Logging and human oversight: the minimum evidence a deployer needs
Two of the Art. 26 duties are the ones auditors actually test for. What has to exist on day one, and what can be built up later.
Oversight and logging are where deployer programmes fail, because both are easy to assert and hard to evidence. A human reviews the output is an assertion. Who, when, against what criteria, and what happens when they disagree — that is evidence.
Human oversight, minimum viable version
- The named role or roles authorised to review, with what competence and what training.
- Which outputs require review before they take effect, and which do not.
- What the reviewer is checking against.
- What happens on disagreement — including the authority to stop.
Logging, minimum viable version
- What the system exposes automatically, confirmed with the provider rather than assumed.
- Retention period, set deliberately and written down, not left to the default.
- Who can read the logs, and how a review is recorded.
- Whether the logs are enough to reconstruct a specific decision after the fact.
That last one is the test. If you cannot reconstruct why a particular output was acted on, the log is decorative. AnnexPath asks for these facts and reports what is missing; it does not manufacture an oversight description from a job title.
This is drafting support, not compliance assurance. Test the controls you describe.