Logging the machine: cyber requirements for AI systems in federal and commercial environments

This whitepaper addresses the critical compliance challenge facing organizations as two major AI regulations converge in 2026: the EU AI Act and US federal AI risk-management mandates. It explores the logging and record-keeping obligations that high-risk AI systems must now meet to comply with these regulations, and examines why most organizations currently lack the infrastructure to produce complete, tamper-evident audit trails of their AI systems’ activities and decision-making processes. The paper positions proper AI compliance as a data-infrastructure problem rather than a paperwork exercise, offering guidance on how organizations can build the necessary systems to pass regulatory audits.