Risk · R-060 · Agentic & Autonomous Systems

Untraceable agent actions

Actions taken by agents cannot be reconstructed or attributed to an instruction, a decision and an accountable person, so errors cannot be investigated and accountability fails.

Severity
High
Audience
Heads-of · Practitioner
Frameworks
Article 12 · AML.M0024 · Accountability · ASI10
Reviewed
2026-11-10

What it is

To account for an agent's action the organisation needs to know what was asked, by whom, what the agent planned, which tools it called with which parameters, what came back, and under whose authority it acted. Ordinary application logs capture the final call at most. This entry is the agent-specific case of record-keeping failure: the reasoning and the delegation chain are part of the record, and they are lost unless deliberately captured.

How it happens

  • Only the final output is stored; intermediate steps are discarded.
  • Agent actions are logged under a shared account.
  • Traces are kept by the model provider and expire.
  • Sub-agents log separately with no common identifier.

Why it matters

After an incident the questions are what happened, why, and who is responsible. If they cannot be answered, the organisation cannot correct the cause, cannot tell affected people or a regulator what occurred, and cannot show that its controls worked.

Warning signs

  • A past agent action cannot be replayed from records.
  • Logs show the action and omit the instruction that led to it.
  • Retention of traces is shorter than the period in which disputes arise.
  • Different agents' logs cannot be joined.

Who owns it

The agent's owner is accountable for its record. Engineering implements tracing. Records management sets retention. Internal audit tests that a sample of actions can be reconstructed.

In practice

A customer disputes a change of address made on their account. The system shows that an agent made the change. It does not show which conversation led to it, what the agent was told, or whether verification took place. The same pattern generalises to any agent whose actions may later need to be explained.

Mitigating controls

Primary controls

Agent action tracing Detective
Records each action with the instruction, plan, tool call and identity behind it. Every agent action is recorded with the instruction, plan, tool call, result and identity that produced it, in a form that allows the sequence to be reconstructed.
AI record-keeping and audit trail Detective
Retains the trace as part of the audit trail. Inputs, outputs, model and prompt versions, decisions and human interventions are recorded automatically and retained for a defined period, so that any past event can be reconstructed.

Supporting controls

AI ownership and accountability framework Directive
Names who answers for each agent. Every AI system has a named individual accountable for it as a whole, and a named senior individual is accountable for AI risk across the organisation, with defined reporting lines.

Framework and clause references

FrameworkClauseTitle
EU AI ActArticle 12Record-keeping Recording of events.
MITRE ATLASAML.M0024AI Telemetry Logging and Monitoring Telemetry logging.
OECD AI PrinciplesAccountabilityAccountability Accountability requires traceability.
OWASP Top 10 for Agentic ApplicationsASI10Rogue Agents Tracing is how rogue behaviour is found.

Sources

EU AI Act: Regulation (EU) 2024/1689 European Union (EUR-Lex) · official text
OECD AI Principles OECD · official text
MITRE ATLAS MITRE · framework

Related terms

How to cite

Axiom Verity (2026). Untraceable agent actions. Reference Library, R-060. https://axiom-verity.com/risks/untraceable-agent-actions. Reviewed 2026-11-10.