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Maintain audit trails, manage certification, and govern regulatory interactions. A regulator, auditor, or notified body that requests demonstration of compliance will evaluate the organisation on the basis of the evidence it can produce, not on the basis of the governance it claims to practise. Compliance without evidence is indistinguishable from non-compliance.
Core Activities
Four capabilities that ensure every governance action across the TRACE lifecycle is captured, preserved, and presentable to any stakeholder.
The audit trail is the evidentiary backbone of TRACE. It captures records generated by every other phase and preserves them in tamper-evident form supporting internal audit, external assessment, and regulatory investigation. Compliance without evidence is indistinguishable from non-compliance.
Conformity assessment is mandatory for high-risk AI systems before market placement. The EU AI Act provides two pathways: internal control (Annex VI, Module A) where the provider self-assesses, and quality management system assessment with technical documentation review (Annex VII, Module H) involving a notified body.
Organisations deploying AI in regulated environments will interact with regulators — proactively through sandboxes and consultations, or reactively through investigations and information requests. Effective management of these interactions is a governance discipline in its own right.
Governance credibility extends beyond regulators. Deployers, affected persons, civil society, and the public have legitimate interests in understanding AI governance. The EU AI Act requires high-risk AI system registration in the EU database before market placement, and transparency obligations apply to deployers informing individuals subject to AI decisions.
Conformity Assessment
A structured process for preparing EU AI Act conformity assessment, whether internal (Module A) or third-party (Module H).
Retention Policy
Retention periods vary across frameworks. The audit trail policy must satisfy the longest applicable period for each record type.
Artefacts
Six categories of deliverable that provide the evidentiary foundation for audit, certification, regulatory interaction, and stakeholder assurance.
Tamper-evident audit trails, conformity assessment readiness, and structured regulatory interaction management — evidence that exists before it's requested.