Naevum’s EU AI Act architecture is a set of built-in records and oversight points for general counsel, so that an auditor’s question gets entries, proofs and timestamps as its answer.
Four articles, and the mechanism that answers each.
Each card quotes the regulation, then names what the stack has built for it and its state.
Fines for prohibited practices reach €35M or 7% of worldwide turnover, whichever is higher; for SMEs, the lower of the two applies. Those maximums cover prohibited practices, not every gap in a log. For most deployers the practical test is an auditor’s question, so the stack writes the answer as it runs: who acted, under whose approval, with which version, and when.56
Record-keeping, log retention and human oversight apply to these systems.
High-risk obligations for AI in Annex I products apply7
Can we answer the auditor’s question?
The general counsel decides what to disclose; the record supplies entries, proofs and times. Illustrative.
1 of 5An auditor asks the general counsel what the procurement agent did on 3 March.
2 of 5The record returns that day’s entries, among them entry 1042: a purchase order the agent drafted and a buyer approved.
3 of 5Each entry carries the hash of the one before, and a Merkle inclusion proof shows entry 1042 belongs to the tree.
4 of 5An RFC 3161 timestamp fixes when the signed chain head existed, so the auditor can check the date independently.
5 of 5The general counsel hands over the entries, the proof and the timestamp, and nothing beyond what the question asked.Decision: The general counsel decides the scope of disclosure.
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1 of 4A former customer asks for their personal data to be erased, and the general counsel accepts the request.Decision: The general counsel accepts the erasure.
2 of 4Entry 1041 holds that customer’s data, encrypted under a key kept for that customer alone.
3 of 4The key is destroyed and a tombstone marks the erasure; nobody can read that personal data again.
4 of 4The entry’s hash stays in the chain, so proofs for every other entry still verify against the same head.
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1 of 4The general counsel sets the retention policy between a 180-day floor and a 400-day ceiling.Decision: The general counsel sets the retention window.
2 of 4Recent entries stay at least 180 days, above the six-month minimum Article 19 sets for logs.
3 of 4Past the 400-day ceiling, the oldest entry’s personal data is due for erasure, which uses key destruction.
4 of 4The chain and its proofs carry on, so an auditor can still check every entry that remains.
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What the record keeps.
01
Hash chain
Each entry carries the SHA-256 hash of the entry before it, so anyone who recomputes the chain sees a changed or missing entry.
Art. 12
02
Merkle proofs
An RFC 6962 Merkle tree gives each entry an inclusion proof, and consistency proofs show the record only grew between two checkpoints.
Art. 12
03
Signed chain head
An Ed25519 signature over the chain head shows continuity. Proving who holds the signing key waits for external key custody, which is in development.
Art. 12
04
Trusted timestamps
RFC 3161 timestamps fix when a chain head existed, so an auditor can check a date outside the system.
Art. 12
05
Retention window
Records stay at least 180 days and at most 400 days: the AI Act’s six-month floor and the GDPR’s storage limit in one policy.
Art. 19 · Art. 26(6)
06
Erasure by key destruction
Personal data is encrypted under its own key. Destroying the key erases the data, and a tombstone keeps the chain verifiable.
Obligation, mechanism, evidence.
Built for the AI Act’s obligations: roles allocated, mechanisms built, evidence kept. The legal assessment stays with the deploying organization.
Obligation
Mechanism
Evidence kept
Record events automatically over the system’s lifetime (Art. 12)1
Hash-chained, Merkle-anchored entries for every consequential action, with RFC 3161 timestamps
Entries, inclusion and consistency proofs, signed chain heads
Keep logs for at least six months (Art. 19, Art. 26(6))2
Retention policy with a 180-day floor and a 400-day ceiling
Each record, held inside that window
Let people oversee, override and stop the system (Art. 14)3
Approval before consequential actions; autonomy ceiling by risk class
Approvals and refusals with the approver; Art. 14 is not yet in the record’s framework map
Tell people they are interacting with an AI system (Art. 50(1))
Disclosure in chat; disclosure by agents acting elsewhere is in development
Chat disclosure mapped to Art. 50(1) in the record
Erase personal data on request (GDPR)
Erasure by key destruction, with a tombstone
A chain that still verifies after the erasure
Explain the AI system’s role in a decision (Art. 86)4
The record holds what an explanation draws on; producing it for the affected person is being built
Agent version, sources, approver and time for each entry
Where it changes the work.
Illustrative situations, connected to the mechanisms that make them possible.
Use outside intelligence on a bounded task
Institutions and R&D teams
A useful model needs context, while the organization holds a much larger sensitive source.
How it works
Select a source-bound projection and account for its disclosure to the actual observer before dispatch.
What changes
The organization can inspect the approved context, purpose and destination of the model work.
A process with a safe stopping point
Industrial edition
An operational process must react to observations while respecting equipment and responsibility boundaries.
How it works
A pipeline separates perception, proposal and gated action; the journal records the resulting state.
What changes
Operators can inspect why a step was admitted, stop the process and recover from its record.
Turn architectural direction into delivery
Organizations commissioning custom AI
A difficult brief spans data, software, interfaces and operating responsibilities.
How it works
The Planner defines a mandate; implementation, review and QA preserve its acceptance conditions.
What changes
The customer can examine how the delivered system answers the original brief.
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Authority is part of the action path
A regulated workflow needs to retain who can approve an effect and what the system was allowed to do. Manna’s envelopes and gates, Synapse’s source/effect admission and Agency Engine’s sealed governance set give those decisions explicit places in the architecture.
Human approval, stop and recovery are operating paths with recorded state. They are distinct from a policy sentence added to a model prompt.
Evidence follows the system version
Immutable source identity, effect identity, policy/runtime binding and event records connect a model task to the configuration that produced it. Black Box’s delivery design carries independent acceptance and the artifact into handover.
The record supports reconstructing the basis of a decision, an interruption and the next operating action. Technical documentation can refer to those actual controls and their qualified deployment scope.
Risk and custody shape the implementation
Synapse accounts for cumulative observer exposure before transport. Agency Engine preserves approval and connector/store-custody boundaries. Metahive defines compute placement and operating responsibility.
The commissioned architecture maps intended purpose, data sources, human roles, monitoring and security controls to the particular deployment. The legal classification and applicable obligations are determined for that use case.
EU AI Act-native is an engineering approach
Naevum brings authority, oversight, traceability and risk boundaries into selected system designs from the outset. Each engagement has an explicit technical and operational responsibility map.
The phrase does not imply automatic conformity assessment or blanket certification. Applicable obligations and evidence are assessed with the responsible organization against the current EU AI Act.
The mechanisms underneath.
The technical choices that give Built for the EU AI Act its particular behavior.
Authority in the execution path
Source-bound admission, operating envelopes and human checkpoints make responsibility part of the system’s behavior.
Records connected to actual effects
An attempt’s inputs, permitted scope, decisions and resulting evidence remain associated through interruption and recovery.
Documentation from the system boundary
Risk, intended purpose, data boundaries and oversight are specified for a deployment. Technical architecture supports this assessment; it does not confer a universal conformity status.
Controlled change
Versioned source, acceptance evidence and bounded policy changes preserve the basis on which an operating system was assessed.