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Show HN: Open-Source Article 12 Logging Infrastructure for the EU AI Act
by systima
EU legislation (which affects UK and US companies in many cases) requires being able to truly reconstruct agentic events.
I've worked in a number of regulated industries off & on for years, and recently hit this gap.
We already had strong observability, but if someone asked me to prove exactly what happened for a specific AI decision X months ago (and demonstrate that the log trail had not been altered), I could not.
The EU AI Act has already entered force, and its Article 12 kicks-in in August this year, requiring automatic event recording and six-month retention for high-risk systems, which many legal commentators have suggested reads more like an append-only ledger requirement than standard application logging.
With this in mind, we built a small free, open-source TypeScript library for Node apps using the Vercel AI SDK that captures inference as an append-only log.
It wraps the model in middleware, automatically logs every inference call to structured JSONL in your own S3 bucket, chains entries with SHA-256 hashes for tamper detection, enforces a 180-day retention floor, and provides a CLI to reconstruct a decision and verify integrity. There is also a coverage command that flags likely gaps (in practice omissions are a bigger risk than edits).
The library is deliberately simple: TS, targeting Vercel AI SDK middleware, S3 or local fs, linear hash chaining. It also works with Mastra (agentic framework), and I am happy to expand its integrations via PRs.
Blog post with link to repo: https://systima.ai/blog/open-source-article-12-audit-logging
I'd value feedback, thoughts, and any critique.
Anyone can generate an alternative chain of sha256 hashes. perhaps you should consider timestamping, e.g. https://opentimestamps.org/ As for what the regulation says, I haven't looked but perhaps it doesn't require the system to be actually tamper-proof.
Thanks for the thoughts and feedback.
Fair point on the reconstruction attack.
The library is deliberately scoped as tamper-evident, not tamper-proof; it detects modification but does not prevent wholesale chain reconstruction by someone with storage access. The design assumes defence-in-depth: S3 Object Lock (Compliance mode) at the infrastructure layer, hash chain verification at the application layer.
External timestamping (OpenTimestamps, RFC 3161) would definitely add independent temporal anchoring and is worth considering as an optional feature. From what I can see, Article 12 does not currently prescribe specific cryptographic mechanisms (but of course the assurance level would increase with it).
On the regulatory question: Article 12 requires "automatic recording" that enables monitoring and reconstruction and current regulatory guidance does not require tamper-proof storage (only trustworthy, auditable records). The hash chain plus immutable storage is designed to meet that bar, but what you raise here is good and thoughtful.
Good one. QQ. If you store it hash chained, how are you handling GDPR erasure requests? Isn't that supposed to erase within 30 days for GDPR instead of 180? Do you recreate the chain or soe sort of Pseudonymization or anything else?
GDPR permits retention where necessary for compliance with a legal obligation (Article 6(1)(c)).
The AI Act qualifies as such a legal obligation.
Crafted by Rajat
Source Code