eu ai act
EU AI Act record-keeping, ready by December 2027
The EU AI Act requires high-risk AI systems to keep automatic logs of their operation (Article 12), monitor performance after deployment (Article 72), and document changes to the system over its lifetime. For standalone Annex III systems — hiring tools, credit scoring, insurance pricing, and more — these obligations apply from 2 December 2027.
The timeline
-
29 June 2026
The EU formally adopts the Digital Omnibus, fixing the current high-risk timeline.
-
2 August 2026
Article 50 transparency duties apply — users must be told when they interact with AI.
-
2 December 2027
High-risk obligations apply to standalone Annex III systems: record-keeping, post-market monitoring, documented change management.
-
2 August 2028
High-risk obligations extend to AI embedded in regulated products.
A builder's summary, not legal advice. Dates reflect the Digital Omnibus as adopted 29 June 2026.
The deferral is a procurement window, not a reprieve
Sixteen extra months sounds like relief. In practice it means every EU-exposed deployer of high-risk AI spends 2026–27 standing up record-keeping, post-market monitoring, and documented change control — and choosing the systems that will do it.
The sleeper clause: substantial modification
Systems already on the market are grandfathered — until they undergo a "substantial modification." A system you continuously improve is a system that will eventually cross that line. If your AI gets better every month, documented change control isn't optional; it's the price of improving.
What the obligations look like in practice
- Record-keeping. Automatic logs of each period of use, tied to the decisions the system made. The Tail records every decision with inputs, context, output, and outcome — signed and append-only. How the Tail works.
- Post-market monitoring. Evidence you're watching live performance, not just pre-deployment tests. Continuous evaluators score real traffic against your own standards and cluster failures into tracked issues. The loop.
- Documented change management. Who changed what, why, and with what effect. Every Looptail patch carries its motivating evidence, replay results, and approval — automatically.
Start now, calmly
A first trail takes 10 minutes. Evidence-grade record-keeping across your production systems takes about a week. That leaves you the rest of the window for the part only you can do: deciding what your standards are.