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EU AI Act for biometrics teams

*Engineering guidance, not legal advice. Your legal team decides how the Act applies to your products.*

Where this sector lands

Annex III point 1 covers biometrics, where their use is permitted under Union or national law:

• (a) remote biometric identification systems. Biometric verification whose sole purpose is to confirm that a person is who they claim to be (a 1:1 selfie match at onboarding, a face unlock) is excluded;
• (b) biometric categorisation according to sensitive or protected attributes;
• (c) emotion recognition systems.

Some biometric uses are not high-risk but prohibited outright by Article 5, in force since 2 February 2025: untargeted scraping of facial images to build recognition databases, emotion recognition in workplaces and schools (except for medical or safety reasons), categorisation that infers race, political opinions, religion or sexual orientation, and real-time remote identification in public spaces for law enforcement outside narrow exceptions. Separately, Article 50(3) requires deployers of emotion recognition or categorisation to inform the people exposed to it.

The logging duties that follow

• Art. 12 (providers): automatic event recording over the system's lifetime. For remote identification, Art. 12(3) sets a minimum: the period of each use (start and end date and time), the reference database checked, the input data that led to a match, and the identity of the people who verified the result.
• Art. 14(5): for remote identification, no action or decision may be taken on a match unless it has been separately verified and confirmed by at least two competent people, with a narrow carve-out in law enforcement, migration and border control where Union or national law deems it disproportionate.
• Art. 19 (providers) and Art. 26(6) (deployers): keep the logs for at least six months. Deployers must also assign competent human oversight (Art. 26(2)).

On timing: the Digital Omnibus agreement moves Annex III high-risk obligations to December 2027 (details and caveats). The Art. 5 bans already apply.

What counts as evidence

The contested moment is a match: someone was stopped, flagged or refused. The question will be whether the two confirmations really happened, before the action, by the people named.

Abbreviated ledger excerpt (prev, hash and sig omitted):

{"seq":0,"type":"run.start","data":{"name":"rbi-search","meta":{"reference_db":"watchlist_v14","use_start":"2026-09-14T08:00:00Z"}}}
{"seq":3,"type":"tool.result","data":{"name":"face_match","output":{"candidate":"ref_0192","score":0.91}}}
{"seq":4,"type":"policy.decision","data":{"kind":"tool.result","action":"warn","hits":[{"rule":"two-person-verification"}]}}
{"seq":5,"type":"tool.call","data":{"name":"confirm_match","input":{"reviewer":"op_17","decision":"confirmed"}}}
{"seq":6,"type":"tool.call","data":{"name":"confirm_match","input":{"reviewer":"op_22","decision":"confirmed"}}}

A hash chain makes a confirmation inserted after the fact, or a rejected match quietly removed, detectable. An independent countersignature fixes when the log existed.

How Vetro Attest fits

Vetro Attest accepts an OpenTelemetry GenAI trace (OTLP/JSON) or a native Vetro ledger, with nothing to install. Verification is free. For 29 USD per ledger, one-off:

• a full EU AI Act report (Markdown and HTML) mapping the run onto the logging obligations, with an explicit list of what the log cannot show;
• an ed25519 countersignature over the ledger digest, event count and timestamp, verifiable by anyone with our published public key.

A practical pattern: countersign each search session at the end of its use period, and store the attestation next to the Art. 12(3) record. Keep face templates and images out of the trace; references are enough, and the countersignature covers only a digest.

Limits, stated plainly: the countersignature proves the log verified clean at a time, not that a match was correct or that the use was lawful. The report supports a compliance conversation; it is not a conformity assessment. Paid ledgers are deleted after 7 days, and the report and attestation are emailed to you to keep.

Next steps

• Run the free EU AI Act Art. 12/14 checker against your current setup.
• Verify a trace free, then get the countersigned report for 29 USD.
• Compare approaches: vs. WORM storage, vs. RFC 3161 timestamping.

See a sample ledger verified in one click, check your own logs free or get the countersigned EU AI Act report.