EU AI Act Logging Requirements
Article 12 of the EU AI Act mandates automatic, tamper-evident logging for all high-risk AI systems. These requirements apply from August 2026. Synthetic data certification is a direct mechanism for satisfying the training data documentation requirement.
What Article 12 Requires
Article 12 of the EU AI Act requires that high-risk AI systems automatically generate logs capturing the operating periods, reference database, input data, and any foreseeable circumstances that may affect system performance. These logs must be retained for a minimum period and be accessible to national competent authorities upon request.
The regulation distinguishes between logging at the system level (operator responsibility) and logging at the provider level (documentation of training datasets, algorithm choices, and evaluation benchmarks). Both layers must be tamper-evident and independently verifiable.
For AI systems that use synthetic training data, the logging requirement includes evidence that the data was generated synthetically and documentation of the generation process — precisely what a cryptographic certification artifact provides.
Training Data Logging Obligations
Documented origin and generation method for each training dataset used in the system.
A cryptographic hash (SHA-256 or equivalent) linking the exact dataset bytes to the log record.
ISO-8601 timestamp of dataset creation, included in a tamper-evident record.
The generation algorithm (e.g. CTGAN), version, and configuration parameters.
An Ed25519 digital signature from a certification authority binding the record to the data.
The log must be verifiable by any third party without requiring trust in the AI provider.
How CertifiedData Satisfies Article 12
CertifiedData acts as a certificate authority for AI datasets. When a synthetic dataset is generated, the platform computes a SHA-256 fingerprint of the output, signs it with an Ed25519 private key, and issues a structured certification artifact containing the algorithm, timestamp, row count, and issuer identity.
The certificate is appended to a public transparency log — an append-only, hash-chained ledger of every certification event. This log is publicly verifiable without authentication, satisfying the EU AI Act requirement that audit records be independently verifiable by competent authorities.
Because the hash is cryptographically bound to the exact dataset bytes, any modification of the training data after certification would invalidate the hash — making the record tamper-evident by design, not policy.
Key Deadlines and Scope
| Obligation | Applies to |
|---|---|
| Article 12 logging | High-risk AI system providers and deployers |
| Article 19 record-keeping | Providers of high-risk AI systems (training data documentation) |
| Training data provenance | All AI systems using third-party or synthetic datasets |
| Public transparency log | Certification authorities and notarization services |