EU AI Act, Articles 12 and 13
Article 12 of the EU AI Act requires high-risk AI systems to automatically record events ("logs") over their lifetime. Article 13 requires those systems to be designed for transparency and to enable users to interpret outputs appropriately. This page maps Verdifax's manifest hash to the specific obligations under both articles.
Maturity note. Hardware attestation graduated to a real, run-bound AMD SEV-SNP quote on 2026-07-17. Two scaffold flags remain: the zero-knowledge transcript and its state-prover binding, which still emit scaffold values rather than real cryptographic proofs. Every audit bundle flags these with a
scaffoldfield; the open-source verifier surfaces them in its report. See /concepts/scaffold-gaps/ for the full disclosure list and what activates each. Rows in the crosswalk below that depend on scaffold layers are flagged inline.
What Articles 12 and 13 actually say
Article 12 (record-keeping) is the direct fit for what Verdifax does. It requires that high-risk AI systems technically allow for the automatic recording of events ("logs") over the lifetime of the system, to a degree appropriate to its intended purpose. Those logs must enable the monitoring of the system's operation and the post-market surveillance referred to in Article 72.
Article 13 (transparency) is a related, secondary obligation. It requires that high-risk AI systems be designed and developed so that:
- Their operation is sufficiently transparent to enable deployers to interpret outputs and use them appropriately.
- They are accompanied by instructions for use that include the system's intended purpose, capabilities, performance, and known limitations.
The post-market surveillance requirement under Article 12 is where the audit-trail integrity question lands. A regulator must be able to look at a recorded event and confirm it actually happened.
Where Verdifax fits
Verdifax does not write the instructions for use. It does not interpret model output. It does not claim to satisfy Articles 12 and 13 in their entirety, that's a system-level obligation that includes documentation, performance reporting, and governance.
What Verdifax does provide is the integrity layer that turns whatever logs your system produces into something a regulator can independently verify. This maps primarily to Article 12's record-keeping obligation:
| Article 12 requirement (record-keeping) | Verdifax contribution |
|---|---|
| Automatic event logs | Every model invocation is sealed by manifest hash |
| Tamper-evident records | The hash collapses 18 sealed fields under SHA-256; any modification invalidates it |
| Reproducibility for post-market review | Re-running the same inputs produces the same hash byte-for-byte |
| Independent verification | The hash can be checked by anyone with the inputs, without trusting the operator |
| Public-log anchoring | Every successful run is committed to the Sigstore Rekor public transparency log, third parties can independently confirm the run existed at a specific time |
| Hardware-anchored attestation | Every run can carry a real, run-bound AMD SEV-SNP hardware quote, verified against AMD's pinned Milan root before sealing (graduated from scaffold on 2026-07-17). SEV-SNP is 1 of 3 planned platforms; TPM2 and Nitro Enclaves remain pending. See scaffold-gaps |
For Article 13 (transparency), the generated audit-pack PDF renders the sealed record in a form an oversight body can read and interpret, which supports (but does not by itself satisfy) the transparency obligation.
Sample audit response
When an EU AI Act regulator requests evidence that a specific decision was made by your AI system, your response can be:
- The original input (or its hash, if PII is at issue)
- The Verdifax manifest hash for that decision
- Optional: the generated PDF audit report from
/runs/{id}/report.pdf, which includes the regulatory mapping section
The regulator re-derives the hash from the inputs and confirms it matches what was recorded. No trust in the operator required.
What this does not cover
- Annex IV technical documentation, Verdifax does not generate this. Your governance team writes it.
- Conformity assessment, Verdifax is one component, not a full assessment.
- Risk management system (Article 9), separate obligation.
- Data governance (Article 10), Verdifax does not see training data.
- Human oversight (Article 14), Verdifax records what happened; it doesn't enforce who was reviewing.