Obligations
These are not our requirements. They exist, they have names, and somebody in your organization already signs them. The column that matters is the last one.
On this page
The instruments
Each instrument below assigns responsibility for a decision to a named party. That is an achievement of modern regulation, and none of it is going away. The open question has never been whether to require the signature.
It is what stands behind it. We have set out what each instrument asks for and what the evidence behind it consists of today. Sources for every row are on the evidence page.
| Instrument | Who signs | What it rests on today |
|---|---|---|
| EU declaration of conformity EU AI Act, Article 47verified at source | The provider | The provider’s own conformity assessment. For most high-risk systems, the permitted route is internal control under Annex VI — that is, self-assessment, with no notified body involved. |
| Self-authenticating electronic records Fed. R. Evid. 902(13), 902(14)verified at source | A qualified person | A written certification by a qualified person. This is the closest any instrument comes to what we are describing, and it still runs through a person supplied by the party producing the record. |
| Authorization to operate NIST SP 800-37 Rev. 2, Risk Management Framework, December 2018verified at source | The authorizing official | An authorization package assembled by the system owner, from the system owner’s own artifacts, at a point in time. |
| Model risk management SR 26-2 / OCC Bulletin 2026-13 (Federal Reserve, FDIC and OCC), 17 April 2026, superseding SR 11-7verified at source | The institution | “Effective challenge” by objective experts with “sufficient independence to maintain objectivity” — evidenced by the institution’s own records of having performed it. The revised guidance excludes generative and agentic AI from its scope; a request for information on those systems is promised. |
| Management assertion on internal control Sarbanes-Oxley Act of 2002 §404; 15 U.S.C. §7262verified at source | Management | Management’s assessment of its own controls, attested to by management; the auditor tests them, working from the organization’s own systems and records. |
| Reliability standards compliance NERC Critical Infrastructure Protection standards, enforceable under Federal Power Act §215, 16 U.S.C. §824overified at source | The registered entity | The entity’s own evidence, retained and produced on audit. |
| Operational resilience Regulation (EU) 2022/2554 (DORA), in application since 17 January 2025verified at source | The financial entity | The entity’s own registers, its own incident reporting, and its own testing results. |
The pattern
Every instrument on this page, and every one we have examined, rests on records the signing party produced about itself. That is no criticism of the regimes, which had nothing else available to them: no one can require evidence that no one can produce.
It is also the one thing an architecture can change, and the reason the two are complements rather than rivals. The regime supplies the obligation and the named signatory. What has been missing is anything for that signature to rest on other than the signer.
Architecture is what makes an attestation worth signing: when the evidence is a by-product of the system running, and anyone you authorize can check it without the operator’s cooperation, the declaration stops being a promise about the past and becomes a finding about it.
The closest case
Rule 902(13) of the Federal Rules of Evidence is the most instructive item on this page. It makes a record generated by an electronic process self-authenticating, so that no live witness is needed to get it admitted. That is a long way further than any of the others go.
It gets there by way of a written certification from a qualified person, and the rule leaves the choice of that person to the proponent, the party offering the record. Self-authenticating is not the same as verifier-independent. One removes the need for a witness at trial. The other removes the need for the producing party’s cooperation at all. The distance between those two ideas is the distance between the instruments on this page and the test this site applies.
Next
If one of them does not land, nothing else here matters.
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