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EU AI Act for logistics and delivery teams

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

Where this sector lands

Most logistics AI optimises things, not people: route planning, load building, slotting, demand forecasting and ETA prediction are not in Annex III. Road traffic management is in point 2, but that concerns traffic authorities operating the network, not fleets using it.

The line is crossed when the system manages people. Annex III point 4(b) covers AI used to allocate tasks based on individual behaviour or personal traits and to monitor and evaluate the performance and behaviour of people in work relationships. The heading of point 4 also covers access to self-employment. That describes:

• warehouse systems that assign pick lists by individual speed and flag slow workers;
• courier platforms that dispatch jobs by acceptance rate and deactivate accounts;
• productivity dashboards that rank drivers or pickers.

Article 5(1)(f) also bans emotion recognition at work, except for medical or safety reasons. The EU Platform Work Directive adds its own rules on algorithmic management for platform couriers.

The logging duties that follow

• Art. 12 (providers): the workforce system records events automatically, so any allocation or deactivation can be traced.
• Art. 19 (providers): keep logs under your control for at least six months.
• Art. 26 (deployers), the logistics operator or platform: competent human oversight (Art. 26(2)), logs kept for at least six months (Art. 26(6)), and informing workers' representatives and affected workers before putting the system into service (Art. 26(7)).

See HR tech for employment AI in general, and retention under Art. 26.

On timing: the Digital Omnibus agreement moves Annex III high-risk obligations to December 2027 (details and caveats).

What counts as evidence

A deactivated courier or a warned picker will ask what the system measured and who decided. The chain should hold the metric, the rule and the human review.

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

{"seq":1,"type":"tool.result","data":{"name":"courier_metrics","output":{"courier":"cr_90412","accept_rate_30d":0.62,"late_pct":0.04}}}
{"seq":2,"type":"policy.decision","data":{"kind":"tool.call","action":"block","hits":[{"rule":"no-auto-deactivation"}]}}
{"seq":3,"type":"tool.call","data":{"name":"ops_review","input":{"reviewer":"ops_27","finding":"zone_closure_week_36","action":"none"}}}
{"seq":4,"type":"run.end","data":{"status":"ok","deactivated":false}}

The blocked deactivation and the reviewer's finding are what show a person, not a threshold, made the call.

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 runs that allocate work, rate a person or change account status, and keep the attestation with the worker record for the retention period.

Limits, stated plainly: the countersignature proves the log verified clean at a time, not that the allocation or decision was fair. 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. OpenTelemetry alone, vs. Langfuse.

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