WARRANTThe answer, in one paragraph.
There is no harmonised standard for EU AI Act Article 12. The European Commission's own standardisation page, last updated 1 July 2026, records that no harmonised standard for the AI Act has yet been referenced in the Official Journal of the European Union. Two documents are in progress and neither is finished. The obligation they will eventually help implement applies on 2 December 2027 for Annex III standalone high-risk systems, deferred from 2 August 2026 by Regulation (EU) 2026/1744.
Availability and citation are different events, and the difference is the whole subject of this entry. A European standard can be ratified, published and on sale and still confer nothing under the AI Act until its reference appears in the Official Journal. EN 18286:2026, on quality management systems, is the furthest-advanced AI Act standard there is: the CEN register records it as ratified on 12 July 2026 and available from 22 July 2026. Its national-adoption date of 31 October 2026 and national-publication date of 31 January 2027 are still ahead of it, and no Official Journal citation of it has been found. So the count of standards that currently produce a presumption of conformity for anything under this regulation is zero.
What follows is the verified status of each document, what an Official Journal citation would and would not buy, and why the deployer's duty to produce the record does not move regardless. The reading is written for the person who will hand these records to someone who does not trust them.
prEN 18229-1 · the European draft.
prEN 18229-1 is the CEN-CENELEC draft for logging. It belongs to CEN-CENELEC JTC 21, Working Group 4, whose remit is foundational and societal aspects, convened by Enrico Panai with AFNOR holding the secretariat. Its formal designation and title, as the document itself is registered:
Part 1 is scoped to logging alone. This matters because earlier descriptions of the document — including sources still circulating in mid-2026 — describe a Part 1 covering logging together with transparency and human oversight. That was accurate once. The series was restructured during 2026 into five parts, and the other subjects moved out of Part 1.
The current stage of Part 1 is Enquiry, stage 40.20, opened 28 May 2026 — the public-comment step. It is not at Formal Vote, not ratified, and not published. National mirror bodies carry the draft under their own numbers and their own comment windows, which is where the close dates diverge: the Bulgarian register shows the next stage, 40.60, falling on 6 August 2026; the Swedish body opened its comment period on 29 May 2026 to close 5 August 2026; the Dutch body published a 21-page national draft on 1 June 2026 with a national deadline of 30 July 2026. Those are national windows around one European Enquiry, not competing European deadlines.
One route matters for timing. On 23 October 2025 the CEN and CENELEC Technical Boards agreed that, on a positive Enquiry vote, JTC 21 drafts may proceed to direct publication without a separate Formal Vote, with Enquiry comments deferred to a later edition, in order to have standards available by the fourth quarter of 2026. Whether Part 1 specifically takes that route is not stated anywhere we could find. It is the difference between a document that could appear within months and one that takes another full ballot cycle.
What the draft asks a system to do is the same territory Article 12 covers line by line: automatic recording of events over the lifetime of the system, addressable for risk identification and post-market monitoring.
ISO/IEC 24970 · the international text, and its European twin.
ISO/IEC 24970, Artificial intelligence — AI system logging, is owned by ISO/IEC JTC 1/SC 42, the artificial-intelligence subcommittee. Edition 1, ICS 35.240.01. Its current catalogue designation is ISO/IEC FDIS 24970 — the final-draft stage — and its catalogue status is under development. The final text was registered for formal approval on 18 May 2026. It is not a published International Standard.
There are in fact three documents in this story, not two, and conflating them is the most common error in the material currently ranking on these queries. The ISO text is one. Its European adoption, prEN ISO/IEC 24970, is a second, carried through CEN by JTC 21 and standing at stage 45.99, dispatch of the Formal Vote draft, on 20 May 2026 — heading into a CEN Formal Vote rather than an Enquiry, which puts it at a different point in its life from prEN 18229-1 despite covering the same subject. prEN 18229-1 is a third and separate, CEN-native document. A national mirror published the European adoption as a 56-page draft in the German and English versions.
The distinction is not bookkeeping. Only a harmonised European standard cited in the Official Journal can produce a presumption of conformity under the AI Act. An ISO/IEC standard cannot, however good it is, because the mechanism in Article 40(1) does not reach it. Conformity with ISO/IEC 24970 is evidence a provider may put forward and an auditor may weigh. It is not a presumption, and a vendor describing it as one is describing something the regulation does not contain.
On retention the international text is explicit that logs are kept for legally mandated periods — which routes the question straight back to the law rather than answering it. The number lives in Article 19(1) for the provider and Article 26(6) for the deployer, at a floor of at least six months. No logging standard supplies that figure, and none is going to.
What an Official Journal citation would actually buy.
Article 40(1) is the operative clause, and its wording repays close reading:
Two limits sit inside that sentence. The first is the citation condition: the presumption attaches to standards whose references have been published in the Official Journal. Drafting, publishing, and being cited are three separate events, and only the third does anything here.
The second limit is the one almost nobody quotes. The presumption runs to Section 2 of Chapter III — the requirements for high-risk AI systems, Articles 8 to 15 — and to Chapter V for general-purpose models. Article 12 sits in Section 2, so a cited logging standard would indeed give a provider a presumption on the logging requirement. But the obligations of providers and deployers, Articles 16 to 27, sit in Section 3. Section 3 is outside Article 40(1) entirely.
| Provision | What it covers | Reached by Art 40(1)? |
|---|---|---|
| Art 12 | Automatic event recording over the lifetime of the system — Chapter III, Section 2 | YES |
| Art 15 | Accuracy, robustness and cybersecurity — Chapter III, Section 2 | YES |
| Art 16 | Obligations of providers of high-risk systems — Chapter III, Section 3 | NO |
| Art 19 | Provider log retention — Chapter III, Section 3 | NO |
| Art 26 | Obligations of deployers, including log retention — Chapter III, Section 3 | NO |
So the ceiling on what any logging standard can ever do for a deployer is fixed by where the deployer's duties live. A fully cited harmonised standard cannot give a deployer a presumption of conformity with Article 26, because Article 40(1) does not point at Section 3. This is not a drafting oversight to be fixed by a better standard. It is the architecture of the regulation.
If the standards stay late, Article 41 is the fallback. Its conditions are cumulative, joined by and: the standards must not have been delivered within the deadline set under Article 10(1) of Regulation (EU) No 1025/2012, and no Official Journal reference covering the Section 2 requirements has been published or is expected within a reasonable period.
The first condition is already satisfied. Commission Implementing Decision C(2025)3871 of 23 June 2025 — which repealed the original 2023 request rather than amending it — asked CEN and Cenelec to deliver by 31 August 2025. That date has passed. Its own recital 6 records that CEN and Cenelec had reported "significant delays" and that a new deadline was needed because the matters are technically complex and novel. The request expires on 28 February 2027. We found no evidence the Commission has invoked Article 41.
The date stopped depending on the standard, on purpose.
This is the part the "align later" advice leaves out. The question of whether the high-risk obligations should wait for the standards was put directly to the EU legislature, and the answer was no.
The Commission's proposal of November 2025 would have made application of the high-risk requirements conditional on the readiness of harmonised standards, common specifications or guidelines, with a long-stop date behind it. Under that design, a missing logging standard would genuinely have moved the deadline. That is the world the "wait for the standard" posture describes.
The final agreed text dropped it. Regulation (EU) 2026/1744 of 8 July 2026, published in the Official Journal on 24 July 2026 and in force from 27 July 2026, replaces Article 113(3)(c) with fixed calendar dates: 2 December 2027 for Article 6(2) and Annex III standalone high-risk systems, moved from 2 August 2026, and 2 August 2028 for Article 6(1) and Annex I. No readiness condition survives.
And the deferral was not granted in ignorance of the standards gap. Recital 40 of the same regulation names the delayed availability of standards, common specifications, and alternative guidance, together with the delayed establishment of national competent authorities, among the reasons the original timetable was jeopardised. The legislature looked straight at the missing standard, granted one extension, and then removed the mechanism that would have granted another automatically.
Read together with §04, the position is narrow and unhelpful to anyone selling delay. The date is fixed and does not track the standard. Article 41 exists precisely so that late standards do not become an excuse. And the deployer's own duties were never inside the presumption in the first place. Note also that Article 50 transparency runs on a separate track that the Omnibus did not defer, applying from 2 August 2026, with a Code of Practice already published.
The deployer's duty does not transfer.
A deployer reading vendor material about forthcoming standards can come away believing the record problem belongs to the provider. The text does not support that. Article 26 places duties on the deployer directly, and §04 established that those duties sit outside the reach of any harmonised standard's presumption.
The monitoring duty follows in Article 26(5): deployers shall monitor the operation of the high-risk AI system on the basis of the instructions for use and, where relevant, inform providers in accordance with Article 72. Where the system presents a risk within Article 79(1), the deployer must without undue delay inform the provider or distributor and the relevant market surveillance authority, and suspend use.
The record duty is one paragraph further on, in Article 26(6) — a distinction worth holding, since it is routinely attributed to 26(5):
The qualifier to the extent such logs are under their control is doing work, and not the work a deployer might hope. It does not excuse a deployer who arranged not to have control. In a managed-service deployment the export feed and the retention duty sit on different parties, so neither side holds the whole record alone — which is exactly the configuration that produces a gap at inspection. The full clause-by-clause reading is in Article 26, line by line.
There is also a trapdoor running the other way. Article 25(1) turns a deployer into a provider of the system in defined circumstances — putting its own name or trade mark on it, making a substantial modification, or changing the intended purpose of a system already on the market. A deployer that crosses that line acquires the Article 16 obligations wholesale, including a fresh Article 12 logging perimeter. Fine-tuning a vendor's high-risk system and rebadging it is the common way this happens quietly.
Penalty exposure is unchanged by any of it. Article 99(4) reaches deployer obligations at EUR 15,000,000 or 3 percent of total worldwide annual turnover for the preceding financial year, whichever is higher.
Where each document lands against the obligation.
The practical posture for a deployer is unchanged by which draft lands first. Keep the agent's execution trace intact and addressable. Keep the record layer separable, so a later standard changes a mapping rather than forcing a rebuild. And keep producing records now, against the obligation as written, because that is what an examiner asks for. The record set is enumerated in what records an AI agent must keep; the narrower question of whether the record layer belongs inside or outside the classified system is worked through in the per-action boundary entry, which this entry supersedes on standards status.
What we could not source, stated as gaps.
The items below could not be confirmed from any source we could reach. They are listed rather than smoothed over, because a status entry whose gaps are invisible is worse than one whose gaps are marked.
Anything on this list that a reader can close from a primary source is welcome at [email protected]. Corrections are published as errata.
Questions a compliance officer asks first.
Read the source directly.
- Regulation (EU) 2024/1689 · EUR-Lex CELEX:32024R1689
- Article 40 harmonised standards and standardisation deliverables
- Article 41 common specifications
- Article 26 obligations of deployers of high-risk AI systems
- European Commission · AI Act standardisation, harmonised-standards status
- CEN-CENELEC · artificial intelligence work programme
- CEN-CENELEC JTC 21 · working groups and projects (prEN 18229-1, AI trustworthiness framework — Part 1: Logging)
- ISO/IEC FDIS 24970 · Artificial intelligence — AI system logging
- Per-obligation Warrant evidence field mapping
Authored by Vivek Kumar, Founder · Warrant Labs, with Warrant Compliance, the regulatory-analysis function at Warrant. [email protected]. Editorial commentary on regulatory text and on the published status of standards-track documents. Not legal advice. Standards stages move; each stage and date above is given with the date on which it was recorded, and the gaps in §08 are stated as gaps.