AI audit log retention: how long EU AI Act, HIPAA, and DORA expect you to keep per-decision records
AI audit log retention is governed by four overlapping regimes that produce different minimum windows on the same record. The EU AI Act Article 12 expects logs across the deployment lifecycle for high-risk systems, with Article 19 fixing a 10-year period for the records the conformity-assessment file references. HIPAA 45 CFR 164.530(j) fixes six years from creation or last effective date. DORA Article 19 fixes a minimum of five years for ICT-related incident records, with longer windows where the supervisor requests them. The retention schedule has to be set to the longest applicable window per record and the storage tiering, tamper-evidence and GDPR deletion handling have to be designed against that window.
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