Don’t take my word for it. Make the policy refuse something.
Your AI agents will be reviewed. I make sure you can account for what they did.
Every enterprise AI program eventually meets one question: which agent did that, on whose authority, and can you prove it? Below is a working evaluator answering it — not a recording, not a mock-up.
Change any field. The decision, the rule that carried it, the evidence record and its digest all change with it.
The grant covers the action, but it is a shared account — so no reviewer could later say which person authorized this. Consequential actions require an authority that resolves to someone.
Evidence record · what a reviewer finds months later
action adjust_limit requires write:limits principal svc:shared attributable no — shared account checkpoint n/a rule R2 · attributable authority decision DENY
digest bdac8aa1 · changes with any field above.
What this shows: changing the context changes the decision, and the record changes with it. What it does not show: no business system is connected, and the checksum is not a signature. A real evidence system needs trusted retention, provenance and independent verification.
Both instruments compute locally. No request leaves this page.
Need native AI in production, owned by your team?
I work as your forward-deployed engineer: inside your team, across the whole stack, with the first evaluated slice in three to four weeks of data access.
Refusal is the easy half.
Any gateway can block a call. What almost no stack produces is the record that makes a refusal — or a permission — defensible to someone asking about it eleven months later.
That is the difference between a control and evidence of a control. It is also the difference a reviewer is trained to find, because the control is what you tell them and the evidence is what they can test.
Most programs arrive at this backward: the policy engine goes in first, the log is whatever the platform happened to emit, and the reconstruction problem is discovered during the first examination — when the answer has to already exist.
Instrument I answers all six for one action. Instrument II answers them for a sequence, and shows what happens when the sequence is edited.
Four layers, in dependency order.
Each layer depends on the one above it, which is why the order is not a matter of taste. The evaluator works because the first two are in place. The third is what makes it survivable afterward. The fourth is what makes it defensible to someone whose job is to disbelieve you.
Entitlements
An agent can only act inside an authority someone actually granted it.
authority granted, scoped, recorded
Policy enforcement
At the point of action — not in a document nobody reads.
a gate at the point of action
Attestation & audit
Months later, reconstruct what happened and why it was permitted.
the record that reconstructs the action
Model risk governance
That satisfies a reviewer, not just a dashboard.
validated against what it may do
Five surfaces. Four layers. Twenty cells, one question.
The five surfaces are where the work happens. The four layers are how any one of them is governed once it exists. Breadth here reads as a system rather than a list because every cell resolves to the same question: which agent did that, on whose authority — and can you prove it?
| Layer ↓ / Surface → | Agent protocols & orchestration | Context graphs & permission-aware retrieval | Security of the agentic stack | Sovereign & open-weight AI | Model risk & validation for agents |
|---|---|---|---|---|---|
| Entitlementsauthority granted, scoped, recorded | Agent-to-agent delegation contracts: who may invoke whom, and on whose authority | Retrieval scoped to the caller's own entitlements, not the index's | Non-human identity issued at machine rate; least agency by default | Who may load which weights, in which jurisdiction | Model inventory keyed to the actions each model may authorize |
| Policy enforcementa gate at the point of action | Control plane and data plane separated; idempotency and compensation | Purpose limitation and minimum necessary enforced at query time | Trust boundaries and egress control; content is not instruction | Residency gates on cross-border inference | Action-class limits derived from the validation outcome |
| Attestation & auditthe record that reconstructs the action | The call graph is not the authority graph — record both | Permission receipts for every document an agent was shown | An incident record that survives the credential being rotated | Evidence held inside the boundary it attests to | Decision records a validator can score, not a dashboard |
| Model risk governancevalidated against what it may do | Effective challenge of the orchestration, not only the model | Retrieval drift monitored as a model risk, because it is one | Adversarial pressure inside the validation plan | Open-weight parity measured on your workflow, not a leaderboard | Fed SR 26-2 and OCC 2026-13 applied to systems that act |
Where a capability is bought rather than assembled, that is an engagement. Where the regime decides what evidence you owe, that is a sector.
No client names. So the work has to speak.
There are no logos on this site and there never will be. What exists instead is a research program anyone can inspect — and, where the sample is too small to mean anything, a published refusal to quantify it.
A sector median is published at twelve runs, and not before.
Below that the number says more about who happened to take the assessment than about the sector, and publishing it would be exactly the kind of unsupported quantification this practice exists to challenge.
Currently held back — Banking (3) · Other regulated industry (2) · Healthcare & life sciences (1)
Only runs at 60% completeness or better are counted. Rows carry no organization, no email and no IP address, so nothing here can be traced to a respondent — including by me. The rubric is fixed and deterministic: the same answers always produce the same score, which is what makes comparison meaningful at all.
Agent governance readiness benchmark
What organizations actually score across entitlements, enforcement, attestation and model risk.
02 · Method available · collecting evidenceOpen-weight parity evaluation
Whether a model you control can match a hosted one on the specific workflow, measured rather than argued.
03 · Method available · collecting evidenceAgentic incident patterns
What actually went wrong in public agent incidents, reduced to the failure that carried it.
04 · Open question · no findings yetOpen problems in agent governance
The questions this practice does not have good answers to, published deliberately.
Your score is only useful next to the obligation.
Every obligation lives in a different document, written by a different body, in a different decade. None of them mention agents. All of them apply. This is the map the work is built against — not a compliance product, a reading of what evidence each regime asks you to produce.
| Jurisdiction | Instrument | What it actually asks you to evidence | Layer |
|---|---|---|---|
| US banking | Model Risk Management: Revised Guidance (OCC Bulletin 2026-13 / Fed SR 26-2) | Effective challenge by someone independent, ongoing monitoring, and a validation record covering what the system may do — not only what it predicts. | 03 · 04 |
| US health | HIPAA Security Rule — audit controls and minimum necessary | Minimum necessary as a decision you can show, and audit controls over every access — including the ones an agent made on a clinician's behalf. | 01 · 03 |
| India | DPDP Act — significant data fiduciary audit obligation | Purpose limitation enforced at retrieval time, and erasure that reaches the copies an agent made downstream. It reads as a privacy law and specifies an architecture. | 01 · 02 |
| India | FREE-AI committee framework | Accountability that resolves to a person inside the regulated entity, and fairness testing that survives the model being swapped. | 01 · 04 |
| Gulf | Guidance on the use of artificial intelligence | Supervisory expectations on outsourcing, residency and board-level oversight of automated decisioning. | 03 · 04 |
| Europe | EU AI Act | Logging, human oversight and post-market monitoring for high-risk use. A delay in the timetable is not a reprieve from the architecture. | 02 · 03 |
Every entry links its primary source. The full register, with force status and review dates, is the regulatory radar.
Seven sectors. The same question, asked by a different reviewer.
Banking
Where model risk management meets systems that act.
2026 interagency model risk guidance (OCC 2026-13) · Internal audit & effective challenge
Capital markets & investment advisers
The supervisor has already named the problem. Most firms have not answered it.
FINRA 2026 Regulatory Oversight Report · SEC examination priorities
Payments & agentic commerce
Agents are spending money. No rulebook defines what an agent is.
Nacha fraud-monitoring rules (phased 2026) · PCI DSS · card network rules
Insurance
Claims and underwriting decisions an agent can now make alone.
NAIC model bulletin on AI use · State DOI expectations
Healthcare & life sciences
Agents touching patient records, clinical workflow and regulated submissions.
HIPAA Security & Privacy Rules · Clinical decision support boundaries
Sovereign & critical infrastructure
National platforms, public data estates, and residency that is not negotiable.
India DPDP Act · Data residency & localization
Gulf financial institutions
Central-bank expectations translated into evidence a reviewer can inspect.
CBUAE AI/ML Guidance Note — issued 11 February 2026 · CBUAE Model Management Standards
Three doors. Pick the one that matches how far along you are.
Agent governance review
A fixed-scope diagnostic on whether your agent architecture can be accounted for under review.
Monthly retainerFractional AI architect
Senior architecture ownership, embedded with your team, through the stretch where the decisions are irreversible.
DeliveryDesign and build
The governance layer itself — entitlement, policy-enforcement and attestation architecture — taken to production.
08 · One question, eleven months later
