Incidents¶
opencomplai incident keeps a local register of serious incidents (Art. 73) and a signed log of every change to it. It watches notification deadlines for you. It does not file anything, and it does not decide whether an event is a reportable incident.
Deadlines are provisional
The day counts below are shipped as data with confidence: low and needs_founder_review: true. They are the author's unverified reading, marked "lawyer to confirm". They are a working aid, not a statement of the legal period. Confirm the applicable period yourself.
Two files¶
| File | What it is |
|---|---|
incident-register.json | The current state: one record per incident (declaration, awareness time, class, notifications, closure). Free text such as the description and closure note stays here. |
incident-log.json | An append-only, hash-chained, signed log. Each declare, classify, notify and close adds one entry of structured fields only (ids, class, timestamps, party kind, name and reference). No free text. |
The commands are described in incident. The log is checked with opencomplai verify incident-log.json --kind incident-log (verify): exit 0 when the chain and signatures hold, 1 when entries are unsigned or the log was edited, reordered or shortened in the middle. Dropping the newest entries is only detectable against a head you stored elsewhere.
declare and close also move the system state (running to incident_mode and back). The log entry is written first, so a refused state change never loses the entry.
Deadline clocks¶
A clock runs from the awareness time you record, not from the declaration time. Its length depends on the incident class:
| Class | Days from awareness |
|---|---|
death | 10 |
critical_infrastructure | 2 |
widespread_infringement | 2 |
health_harm | 15 |
fundamental_rights | 15 |
property_environment | 15 |
unclassified | no clock |
Each of these rows is stored with:
source:Regulation (EU) 2024/1689 Art. 73 (reading unverified)confidence:lowneeds_founder_review:truenote: "Proposed day count; lawyer to confirm." (forunclassified: no clock until the incident is classified)
An incident with no class has no deadline. The first authority notification decides whether the deadline was met.
No scheduler¶
Nothing here runs in the background. A deadline, a "due soon" state (within 24 hours) and an "overdue" state are computed at the moment you ask, from the register and the time of the question, through an injected clock. OPENCOMPLAI_NOW fixes that time for tests and CI. incident export shows the absolute deadline and prints no current date, state or relative days, so the same record always exports the same bytes.
Evidence in the gap report¶
An incident-log.json in the repository root, and a post-market monitoring plan file, are the evidence Arts. 72 and 73 read in the gap report. Both rows stay at partial at most, and the incident log also feeds QMS clauses (h) and (i). A log that exists is evidence that a process runs, not that it works.
What leaves your machine¶
The register's free text never leaves it. The scan artifact can carry an incidents summary of leaf values only (incident id, class, open or closed, dates, party kinds and counts); see Published schemas. The templates for an authority report and a downstream notice (incident template) are drafts: low confidence, flagged for founder review, and not legally reviewed.