When the EU AI Act comes into force in August 2026, Article 12 will become one of the most technically demanding requirements for high-risk AI systems. It's also one of the most misunderstood.
Most compliance platforms treat Article 12 as a documentation exercise—generate some logs, store them somewhere, produce a report when asked. This approach will fail the first serious audit.
What Article 12 Actually Says
Article 12 requires that high-risk AI systems "allow for the automatic recording of events ('logs') while the system is operating." The key word is 'automatic.' Not 'documented after the fact.' Not 'reconstructed from memory.' Automatic.
The regulation specifies that logs must capture: the period of each use, the reference database against which input data was checked, input data for which the search led to a match, and the identification of natural persons involved in verification of results.
Why Documentation Platforms Fall Short
Documentation platforms excel at producing impressive compliance reports. They can generate Annex IV technical documentation, create human-readable summaries, and organize information into auditor-friendly formats.
But they have a fundamental limitation: they document what you tell them, not what actually happened. If your AI system makes a decision at 2:47 AM on a Sunday, a documentation platform can't capture it unless something else already recorded that event.
The Infrastructure Requirement
Article 12 compliance requires infrastructure that sits between your AI systems and the outside world—capturing every prediction, every input, every decision, every outcome. Not sampling. Not best-effort. Every event.
This infrastructure must be provider-independent. If you're using Claude today and GPT-4 tomorrow, your logging can't depend on either provider's cooperation. It must work regardless of which model made the decision.
- 99.8%+ capture rate with cryptographic verification
- Immutable storage that can't be retroactively modified
- Provider-independent operation across any AI model
- Real-time logging, not batch processing after the fact
- Complete chain of custody from input to output
What Auditors Will Actually Check
Conformity Assessment Bodies won't accept a report that says "we log everything." They'll ask for evidence. Show me the logs from last Tuesday. Prove this decision was made by this model with this input. Demonstrate that the log couldn't have been modified after the fact.
Infrastructure-level compliance provides these answers automatically. Documentation-level compliance requires you to scramble.
The August 2026 Timeline
Six months before the deadline is not the time to discover your compliance approach won't survive an audit. Organizations deploying high-risk AI systems should be implementing capture infrastructure now—while there's still time to identify gaps and prove the system works.
CleanAim® provides the infrastructure layer that makes Article 12 compliance automatic. Every AI decision captured. Every event logged. Every audit answered with evidence, not explanations.