ISO/IEC FDIS 42105 · stage 50.20 FDIS ballot closes 21 October 2026 Planning date 16 Feb 2027, our estimate Official record
OHISO 42105 Revision CheckerHuman oversight of AI systems, before publication

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EU AI Act, Article 12

Record-keeping and logs

Unit OH-42 in the Information theme. The held citation is EU AI Act, Article 12, and the row asks for 3 pieces of evidence.

At a glance

Ref
OH-42
Theme
Information
Held source
EU AI Act
Citation
EU AI Act, Article 12
Evidence
3 items
Gaps
2 common

Evidence to keep

  • Record-keeping and logsLogging capability design evidence
  • Record-keeping and logsA retention policy aligned with the intended purpose
  • Record-keeping and logsA sample reconstruction of a live decision

Questions before you sign

  • Can you reconstruct a decision from the log?
  • Is the human action recorded?
  • Does retention match the duty?

The requirement, in our words

High-risk systems must technically allow automatic recording of events over the lifetime of the system, with traceability appropriate to the intended purpose. For remote biometric identification, the log must include the period of use, the reference database, the input that led to a match and the people involved.

What it means for human oversight

The log is the audit trail of the oversight decision. It should let a reviewer reconstruct what the system produced, what the person did and when.

How to evidence it

Attach the artefacts above to the Record-keeping and logs row with the system name, the owner and the date. The first one is the anchor: Logging capability design evidence. The OH-42 file is complete when the named person can produce that artefact and explain the decision it records, without asking someone else where it is.

The reviewer will sample one live decision and ask for A retention policy aligned with the intended purpose. If that artefact for OH-42 cannot be produced, the row is a gap, whatever the policy says.

OH-42 carries 3 evidence items and 2 common gaps. For record-keeping and logs, keep the version the operator actually received with its date, because the current intranet copy is not evidence of what was in force. The OH-42 statement above is ours, written from EU AI Act, Article 12, not a reproduction of the licensed text.

Common gaps

  • Insufficient logging to reconstruct operation
  • Logs not retained over the lifetime
Where the FDIS fits. The public abstract says the draft applies to all types of organizations across the AI system life cycle, so record-keeping and logs is one of the places the guidance is expected to operate. For OH-42, the FDIS clause numbering and wording are not public, so this page cites EU AI Act, Article 12 above and does not quote the draft.

Related units

Source for this page: EU AI Act, Article 12. Open EU AI Act, Article 12 and compare it with the OH-42 statement above. Retrieved 2026-10-21.