ENFORCEMENT LIVE · 2 AUG 2026HIGH-RISK · 2 DEC 2027

The EU AI Act is clumsy. Producing the evidence for it shouldn't be.

Every deliverable the Act asks a software team for is a question about the past: who supervised this, for how long, on whose authority, and why is it built this way.

A compliance project answers those with archaeology. letopis answers them with a lookup — the answer was recorded on the day.

THE DEADLINE NOBODY PUT ON A SLIDE

11 SEP 2026

The AI Act moved. The Cyber Resilience Act did not.

Article 14 gives you 24 hours to file an early warning on an actively exploited vulnerability, 72 for the full notification,14 days for a root-cause report.

It reaches backwards, too — the duty covers everything already on the market. On that clock, knowing what changed and why is the difference between filing and guessing.

ARTICLE BY ARTICLE

Six provisions, and which book writes the answer.

Annex IV §2(b) — via Art. 11, technical documentation

The design specifications: the key design choices, including the rationale and assumptions made, and the trade-offs behind the technical solutions adopted.

A dated, attributable record of each design decision and the option you rejected — captured when it was made, not reconstructed by whoever is still on the team.

zavet

Art. 14 · Art. 26(2) — human oversight

The system is overseen by natural persons who are competent, trained and actually able to intervene.

Evidence that a human supervised this change, and for how many minutes — instead of a policy PDF asserting in general that humans supervise.

dira + proba

Art. 17 — quality management system

Design control and design verification, change control, and procedures for keeping the records that prove both.

Per merged change: CI state at the merge commit, a review by someone other than the author, recorded decisions respected, branch protection not bypassed.

proba

Art. 12 · 19 · 26(6) — record-keeping & retention

Automatic recording of events, traceable over the lifetime of the system, retained and produced on request.

Records that are tamper-evident and non-repudiable — signed at capture on the workstation, append-only afterwards, and still legible in six months or ten years.

the chain

Art. 25 · Art. 43(4) — substantial modification

Modify a high-risk system substantially and you inherit the provider's obligations for it.

Knowing exactly what changed, when, and on whose authority — including the refactor an agent made at 02:40 that no human ever opened.

the chain

Art. 73 — serious incident reporting

Report a serious incident to the authority without undue delay — 15 days at the outside, but two if the infringement is widespread or the incident risks serious injury, and ten where someone has died.

Reconstructing the decision and change history of one subsystem in an afternoon./zavet:why answers with citations; a wiki search does not.

zavet /zavet:why

THE HALF NOBODY HAS

There are two AIs in your product, and only one of them is being logged.

Every AI Act tool on the market instruments the model your users talk to. Almost nothing instruments the models that wrote the code.

THE MODEL IN YOUR PRODUCT

Runtime logging, evals, guardrails. Article 12 territory — a crowded market, and not what dira does.

THE MODELS THAT BUILT IT

Who supervised the agent, for how long, which harness, against which recorded decision. letopis was in the room when it happened.

WHAT LETOPIS WILL NOT CLAIM

A chronicle has no opinions — least of all legal ones.

It cannot tell you whether you are high-risk, and no dashboard can certify you as compliant. What it removes is the archaeology: the interviews, the guessed dates, the rationale written in August about a March decision.

Start recording before you need the record.

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regulation (EU) 2024/1689ai omnibus in force since 27 jul 2026high-risk deferred to 2 dec 2027

The EU AI Act is clumsy. Producing the evidence for it shouldn't be.

Every deliverable the AI Act asks a software team for is a question about the past:what did you decide, why, what did you reject, and who was actually watching the agent?

A compliance project answers those with archaeology. letopis answers them with a lookup, because the answer was recorded while the work was happening. That is the entire difference, and it is not a small one.

penalty ceiling, these obligations €15M or 3% of worldwide turnoverdeployer log retention ≥ 6 monthstechnical documentation kept 10 yearscra reporting starts 11 sep 2026harmonised standards: late 2026 / early 2027

APPLICATION TIMELINE

2 Feb 2025

Prohibited practices bite.Article 4 AI literacy applies to every provider and deployer — softened by the omnibus tosupport the development of, not ensure.

2 Aug 2025

GPAI models, governance, penalties.The model provider's problem, not yours — until you build on one.

2 Aug 2026 · in force

The Act is generally applicable, and being enforced.

The AI Office and national authorities start enforcing. Article 50 applies: your chatbot says it is a chatbot, and generated output carries a machine-readable mark.

2 Dec 2026

Article 50(2) catches systems already on the market.The omnibus's new prohibition — AI-generated CSAM and non-consensual intimate material — applies from the same day.

2 Dec 2027

High-risk under Annex III: risk management, technical documentation, record-keeping, human oversight.

Annex I products follow on 2 Aug 2028.

The delay is real, and narrower than the headlines. The AI Omnibus — Regulation (EU) 2026/1744 — was adopted on 29 June 2026, published in the Official Journal on 24 July, and has been in force since 27 July: it moved Chapter III for Annex III systems by sixteen months and Annex I by a year, and moved nothing else. Article 50, Article 4, the prohibitions, GPAI and enforcement all kept their dates — and sixteen extra months do not hand you back the March you failed to record.

THE DEADLINE NOBODY PUT ON A SLIDEregulation (EU) 2024/2847 · art. 14

The AI Act moved. The Cyber Resilience Act did not.

On 11 September 2026 the CRA switches on its reporting regime. If you make a product with digital elements available in the EU — software counts — an actively exploited vulnerability or a severe incident starts a clock measured in hours, not weeks.

And it reaches backwards. Article 69(3) applies this duty to everything already on the market, not only to what you place there after the main obligations land in December 2027. The regulation most teams filed under next year has its first hard date next month.

DAYS TO 11 SEP 2026

then 24 hours, once

24hearly warning to your CSIRT and ENISA, from becoming aware

72hfull notification: what it is, what is affected, what you are doing

14dfinal report once a fix exists — root cause and corrective measures

WHAT A 24-HOUR CLOCK ACTUALLY ASKS OF YOUR RECORD

What changed, and when

The affected code's change history, anchored to commits that provably exist in the remote. You have hours to state the product, the version and the window — not a week of git archaeology.

Who — or what — wrote it

Which harness produced the change, under whose identity, and how many engaged minutes a human spent on it. A line written by an unsupervised agent at 02:40 is a different report from one a reviewer signed.

Why it was built that way

The final report wants root cause and corrective measure. The recorded rationale — and the option that was rejected — is what turns we changed it into an account of why this fix is the right one.

letopis does not detect exploitation, does not judge severity, and does not file anything with ENISA or your CSIRT. It is not a scanner and not a compliance workflow. It answers the questions the report asks about the past — which, on a 24-hour clock, is the one part you cannot buy on the day.

THE EVIDENCE LADDER · PICK A RUNG

Compliance is not a switch. It is a depth of evidence — and you can watch it get deeper.

Gold is stamped 585, 750 or 999 for how much of it is actually gold. A proba hallmark is stamped for how much of the change is actually evidenced. Each rung turns a row below from— into ✓.

WHAT AN AUDITOR CAN ASK AND GET AN ANSWER TO

6 / 8

✓Was CI green at the merge commit?Art. 17

✓Did somebody other than the author approve it?Art. 14

✓Was branch protection bypassed to land it?Art. 17

✓Which harness wrote this change?Annex IV §2(a)

✓How many minutes did a human actually supervise it?Art. 14 · 26(2)

✓Is that record non-repudiable, or just a line of text?Art. 14 · 26(2)

—What was the design rationale, and what was rejected?Annex IV §2(b)

—Were recorded decisions respected, or quietly reverted?Art. 17

Add dira and the workstation becomes visible: which harness, whose identity, how many engaged minutes, signed at capture. This is the rung most teams cannot reach with anything they currently own — a code host structurally cannot see it.

THE WHOLE CHAIN · WHERE IT LEAVES YOU

Run all four books and this is the honest overall state.

Not a score, and not a percentage of the Act. Four numbers, each of which you can check against the rows above and below.

8 / 8

evidence questions on the ladder above, answerable by lookup rather than by interview

999

the fineness every merged change can reach — the top of the assay scale, with nothing above it

6 / 6

provisions in the table below whose deliverable falls out of the record as a byproduct

runtime obligations covered. Article 12 inference logs, drift, your CE mark: another vendor's product

diraWho ran which agent, under whose git identity, and the engaged supervision minutes — deduped across parallel sessions, signed at capture on the workstation.

zavetThe design rationale, the assumptions and the option that was rejected — in the repo, reviewable in a PR, guarded against the next agent quietly contradicting it.

probaThe per-merge process record, signed and immutable: CI at the merge commit, a non-author review, no bypass, and the fineness of the evidence behind all of it.

miaraNothing. miara prices future work from evidenced history and makes no compliance claim at all — it is in the suite for your margin, not for your auditor.

Read together: every question the Act asks about the past has an answer, and every question about runtime still needs a product we do not sell. That is not a certificate — nobody can sell you one. It is the difference between an afternoon and a quarter on the day somebody asks.

ARTICLE BY ARTICLE

Six provisions, and which book writes the answer.

THE ACT SAYS

WHAT IT ASKS FOR

WHICH IN PRACTICE MEANS

WRITTEN BY

Annex IV §2(b)

via Art. 11 — technical documentation

The design specifications: the key design choices, including the rationale and assumptions made, and the trade-offs behind the technical solutions adopted.

A dated, attributable record of each design decision and the option you rejected — captured when it was made, not reconstructed by whoever is still on the team.

zavet

Art. 14 · Art. 26(2)

human oversight

The system is overseen by natural persons who are competent, trained and actually able to intervene.

Evidence that a human supervised this change, and for how many minutes — instead of a policy PDF asserting in general that humans supervise.

dira + proba

Art. 17

quality management system

Design control and design verification, change control, and procedures for keeping the records that prove both.

Per merged change: CI state at the merge commit, a review by someone other than the author, recorded decisions respected, branch protection not bypassed.

proba

Art. 12 · 19 · 26(6)

record-keeping & retention

Automatic recording of events, traceable over the lifetime of the system, retained and produced on request.

Records that are tamper-evident and non-repudiable — signed at capture on the workstation, append-only afterwards, and still legible in six months or ten years.

the chain

Art. 25 · Art. 43(4)

substantial modification

Modify a high-risk system substantially and you inherit the provider's obligations for it.

Knowing exactly what changed, when, and on whose authority — including the refactor an agent made at 02:40 that no human ever opened.

the chain

Art. 73

serious incident reporting

Reconstructing the decision and change history of one subsystem in an afternoon./zavet:why answers with citations; a wiki search does not.

zavet /zavet:why

None of the rows above is a feature built for the AI Act. Every one is a byproduct of recording the work properly — which is why the chronicle was worth keeping before any of this was law.

THE HALF NOBODY HAS

There are two AIs in your product, and only one of them is being logged.

Every AI Act tool on the market instruments the model your users talk to. Almost nothing instruments the models that wrote the code around it. Both sides of this line are in scope, and the left-hand one is where the design rationale lives.

BUILD TIME · THE AI THAT BUILT IT

letopis lives here

✓Which harness wrote each change, cryptographically attributed rather than claimed

✓Engaged supervision minutes per change, deduped across parallel agents

✓Design decisions with rationale, rejected options and guarded scope

✓Per-merge process record: CI, non-author review, no bypass, signed

✓The full change history of the system, anchored to commits in the remote

DEPLOY

RUNTIME · THE AI YOUR USERS TOUCH

letopis does not go here

✕Inference-time input and output logging under Article 12

✕Per-decision explanations to the affected person

✕Drift, bias and accuracy monitoring in production

✕Your conformity assessment, your registration, your CE mark

—Buy that elsewhere. We will not pretend a git-anchored session says anything about a credit-scoring decision your model made at 4am.

WHAT LETOPIS WILL NOT CLAIM

A chronicle has no opinions — least of all legal ones.

The market for this is already full of dashboards that print the wordcompliant. Four things letopis refuses to do, on purpose:

It is not a compliance badge

No product can certify you against the AI Act, and a proba hallmark never sayscompliant. It states, at a declared fineness, what was observed. What that is worth is your auditor's call, not ours.

It is not runtime logging

Article 12 governs the AI system your users touch. letopis records the AI that builtit. If your product is high-risk you still need runtime logs — letopis is the half nobody has.

It is not legal advice

Whether you are high-risk depends on what the system was deployed to do, not on the fact that agents wrote it. letopis will not tell you, and will not sell you a questionnaire that pretends to.

It is not retroactive

The uncomfortable one. Evidence cannot be backfilled honestly — zavet marks reconstructed decisionsunverified until a human confirms them. The only way to hold March's record is to have recorded in March.

Which is the whole argument for starting the chronicle on a quiet Tuesday, rather than in the week somebody asks.

Start recording before you need the record.

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