The proposal states that trust is not a control, and that shared evidence and verifiable improvement are how trust is earned. I want to raise where I think Evidence Preservation currently falls short of that standard.
The list of required evidence is thorough. Prompts, traces, tool calls, logs, configurations, model and safeguard versions, agent and workload identities, permissions and credentials available during the run, human approval and intervention events, artifacts created or modified, detection and containment events, and a complete timeline. I would not remove anything from it.
What the section does not specify is any integrity property for that evidence. Members preserve it, members provide it, and the systems that generated it belong to the member. Where an incident involves a member's own AI system operating in the member's own environment, the resulting analysis rests substantially on the member's account of what happened.
The Review Framework already anticipates this tension. It says the affected organization may correct factual errors but should not have veto power over learnings or recommendations. That is the right instinct, but it assumes the facts are independently establishable. If the only record of an agent's action chain is a log the operating member can modify, an external reviewer has no way to distinguish a corrected factual error from a shaped record.
This matters most for the questions the Review Framework actually asks. Whether a model recognized scope boundaries and stop conditions. Whether classifiers, policies, approvals and action limits operated as intended. Whether escalation paths and kill procedures were followed. All of those are answered from runtime records, and runtime records are the thing most likely to be incomplete after an incident, because the incident is often what revealed the instrumentation gap in the first place.
Suggested direction: specify minimum integrity properties for preserved evidence, not only its contents. Three candidates:
-
Append-only or tamper-evident storage for runtime records, so that post-incident modification is detectable.
-
Cryptographic binding of an action to the context it occurred in, the authorization decision that permitted it, and the outcome that followed, so that the four cannot be separated or reordered after the fact. Timeline reconstruction is only as reliable as the linkage between these elements.
-
Independent attestation of environment configuration where a third-party evaluation or hosting partner is involved.
The third connects directly to the supply chain review question, which asks whether a cloud, evaluation, data or tooling partner invalidated assumed controls. Evidence held solely by the member cannot establish what the partner's environment actually permitted. That question is unanswerable without something from the partner side.
Disclosure: I am a technical contributor to the AARM specification, which addresses part of this problem through runtime policy evaluation, session context accumulation, and tamper-evident receipt generation binding action, context, decision and outcome. I am raising this as a gap in the proposal rather than advocating for a particular implementation. There are other reasonable ways to meet the same requirement, and I would rather see the requirement stated than any specific mechanism named.
Happy to draft language if this direction seems useful.
The proposal states that trust is not a control, and that shared evidence and verifiable improvement are how trust is earned. I want to raise where I think Evidence Preservation currently falls short of that standard.
The list of required evidence is thorough. Prompts, traces, tool calls, logs, configurations, model and safeguard versions, agent and workload identities, permissions and credentials available during the run, human approval and intervention events, artifacts created or modified, detection and containment events, and a complete timeline. I would not remove anything from it.
What the section does not specify is any integrity property for that evidence. Members preserve it, members provide it, and the systems that generated it belong to the member. Where an incident involves a member's own AI system operating in the member's own environment, the resulting analysis rests substantially on the member's account of what happened.
The Review Framework already anticipates this tension. It says the affected organization may correct factual errors but should not have veto power over learnings or recommendations. That is the right instinct, but it assumes the facts are independently establishable. If the only record of an agent's action chain is a log the operating member can modify, an external reviewer has no way to distinguish a corrected factual error from a shaped record.
This matters most for the questions the Review Framework actually asks. Whether a model recognized scope boundaries and stop conditions. Whether classifiers, policies, approvals and action limits operated as intended. Whether escalation paths and kill procedures were followed. All of those are answered from runtime records, and runtime records are the thing most likely to be incomplete after an incident, because the incident is often what revealed the instrumentation gap in the first place.
Suggested direction: specify minimum integrity properties for preserved evidence, not only its contents. Three candidates:
Append-only or tamper-evident storage for runtime records, so that post-incident modification is detectable.
Cryptographic binding of an action to the context it occurred in, the authorization decision that permitted it, and the outcome that followed, so that the four cannot be separated or reordered after the fact. Timeline reconstruction is only as reliable as the linkage between these elements.
Independent attestation of environment configuration where a third-party evaluation or hosting partner is involved.
The third connects directly to the supply chain review question, which asks whether a cloud, evaluation, data or tooling partner invalidated assumed controls. Evidence held solely by the member cannot establish what the partner's environment actually permitted. That question is unanswerable without something from the partner side.
Disclosure: I am a technical contributor to the AARM specification, which addresses part of this problem through runtime policy evaluation, session context accumulation, and tamper-evident receipt generation binding action, context, decision and outcome. I am raising this as a gap in the proposal rather than advocating for a particular implementation. There are other reasonable ways to meet the same requirement, and I would rather see the requirement stated than any specific mechanism named.
Happy to draft language if this direction seems useful.