Sanction & the EU AI Act
Sanction is the evidence and human-oversight layer you put around the AI agents you operate — so you can demonstrate the record-keeping, transparency, and oversight the EU AI Act expects. It is not legal advice, and it does not make you compliant. It gives you signed, replayable proof of how your agents were governed.
What Aug 2, 2026 actually is
On 2 August 2026 the AI Act becomes fully applicable: the Commission's enforcement powers over general-purpose AI (GPAI) models — including fines — come into force, and the governance and penalties framework goes live. The Article 50 transparency obligations (§§1, 3, 4 — chatbot disclosure, synthetic-content marking, deepfake labelling) also apply from that date to any AI system placed on the EU market.
The high-risk obligations most teams brace for were pushed back by the Digital Omnibus on AI, now law as Regulation (EU) 2026/1744 — published in the Official Journal 24 July 2026, in force 27 July 2026: high-risk Annex III (standalone) systems move to 2 Dec 2027, and Annex I (embedded in regulated products) to 2 Aug 2028. GPAI models placed on the market before Aug 2, 2025 have until Aug 2, 2027. Content-marking transition and the CSAM/NCII prohibition land 2 Dec 2026.
Aug 2, 2026 did not move. The Omnibus delayed the high-risk clock; it left general application and Article 50 transparency where they were. Reports that Aug 2 was postponed are wrong.
So: Aug 2, 2026 is the enforcement-goes-live milestone and the moment every enterprise deploying AI starts asking "can we evidence oversight and logging for our AI?" The hard high-risk clock now runs to 2027–2028, but transparency and the audit trail are live obligations — and the question is here now.
Where Sanction fits
Sanction is not itself a high-risk AI system: it's an authorization and governance layer, not an AI system making consequential decisions about people. Its job is to produce the operator evidence that the Act's logging (Art 12), transparency (Art 13), and human-oversight (Art 14) provisions call for, for the agents you run.
Crosswalk — obligation → Sanction surface → how to pull the evidence
| AI Act obligation | Sanction surface | Evidence you can produce today |
|---|---|---|
| Art 12 — automatic record-keeping / logging over the system's lifetime | Every governed decision (spend, tool, capability, provision), token log, and credential injection is persisted | GET /api/v1/audit/export — a signed, hash-chained snapshot; altering, dropping, or reordering any entry breaks the chain |
| Art 13 — transparency & interpretability of outputs | Stable decision codes + the exact policy revision each decision ran under; deterministic replay reproduces any decision | Each decision carries policy_revision; replay evidence via the evidence endpoints |
| Art 14 — human oversight (a person can intervene and stop) | Escalation → human approval/denial → single-use grant; the freeze kill-switch halts an agent or a whole pool instantly | Approvals record who decided, when, and why (resolvedBy, timestamp, rationale) |
| Art 9 — risk management (documented, enforced controls) | Budgets, per-transaction caps, category/tool/capability allow-lists, cost-per-outcome ceilings, subtree caps | The policy revision history is the documented, versioned control set |
| Traceability / reproducibility | Immutable policy revisions + stored decision contexts + replay match verdict | Same request + same revision + same state ⇒ same decision, provably |
| Art 15 — accuracy, robustness, cybersecurity | Row-level tenant isolation, envelope-encrypted credential vault, fail-closed auth planes | See Security & threat model |
One signed, Article-framed evidence bundle
Pull a tamper-evident export for a wallet — or a whole org — framed against the Act:
# The whole org (a parent wallet + every pool beneath it), framed for the Act.
curl "https://getsanction.com/api/v1/audit/export?wallet_id=WALLET_ID&scope=subtree&framing=eu-ai-act" \
-H "x-mgmt-key: sk_your_management_key"
You get the normal signed export plus an ai_act block: the Article mapping,
the retention statement, decision counts (including how many were resolved by a
named human), and the signed head. Prove it wasn't altered afterward:
# Anyone can re-verify the chain + signature — no trust in us required.
curl -X POST "https://getsanction.com/api/v1/audit/verify" \
-H "x-mgmt-key: sk_your_management_key" \
--data-binary @export.json
# → { "valid": true, "chain_valid": true, "signature_valid": true, "count": N }
The ai_act framing rides alongside the signed decisions — it never alters
them, so verification is independent of the framing.
Retention & immutability
The audit trail is append-only. Governed decisions, token logs, and credential-injection records are never modified or deleted after write — there is no purge job and no mutation path. An export is a signed snapshot of a time range; the underlying records remain for the life of the wallet. This is the record-keeping durability Art 12 is asking for.
The honest boundary
- Sanction gives you evidence to support Art 12/13/14 obligations. It is not a compliance certification, a conformity assessment, or legal advice.
- The high-risk timeline is 2027–2028 under Regulation (EU) 2026/1744 (in force 27 July 2026); the Aug 2, 2026 date is enforcement-live + GPAI + Art 50 transparency. We say "helps you demonstrate," never "makes you compliant."
- Talk to your own counsel about which obligations apply to your systems.
Primary sources: the AI Act text and Commission guidance.