OpenTelemetry spans give engineers visibility into AI agent execution. Under EU AI Act Articles 9 and 13, that visibility is not evidence. Here is what the gap looks like structurally and how to close it.
Distributed Tracing Shows You What Happened. It Cannot Prove It to a Regulator.
Engineers instrumenting AI agents with OpenTelemetry make a reasonable assumption: if I can trace every tool call, model invocation, and decision branch, I have an audit trail. Regulators under EU AI Act will disagree. The distinction matters, and it is structural.
What Distributed Tracing Actually Captures
A typical OpenTelemetry span for an AI agent call looks like this:
