"This provision is named in none of the three points of Article 113, third paragraph, and therefore falls under the general application date in the second paragraph: 2 August 2026. The move to 2 December 2027 and 2 August 2028 in point (c) concerns only Chapter III, Sections 1, 2 and 3, with the exception of Article 6(5). When a high-risk AI system that this provision addresses can practically exist is a second question: through Article 6(2) and Annex III that is 2 December 2027, and through Article 6(1) and Annex I 2 August 2028. That practical date sits in high_risk_regime_from and not in deadline_at. This is how decision D1 of 6 September 2026 is recorded; see data/ai-act/review/decision-d1-application-dates.json.","source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Article 1, point (40)(b), replacing Article 113, third paragraph, point (c)","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"},{"kind":"editorial_interpretation","statement":"The deadlines are too short to design the process during the incident: those who decide who reports at the first incident will not make 15 days, let alone 2. This is the GDPR breach playbook, but for AI.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 73(1)-(11)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"recommended_action","statement":"Connect the AI incident process to the existing breach and security process and add the AI-specific definitions and deadlines.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 73(1)-(11)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"}]},{"slug":"article-16-provider-obligations","label":"Article 16: the twelve duties of a provider of a high-risk AI system","summary":"Article 16 is the summary list of duties for providers: twelve points that route onward to the quality management system, the documentation, the logs, the conformity assessment, the EU declaration of conformity, the CE marking, the registration, corrective actions and accessibility requirements.","legal_status":"upcoming","deadline_at":"2027-12-02T00:00:00.000Z","high_risk_regime_from":null,"human_page":"https://www.praxikon.com/en/verplichtingen/article-16-provider-obligations","api":"https://www.praxikon.com/api/v1/obligations?lang=en","official_source":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","citations":[{"kind":"official_fact","statement":"Article 16 requires providers of high-risk AI systems to do twelve things. They must ensure their systems comply with the requirements of Chapter III, Section 2 (point (a)); indicate on the system or, where that is not possible, on its packaging or accompanying documentation, their name, registered trade name or registered trade mark and the address at which they can be contacted (point (b)); have a quality management system in place complying with Article 17 (point (c)); keep the documentation referred to in Article 18 (point (d)); keep the automatically generated logs referred to in Article 19 when under their control (point (e)); ensure the system undergoes the conformity assessment procedure referred to in Article 43 prior to being placed on the market or put into service (point (f)); draw up an EU declaration of conformity in accordance with Article 47 (point (g)); affix the CE marking in accordance with Article 48 (point (h)); comply with the registration obligations referred to in Article 49(1) (point (i)); take the necessary corrective actions and provide the information required under Article 20 (point (j)); upon a reasoned request of a national competent authority, demonstrate conformity with the requirements of Section 2 (point (k)); and ensure the system complies with the accessibility requirements of Directives (EU) 2016/2102 and (EU) 2019/882 (point (l)).","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 16(a)-(l)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"editorial_interpretation","statement":"Article 16 reads like a table of contents and is therefore often planned as a single roadmap line. It is twelve separate duties with widely differing lead times: building a quality management system takes months, affixing a CE marking takes a day. The bigger trap sits in Article 25(1): anyone who puts their own brand on an existing high-risk system, substantially modifies it, or changes the intended purpose of a non-high-risk system so that it becomes high-risk counts as a provider and inherits all twelve points without ever having built anything. In the branding scenario of point (a) this applies without prejudice to contractual arrangements stipulating that the obligations are otherwise allocated, but you must have made and be able to show those arrangements in advance. In practice this catches parties that white-label AI or apply a general-purpose model to an Annex III use case.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 16(a)-(l)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"recommended_action","statement":"First determine whether you are a provider or whether Article 25 makes you one, then work out the twelve points as twelve separate work packages with an owner and a date. Start with points (c) and (f), because they set the lead time of the whole track.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 16(a)-(l)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"}]}],"conditional":[{"slug":"article-61-informed-consent","id":"praxikon:eu:ai-act:obligation:article-61-informed-consent","label":"Article 61: informed consent of test subjects for testing in real world conditions","status":"possibly_applies","source_locator":"Article 60(4), point (i), with Article 61(1)","addressee":"reader","human_page":"https://www.praxikon.com/en/verplichtingen/article-61-informed-consent"}],"sources":[{"id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","title":"EU Artificial Intelligence Act 2024/1689","publisher":"European Parliament and Council","canonical_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj","source_version":"original-oj-2024-07-12","verified_at":"2026-08-08T00:00:00.000Z"},{"id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","title":"Digital Omnibus on AI 2026/1744","publisher":"European Parliament and Council","canonical_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj","source_version":"official-journal-2026-07-24","verified_at":"2026-08-08T00:00:00.000Z"},{"id":"praxikon:eu:ai-act:source:commission-draft-high-risk-classification-guidelines","title":"Draft guidelines on the classification of high-risk AI systems","publisher":"European Commission (AI Office)","canonical_url":"https://digital-strategy.ec.europa.eu/en/library/draft-commission-guidelines-classification-high-risk-ai-systems","eli":null,"source_version":"draft-for-consultation-2026-05-19","verified_at":"2026-08-08T00:00:00.000Z"},{"id":"praxikon:eu:ai-act:source:cen-cenelec-jtc21","title":"CEN-CENELEC JTC 21: European standards under standardisation request M/613","publisher":"CEN-CENELEC JTC 21","canonical_url":"https://www.cencenelec.eu/areas-of-work/cen-cenelec-topics/artificial-intelligence/","eli":null,"source_version":"work-programme-checked-2026-08-08","verified_at":"2026-08-08T00:00:00.000Z"}],"first_actions":[{"label":"Design logging into the system","summary":"Ensure the system automatically records events relevant to risk identification and post-market monitoring."},{"label":"Justify the Article 6(3) exception against each individual condition","summary":"Name which of the four Article 6(3) conditions you invoke, with facts, and separately justify why the system poses no significant risk of harm to health, safety or fundamental rights and does not materially influence the outcome of decision making."},{"label":"Draw up a post-market monitoring plan","summary":"Systematically collect and analyse real-world data on the system’s performance and compliance throughout its lifetime."}],"evidence":[{"label":"Logs and retention regime","summary":"Log files with a retention period appropriate to the purpose and at least six months for deployers (Articles 19 and 26).","url":null},{"label":"Article 49(2) registration record for the system assessed as not high-risk","summary":"Proof that the system for which you invoke the Article 6(3) exception is registered as Article 49(2) requires, with the registration number linked to the underlying assessment.","url":null},{"label":"Monitoring plan and reports","summary":"The plan as part of the technical documentation plus the periodic analyses and follow-up actions.","url":null}],"guidance":[{"label":"Article 6 has two separate routes to high-risk","statement":"The European Commission's draft guidelines on the classification of high-risk AI of 19 May 2026, which are expressly non-binding, state in paragraph (7) that an AI system is high-risk in two scenarios: first, where it is intended to be used as a safety component of a product, or is itself a product, covered by the Union harmonisation legislation listed in Annex I and required to undergo third-party conformity assessment; and second, where it falls within one of the use cases in the areas listed in Annex III. Paragraph (448) of those same draft guidelines notes that the Article 113 application dates have been postponed by the AI Omnibus to 2 December 2027 for the Article 6(2) route and 2 August 2028 for the Article 6(1) route.","source_locator":"Draft guidelines on high-risk AI classification (19 May 2026), General principles chapter, section II, paragraph (7); section V, paragraph (448)"},{"label":"Broadly positioned and general purpose AI systems: a disclaimer is not enough","statement":"According to the non-binding draft guidelines of 19 May 2026 on the classification of high-risk AI, paragraph (12) provides that where the instructions for use, contractual arrangements, terms of service, usage policy, promotional and sales materials or technical documentation present the AI system as broadly applicable across a generality of contexts and functions, and do not consistently limit its application or exclude high-risk uses, the system's intended purpose will be deemed to also encompass high-risk use cases and therefore qualify as high-risk. Under these draft guidelines this applies in particular where such uses are feasible and reasonably foreseeable given the system's functionalities and capabilities. The same paragraph states that merely asserting, for example in the terms of service, that high-risk uses are excluded is insufficient where the provider's overall presentation, examples or product positioning effectively provides for or promotes such uses, and that any limitations of use must be described clearly, concretely and coherently across all materials.","source_locator":"Draft guidelines on high-risk AI classification (19 May 2026), General principles chapter, section II.2, paragraph (12)"},{"label":"High-risk does not mean prohibited, and not high-risk does not mean permitted","statement":"The draft guidelines of 19 May 2026 on the classification of high-risk AI, which are not binding, state in paragraph (3) that the fact an AI system is listed as an example in these guidelines does not mean its use should automatically be considered lawful, since such use would still need to comply with other applicable legislation, and in paragraph (4) that the scope of these guidelines is limited to whether an AI system is high-risk or not. In the Annex III chapter of this draft, paragraph (68) states that classifying systems as high-risk under Article 6(2) does not mean their use is prohibited, but that those systems are subject to appropriate requirements. Paragraphs (82) and (83) of this draft explain the wording in so far as their use is permitted under relevant Union or national law and state that falling within a use case does not necessarily mean the system may lawfully be used in those cases, that in addition to the prohibitions other provisions of Union or national law may restrict use, and that under Article 2(9) the AI Act applies without prejudice to rules on consumer protection, product safety and data protection.","source_locator":"Draft guidelines on high-risk AI classification (19 May 2026), General principles chapter, paragraphs (3) and (4); Annex III chapter, paragraph (68) and section 2.6, paragraphs (82) and (83)"},{"label":"Split and agentic architectures are assessed as a whole","statement":"The non-binding draft guidelines of 19 May 2026 provide in paragraphs 75, 76 and 90 that where several AI systems form part of a more complex whole and their combined intended purpose or joint outputs materially influence an individual decision, that configuration is treated as a single AI system for classification. The draft expressly states that split architectures are assessed as a whole to prevent circumvention by system design, that exemptions for individual modules do not apply where the overall configuration influences key aspects of the decision, and that this also extends to complex interconnected setups such as agentic AI systems whose linked actions jointly serve a high-risk purpose. Under the same draft, strictly procedural or preparatory functions do remain eligible for exemption where they are genuinely separable from the system and do not structure or feed outputs that materially influence the examination of an individual case.","source_locator":"Section IV.2.3, paragraphs 75 and 76, and section IV.2.7.1 paragraph 90"}],"examples":[{"label":"Logging in admission and assessment: what the institution keeps in its own hands","situation":"A university of applied sciences uses a purchased AI system that ranks student admissions and also raises flags during digital assessment. The logs sit in the supplier environment, which hands them over on request. The teaching organisation wonders whether that settles the matter or whether the school retains a duty of its own.","outcome":"Article 12(1) requires a high-risk AI system to technically allow for the automatic recording of events (logs) over the lifetime of the system, and Article 12(2) ties that recording to a level of traceability appropriate to the intended purpose of the system. Article 26(6) provides that deployers keep the automatically generated logs to the extent those logs are under their control, for a period appropriate to the intended purpose, of at least six months, unless applicable Union or national law provides otherwise, in particular Union law on the protection of personal data. Article 19(1) places a corresponding retention duty on providers for the logs generated by their systems that are under their control, likewise for at least six months.","lesson":"On our reading, the fact that the supplier hosts the logs does not by itself place the school outside Article 26(6): what matters is whether the logs are under its control. The Regulation does not define that notion, and on our reading server location is not decisive in itself; the question is whether you can actually and contractually dispose of those logs, and it has to be answered for each procurement. So agree at procurement that the institution can request, export and itself retain the logs for the chosen period, and record which admission and assessment events that covers. Take data protection into account at the same time, because the same provision allows other Union or national law to cap the retention period.","source_locator":"Article 12(1) and (2), Article 19(1) and Article 26(6)","provenance":"editorial"},{"label":"Logging on the production line: which logs the manufacturer keeps and which the factory keeps","situation":"A manufacturer supplies an AI system that runs as a safety component inside the machinery of a production line and also drives quality control. The factory operating the line keeps only the alerts visible in the local controller; the rest of the recording flows to the supplier environment. The question is who has to keep which logs when it later has to be reconstructed why the line was halted.","outcome":"Article 12(1) requires high-risk AI systems to technically allow for the automatic recording of events (logs) over the lifetime of the system. Under Article 12(2), those logging capabilities must enable the recording of events relevant for identifying situations that may result in the system presenting a risk within the meaning of Article 79(1) or in a substantial modification, for facilitating the post-market monitoring referred to in Article 72, and for monitoring the operation of the high-risk AI systems referred to in Article 26(5). Article 19(1) obliges providers to keep those automatically generated logs to the extent they are under their control, for a period appropriate to the intended purpose of the system, of at least six months, unless applicable Union or national law provides otherwise. Article 26(6) places a corresponding retention duty on deployers for the logs under their control, with the same six-month floor.","lesson":"We read Article 19 together with Article 26(6) as leaving the manufacturer, acting here as the provider, and the factory, acting as the deployer, each with a retention duty of its own for the logs under its control. The Regulation does not say when logs count as being under your control, and on our reading the place where the recording physically lands does not settle that by itself; the question has to be answered system by system. For a production line that means recording which events stay in the machinery controller and which travel to the supplier, and securing access to that second set contractually before you need it. Leave that unarranged and you risk being unable to trace a line stoppage or a quality control rejection back to the behaviour of the system.","source_locator":"Article 12(1) and (2), Article 19(1) and Article 26(6)","provenance":"editorial"},{"label":"Logging in task allocation at work: evidence about the system or a file on the employee","situation":"An employer deploys an AI system that handles task allocation among staff and summarises their performance for the performance review. HR wants to know what record of those outcomes has to be retained when an employee objects months later to a promotion decision.","outcome":"Article 12(1) requires high-risk AI systems to technically allow for the automatic recording of events (logs) over the lifetime of the system. Article 12(2)(c) names, as one of the purposes of those logging capabilities, monitoring the operation of the systems referred to in Article 26(5), and that paragraph obliges deployers to monitor operation on the basis of the instructions for use and, where relevant, to inform the provider in accordance with Article 72. Article 26(6) obliges deployers to keep the automatically generated logs to the extent they are under their control, for a period appropriate to the intended purpose, of at least six months, unless applicable Union or national law provides otherwise. Article 19(1) sets out a corresponding retention duty for providers, with the same six-month floor.","lesson":"We read Article 12(2) as putting the logging capabilities there first of all to follow risks, substantial modifications and the operation of the system, not to sharpen judgements about individual staff. Whether that statement of purpose also limits what the retained logs may later be used for is something Article 12 does not say: on our reading that limit has to come from data protection law, to which Article 26(6) itself refers. For HR a practical line follows: keep what is needed to trace an outcome and to carry out the monitoring under Article 26(5), and settle in writing beforehand whether those same files may double as a performance record. Bear in mind that the six-month floor can be shorter than the period within which an employee challenges a promotion decision; the Regulation does not govern that evidential position.","source_locator":"Article 12(1) and (2)(c), Article 19(1) and Article 26(5) and (6)","provenance":"editorial"},{"label":"Candidate recommendation that automatically becomes a decision","situation":"An employer uses a system that ranks applicants and recommends a candidate to hire. In one setup a recruiter weighs that recommendation in their own assessment; in the other the outcome is applied automatically and a candidate is rejected without anyone looking at it.","outcome":"The Commission draft guidelines of 19 May 2026 address this case when determining whether an application falls under Annex III. The document is a consultation version: non-binding and not yet final.","lesson":"Assess a recruitment system on its intended purpose rather than on whether a recruiter reviews the output, because adding or removing human involvement does not change its high-risk classification.","source_locator":"Draft guidelines on high-risk AI classification, 19 May 2026, annex on Annex III","provenance":"official"}],"standards":[{"label":"prEN 18229-1: AI trustworthiness framework part 1, logging","summary":"The draft European standard for the automatic event recording that Article 12 requires of high-risk AI systems.","statement":"prEN 18229-1 (AI trustworthiness framework, Part 1: Logging) is the JTC 21 deliverable under M/613 for Article 12 of the AI Act: high-risk AI systems must technically allow for the automatic recording of events over their lifetime. As at June 2026 the deliverable was at the Enquiry stage. It has not yet been published as an EN and is not cited in the Official Journal."}],"definitions":[],"answer_page":"https://www.praxikon.com/en/antwoord/logs-bewaren","follow_up_questions":[{"question":"How do we monitor our AI system after it goes live?","url":"https://www.praxikon.com/en/antwoord/monitoring-na-livegang"},{"question":"We build an AI product for customers. What are a provider’s duties?","url":"https://www.praxikon.com/en/antwoord/ai-product-bouwen"},{"question":"Can we test our AI system before it goes to market?","url":"https://www.praxikon.com/en/antwoord/testomgeving-en-praktijktest"}],"disclaimer":"General interpretation, not legal advice. The official source remains authoritative.","methodology":"https://www.praxikon.com/en/methodologie"}