What records must an AI agent keep to satisfy a regulator?

The record set, in one paragraph.

The regulator's question is narrow. Show me what the agent did, prove the record is intact, and prove you kept it long enough. Three regimes ask it three ways. The EU AI Act asks for an automatic event record over the lifetime of the high-risk system. NYDFS asks for an audit trail that detects cybersecurity events at the operation level. US bank model risk guidance asks for comprehensive documentation of the model and its decisions. Across all three, the unit that satisfies is the same: a record mapped to a specific obligation, kept for at least the retention floor, independently verifiable without contacting Warrant.

This entry is structured as the regulator's question, the record artifact that answers it, and the article that demands it. Run the list against a production agent and the gaps are the gaps an inspection finds first.

EU AI Act Article 12 · the event record over the lifetime.

Article 12(1) binds providers of high-risk AI systems to automatic event recording over the lifetime of the system. The application date is 2 August 2026, subject to a provisional deferral to 2 December 2027 for Annex III standalone systems under the May 2026 Digital Omnibus, pending OJEU publication. Non-compliance is reachable under Article 99(4) at up to EUR 15 million or 3 percent of global annual turnover. The line-by-line read is in Article 12, line by line.

What the record has to capture is set by Article 12(2). Paragraph 2(a) covers situations that may result in the system presenting a risk under Article 79(1) or a substantial modification. Paragraph 2(b) covers facilitation of post-market monitoring under Article 72. Paragraph 2(c) covers monitoring of the operation under Article 26(5). The record is event-shaped, not request-shaped: it must be addressable by deployment, by version, and by the action the agent took, not just by the HTTP call that carried it.

For an autonomous agent that takes many consequential actions in one run, whether the record is one running log or a discrete record per action is the open boundary. That question is read in full at does Article 12 require a record per agent action.

The retention floor · at least six months, on two sides.

Article 19(1) is the provider floor. The provider keeps the Article 12 logs for a period appropriate to the intended purpose, of at least six months, unless Union or national law requires longer. Article 26(6) is the deployer mirror. The deployer keeps the logs that come under its control, for the same appropriate period, of at least six months. The two floors run in parallel. The detail of the deployer side is in the Article 26 deployer obligations, line by line.

Six months is a floor, not a ceiling. Sectoral law pushes the actual horizon longer wherever it speaks. MiFID II Article 16(7) runs five years for orders and decisions to deal. The Medical Device Regulation Article 10(8) runs ten years, fifteen for implantable devices. A six-month rolling window destroyed twelve months ago is not an answer to a regulator's request twelve months and one day after the event. The phrase in particular in Union law on the protection of personal data is the GDPR carve-back: where logs contain personal data, storage-limitation under GDPR caps the upper bound, and the deployer settles on a per-use-case number that satisfies both regimes.

NYDFS · the audit trail at the operation level.

The 16 October 2024 NYDFS Industry Letter imposes no new rule. It applies 23 NYCRR Part 500 to AI, including the § 500.6(a)(2) audit-trail provision. Read against an AI agent, a standard application log does not satisfy: it records that a request returned a status code, not what was accessed or under what authorization. The full reading is in standard API call logs do not satisfy 23 NYCRR § 500.6.

The audit trail has to answer four questions about each operation the agent performed. What was accessed — the specific nonpublic-information element, not a request hash. By which agent — the model identifier and provider, not "the chatbot". Under what authorization — the policy and purpose limitation the action satisfied. When — a timestamp the covered entity cannot retroactively change. The retention side is its own clock: § 500.6(b) runs five years for the (a)(1) reconstruction records and three years for the (a)(2) audit-trail records.

SR 11-7 · documentation as a record obligation.

The fourth pillar of US bank model risk guidance is comprehensive documentation. SR 11-7, originally issued 4 April 2011 by the Federal Reserve with OCC Bulletin 2011-12 the same day and adopted by FDIC through FIL-22-2017, was carried forward by SR 26-2 in 2026 with explicit AI/ML scope. Under SR 26-2, large language models and agentic systems that produce or shape a bank decision are named as material models, so the documentation pillar attaches to them directly. The line-by-line read is in SR 11-7 / SR 26-2, line by line.

For an AI agent, the documentation record is three layers. The development record — the agent's tool-selection logic, prompt template, retrieval policy, scope of use, and limitations, which are bank artifacts even when a vendor supplies the foundation model. The validation record — the ongoing-monitoring cadence and the triggers that force re-validation. And the per-decision record — what the agent did and the alternatives it weighed, which SR 26-2 reads as part of effective challenge at runtime. The unmapped AI deployment with no model inventory entry is the next examination cycle's most likely model risk finding.

The checklist · question, record, clause.

The mapping below is the whole entry in one table. Each row is a question a regulator asks, the record artifact that answers it, and the clause that demands it. A deployer can run this against a production agent and treat any empty record cell as a finding.

The structural choice a deployer makes now is whether each of these records lives inside the agent or in a record layer downstream of the decision. A record mapped to a specific obligation, kept past the retention floor, and independently verifiable without contacting Warrant satisfies the question in every column at once.

Questions a compliance officer asks first.

Read the source directly.

• Regulation (EU) 2024/1689 · EUR-Lex CELEX:32024R1689
• Article 12 record-keeping · annotated text
• Article 19 automatically generated logs · retention
• Article 26 obligations of deployers of high-risk AI systems
• 23 NYCRR Part 500 · Second Amendment (1 November 2023, PDF)
• Federal Reserve SR 11-7 · Supervisory Guidance on Model Risk Management
• Article 12, line by line · the record obligation read in full
• Article 26 deployer obligations · who keeps the records
• NYDFS § 500.6(a)(2) · why standard logs do not satisfy

Authored by Warrant Compliance, the regulatory-analysis function at Warrant. [email protected]. Editorial commentary on regulatory text. Not legal advice. The verbatim quotations of Article 12(1) and Article 19(1) reflect the official English-language text of Regulation (EU) 2024/1689 as published in the Official Journal of the European Union on 12 July 2024. The 23 NYCRR § 500.6(a)(2) text reflects the Second Amendment effective 1 November 2023. The SR 11-7 quotation reflects the Federal Reserve supervisory guidance issued 4 April 2011, carried forward by SR 26-2 with explicit AI/ML scope in 2026.