Article 12 binding in 68 days · 2 August 2026

Article 12-compliant logging for high-risk AI.
Retain zero personal data.

zkRune is the cryptographic record-keeping layer for EU AI Act Article 12. Every decision your AI system makes becomes a tamper-evident Groth16 proof — verifiable by a regulator, containing no raw input data, at under 200 bytes.

The paradox

EU law will require you to log personal data. EU law also forbids you from keeping it.

For Annex III point 1(a) AI systems, Article 12(4) mandates retention of the "input data for which the search has led to a match" for at least six months. GDPR Article 5(1)(c) mandates data minimisation. Both are binding. Both apply to the same system, at the same moment.

GDPR Art. 5(1)(c) — in force since 2018

"Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed."

Principle: delete what you don't need.
AI Act Art. 12(4)(c) — binding 2 Aug 2026

"The input data for which the search has led to a match." Retained for at least six months.

Principle: keep what regulators may need to inspect.

Most vendors are choosing one of three bad options: log raw PII and eat the GDPR exposure, log partial hashes and hope regulators accept it, or log nothing and hope no one audits. None survive conformity assessment.

Article 12(4) mapping

Every sub-requirement, satisfied cryptographically.

A direct mapping of the four statutory log fields to the primitives zkRune already produces in production.

Art. 12(4) requirementzkRune implementation
(a) Start & end date/time of each useBlock timestamp at proof submission on-chain. Immutable, UTC-normalized, independently verifiable.
(b) Reference database the input was checked againstThe circuit's Merkle root commitment — cryptographically bound inside every proof. Changes to the reference database produce a new, visible root.
(c) Input data for which the search led to a matchProof public inputs + unique nullifier + proof hash. The private witness — face embedding, document content, biometric template — is never transmitted and never stored.
(d) Natural persons involved in verification (Art. 14(5))Cryptographic signature of the human reviewer's wallet or identity key, bound into the log record. Produces a non-repudiable human-in-the-loop trail.
Proof of readiness

Not a slide deck. A production system.

13
Production circuits
0.4–5 s
Proof generation
~200 B
Proof size
< 2 ms
Verification time
3
Mainnet chains
0
Raw PII retained
Who this is for

High-risk AI systems under Annex III point 1(a).

Primary scope

  • Remote biometric identification systems (face, iris, voice)
  • Identity verification and KYC platforms in regulated industries
  • Age-assurance AI under DSA and national age-gating mandates
  • Border control, access control, critical-infrastructure identity checkpoints
  • Financial-sector customer-due-diligence AI

Buyer profile

Data Protection Officer
Owns GDPR risk. Co-signs logging architecture.
Head of AI Governance / AI Risk
Owns AI Act conformity assessment.
CISO
Owns log integrity, audit readiness, incident response.

zkRune is adopted once, referenced by all three.

Competitive landscape

Why existing tooling doesn't solve Article 12.

SIEM / log aggregation
Splunk, Datadog, Elastic
Stores raw PII. No cryptographic integrity. Direct GDPR exposure.
AI observability
Arize, Fiddler, WhyLabs
Model drift and fairness focus. No per-match regulator-facing audit trail.
AI governance platforms
Credo AI, Holistic AI
Policy and risk-assessment layer. Presumes technical logging already solved.
In-house blockchain logging
Custom builds
12–24 months engineering. Requires ZK expertise. No production verifiers across chains.
zkRune
Purpose-built for Article 12(4). Ships today. No PII retained. Multi-chain. Regulator-inspectable.
Implementation

From signature to Article 12-ready in under 90 days.

12 weeks
Scoping & mapping
Annex III classification, circuit selection, data-flow diagram, DPIA inputs.
23–6 weeks
Integration
SDK embedded in inference pipeline, test proofs generated, reviewer-signing wired.
32 weeks
Regulator dossier
Article 12(4)(a)-(d) mapping, conformity annex, log-export sample pack.
41 week
Production cutover
Verifier registration, monitoring enabled, retention policies signed off.

Engagements starting April–May 2026 finish well inside the 2 August 2026 deadline.

Article 12 binding in 68 days · 2 August 2026

A 30-minute technical session with your DPO and AI governance lead.

We will walk through your Annex III classification, run a live proof against a representative decision flow, and deliver a draft Article 12 mapping tailored to your system within 5 business days.