# Briefing Note for AI & Technology Practice Groups

**From:** Arian Gogani, Maintainer, Nobulex
**Re:** Tamper-evident logging for AI agents under EU AI Act Article 12
**Date:** April 2026

## The question your clients will ask

Article 12 of the EU AI Act takes effect August 2, 2026. For any high-risk AI system, it requires logs that are automatic, tamper-evident, and sufficient to enable post-incident investigation.

General counsel at your clients are already asking a specific version of this question: our AI agents are making decisions in production, how do we generate a record a regulator will actually accept.

The Act does not name a tool. That gap is where outside counsel gets the call. This note is a resource for that call.

## What tamper-evident actually requires

A log file written by the same system that ran the agent is not tamper-evident. If the system that produced the evidence can also edit the evidence, the evidence is circumstantial at best.

Meeting Article 12 cleanly means three things:

1. A signed record that the agent was authorized for a specific action before it ran.
2. A signed record of what the agent actually did after.
3. Both records cryptographically bound, so an auditor can confirm they came from the same session and the authorization matches the outcome.

Most AI logging tools in the market today handle the second item. Very few handle the first and third.

## What Nobulex is

Nobulex is an open source protocol, MIT licensed, that issues two signatures per agent action. One before execution, committing the agent to a specific action under a specific policy. One after execution, binding the actual result to the first. Both receipts are hash chained, so a full session can be replayed and verified independently by anyone holding the public key.

Reference implementations exist in TypeScript and Python. They produce byte identical digests across both languages, which matters for one practical reason: a receipt generated by one system can be verified by a completely different system without trusting the operator.

## Where it is today

Merged into Microsoft's Agent Governance Toolkit as the bilateral receipt primitive (PR 1333, April 22, 2026). OpenSSF Best Practices passing level, self-certified against Linux Foundation criteria. Receipt format under active review by OpenLineage (a Linux Foundation project) as an attribution facet. Referenced in a proposal to the in-toto attestation framework. Nineteen independent contributors across LangChain, AutoGen, CrewAI, NousResearch, and others.

Nobulex is a protocol rather than a vendor. There is no SaaS, no lock-in, and no license fee.

## Three questions worth putting in front of clients

1. Can you produce a cryptographic receipt for every agent action, signed with a key outside the agent runtime?
2. Can a third party verify that receipt without trusting your infrastructure?
3. Is the receipt format an open standard that a court appointed expert could validate independently?

A vendor that answers no to any of the three has a documented compliance gap. Clients will want that in writing before the deadline, not after.

## If this is useful

The spec is at github.com/arian-gogani/nobulex. Readable in under thirty minutes. A competent compliance engineer can integrate the reference implementation in under a day.

Happy to answer any specific client question that surfaces, or to provide a longer technical briefing for your practice group.

## Contact

Arian Gogani
nobulex.dev@gmail.com
github.com/arian-gogani/nobulex
nobulex.com
