EU AI Act · Regulation (EU) 2024/1689

The independently verifiable audit trail for AI.

Cryptographically signed, Bitcoin-anchored, and mapped to Articles 12 & 19 of the EU AI Act. The record-keeping evidence your auditor can verify — without trusting the vendor who produced it.

Article 12 requires automatic logging over an AI system's lifetime. ArmoredLedger makes those logs provable to a third party — not just present in your database.

Your AI compliance rests on logs. Your logs rest on "trust us."

The EU AI Act turns record-keeping into a legal obligation: high-risk systems must log their operation (Article 12), and those logs must be kept for auditors and market-surveillance authorities (Article 19). But a log that lives only in your vendor's database is a log they can edit, back-date, or lose — and one an auditor has no independent way to trust. When a regulator asks you to prove what your AI did and when, "here's our export" is an assertion, not evidence.

ArmoredLedger is the integrity layer that sits beneath your record-keeping. It doesn't replace your governance suite — it makes the audit trail underneath it independently verifiable.

Every AI-governance suite ends its audit story with "trust our database." ArmoredLedger ends it with the Bitcoin blockchain.

Governance platforms give you a self-attested "system of record" — a log inside an application database that you, and only you, can vouch for. ArmoredLedger anchors each day's records into the public Bitcoin blockchain via OpenTimestamps. An auditor can verify a record's signature and its Merkle inclusion against a chain no vendor owns — offline, with no access to our systems, and even if we disappear tomorrow.

This gap is the market's own admission: in 2024, IBM had to partner with Casper Labs to bolt blockchain onto watsonx.governance for the "tamper-resistant, time-synched" AI records it couldn't produce natively. Public-blockchain anchoring isn't a feature the governance suites have — it's one they reach outside for.

Trust no one. Verify everyone.

Self-attested log vs. independently verifiable record

The difference an auditor actually cares about.

A governance suite's "system of record"

  • Log lives in the vendor's application database
  • Integrity is asserted by the vendor, not proven
  • Timestamps come from a clock the vendor controls
  • Verification requires access to (and trust in) the vendor
  • If the vendor disappears, the evidence goes with them

ArmoredLedger's anchored record

  • Each record is content-addressed and hash-chained
  • Each attestation is cryptographically signed and checked against published trust anchors
  • Daily Merkle roots are anchored into Bitcoin via OpenTimestamps
  • Anyone verifies signature + inclusion + anchor in a browser, offline
  • Proof survives the vendor — the anchor is on a public chain

Mapped to the Articles your auditor cites.

ArmoredLedger is an audit-trail and record-integrity layer. It supports the record-keeping and traceability obligations below — it is not a full governance suite, and it doesn't claim to be.

ArticleObligationHow ArmoredLedger supports it
Art. 12 Record-keeping — automatic logging of events over the system's lifetime The ai-action-v1 schema records operational AI events — tool calls, content generation, code changes — with input and output digests, outcome, and model, under fail-closed authority binding. Signed and hash-chained so the log itself is tamper-evident.
Art. 19 Log retention — keep automatically generated logs (≥ 6 months) Records are retained in the hosted ledger for your plan's retention window, and their Bitcoin anchor makes the proof-of-existence permanent — verifiable long after the raw rows age out.
Art. 26(6) Deployer obligations — deployers keep logs under their control Deployers emit their own attestations to a private trust anchor, giving them an independently verifiable copy of the logs they are obligated to keep.
Art. 50 Transparency — disclosure and labelling of AI-generated content Content-generation events carry the input/output digest and model in the signed record, producing durable, verifiable evidence of what was AI-generated and when.
Art. 11 · Annex IV Technical documentation kept up to date Signed provenance for software releases and model/pipeline changes gives your technical documentation an anchored, tamper-evident change history.

Honest framing. ArmoredLedger provides the tamper-evident record that supports these obligations; it is not itself a certification, and using it does not by itself make an AI system "EU AI Act compliant." The operational-logging SDK (ai-action-v1) exists and enables Article 12 logging, but is not yet wired into live products — this is the integrity layer for AI records, not a claim that we log your model's every decision today. The signed, enforced path (/v1/attest) is distinct from the unsigned developer path (/v1/attestations); only signed records are presented as proof of authorship. The declared principal ("who acted") is emitter-asserted — ArmoredLedger proves the record is signed, anchored, and unaltered, not which human was at the keyboard. Signing uses a FIPS 140-2 Level 3 HSM; it is not a CMVP-certified module. Records are tamper-evident between anchor intervals.

The deadline moved. The lead time didn't.

The EU's Digital Omnibus deferred the high-risk obligations — including Articles 12 and 19 — from August 2026 to 2 December 2027 (Annex III systems; Annex I-embedded systems follow in August 2028). That's runway, not reprieve: traceability is the one obligation you can't retrofit after the fact, and general-purpose AI (GPAI) obligations have already been in force since August 2025.

Aug 2025 · in force

GPAI obligations live

General-purpose AI model obligations already apply. Provenance for model and pipeline releases is due now, not later.

2 Dec 2027

High-risk record-keeping

Articles 12 & 19 apply to Annex III high-risk systems. Article 12 logging must cover the system's lifetime — you can't backfill a log you never kept.

Aug 2028

Embedded high-risk

High-risk AI embedded in Annex I regulated products reaches its obligation date. Same traceability requirement, longer product cycles.

Article 12 requires logs that cover a system's operating life. Because you cannot reconstruct a traceable, anchored history retroactively, the practical lead time for record-keeping is longest — it starts the day the system goes live, not the day the obligation bites.

Four steps. Zero trust required.

The same integrity model, applied to your AI records.

01 · Record

Content-addressed

Every AI event is hash-chained — what happened, the input/output digests, the model, the outcome, on whose declared authority.

02 · Sign

Trust-anchored

Each attestation is signed (Ed25519 / HSM P-384) and verified against published trust anchors.

03 · Anchor

To Bitcoin

Every day the Merkle root is timestamped into Bitcoin via OpenTimestamps — a clock no one owns.

04 · Verify

Anywhere

Your auditor checks any record in-browser: signature, inclusion, anchor. No login. No faith in us.

Give your auditor proof, not a promise.

The integrity layer for AI record-keeping under the EU AI Act — signed, Bitcoin-anchored, and verifiable by anyone. Slot it beneath the governance suite you already run.