OAIES Normative Controls

Version: 1.0.1
Published: 2026-07-16
Status: Normative

Purpose

Define the minimum control baseline for OAIES-conformant AI systems. Each requirement is testable and names the objective evidence expected by an assessor.

Why

AI assurance fails when controls describe aspirations instead of observable safeguards. This catalog binds each obligation to applicability and evidence so design adequacy and operating effectiveness can be assessed separately.

How

Apply universal controls first, then every selected workload, autonomy, and impact overlay. Evidence examples are minimum evidence classes, not exhaustive implementation prescriptions. Equivalent evidence is acceptable when it is authentic, scoped, attributable, timely, and reproducible.

Universal Governance and Risk Controls

Control ID	Normative requirement	Applicability	Objective evidence
OAIES-RSK-002	The system owner MUST maintain a risk register covering intended use, foreseeable misuse, affected parties, failure modes, likelihood, impact, safeguards, residual risk, and treatment owner.	Universal	Approved risk register linked to system version and review history
OAIES-RSK-003	Residual risks above the organization’s approved tolerance MUST NOT be accepted by the system owner alone.	Universal	Risk policy, approval matrix, signed acceptance by authorized risk owner
OAIES-MOD-001	The organization MUST define measurable acceptance criteria and evaluate the complete system against representative and adversarial cases before release.	Universal	Versioned evaluation plan, dataset lineage, executable results, threshold decision
OAIES-MOD-002	Production model, prompt, policy, tool, and configuration versions MUST be uniquely identifiable and reproducible.	Universal	Immutable release manifest, hashes/versions, configuration snapshot, rebuild or replay result
OAIES-MOD-003	Material model or prompt changes MUST NOT bypass regression, safety, and security gates.	Universal	Change diff, CI/release gate logs, evaluation comparison, approval record
OAIES-DAT-001	Data used for training, tuning, retrieval, evaluation, or inference MUST have documented provenance, permitted purpose, sensitivity, retention, and responsible owner.	Universal	Data inventory, lineage records, legal basis/license, classification and retention policy
OAIES-DAT-002	Sensitive data MUST be minimized and protected in prompts, logs, memory, evaluation sets, and outputs according to its classification.	Where sensitive data is processed	Data-flow map, minimization decision, access controls, encryption settings, DLP test results
OAIES-SEC-001	Identity and access controls MUST enforce least privilege for models, tools, data stores, administrative interfaces, and service accounts.	Universal	Access matrix, policy configuration, entitlement review, denied-access tests
OAIES-SEC-002	Untrusted input and model output MUST be treated as data rather than executable authority across trust boundaries.	Universal	Threat model, parser/validator policy, sandbox configuration, injection test results
OAIES-SEC-003	Secrets MUST NOT be embedded in prompts, source artifacts, model context, logs, or generated output.	Universal	Secret-scanning results, vault references, redacted telemetry sample, incident review
OAIES-OPS-001	Production releases MUST use an approved, attributable, reversible change process with separation appropriate to impact.	Universal	Release ticket, approver identity, deployment log, rollback plan and exercise
OAIES-OPS-002	The organization MUST monitor safety, security, quality, availability, cost, and policy-relevant events at frequencies justified by risk.	Universal	Monitoring specification, dashboards/alerts, sampled events, alert test and response records
OAIES-OPS-003	AI incidents MUST enter a documented response process that preserves evidence, limits harm, notifies accountable parties, and records corrective action.	Universal	Incident plan, exercise or incident record, preserved logs, notifications, corrective-action closure
OAIES-OPS-004	Users MUST receive accurate notice when they interact with AI or when AI materially influences an outcome, except where lawfully exempted and documented.	User-facing or decision-influencing systems	Interface capture, notice text/version, exemption analysis, usability test
OAIES-ASR-001	Applicable controls MUST be supported by evidence meeting the quality rules in 03.	Universal	Evidence index linked bidirectionally to SoA and immutable evidence objects

P1 — Assistant Controls

Control ID	Normative requirement	Applicability	Objective evidence
OAIES-MOD-010	Assistant output MUST be constrained or reviewed where an unsupported claim could cause material harm.	P1, I2–I3	Output policy, enforcement configuration, test corpus and results, review records
OAIES-MOD-011	The system MUST communicate material capability limits and uncertainty at the point where a user relies on output.	P1	Approved UX copy, rendered interface evidence, user-comprehension test
OAIES-MOD-012	Safety and refusal behavior MUST be tested against domain-relevant harmful, ambiguous, multilingual, and adversarial requests.	P1	Threat-informed test set, run metadata, results, defect remediation

P2 — RAG Controls

Control ID	Normative requirement	Applicability	Objective evidence
OAIES-DAT-010	Retrieval authorization MUST be enforced at query time using the requesting principal and source permissions.	P2 with restricted content	Authorization design, index ACL mapping, positive/negative access tests, query audit logs
OAIES-DAT-011	Retrieved content MUST retain source identity, version or retrieval time, and trust metadata through generation.	P2	Indexed metadata schema, response trace, citation/provenance tests
OAIES-DAT-012	The system MUST evaluate retrieval relevance, coverage, grounding, and resistance to content-based instruction injection before release.	P2	Curated evaluation set, metric definitions, thresholds, run results, poisoning/injection tests
OAIES-DAT-013	Stale, revoked, or deleted source content MUST be removed from serving indexes within a documented risk-based service level.	P2	Freshness SLA, deletion propagation logs, reconciliation report, stale-content alert test

P3 — Coding Agent Controls

Control ID	Normative requirement	Applicability	Objective evidence
OAIES-AGT-010	Code execution MUST occur in an isolated environment with bounded network, filesystem, identity, compute, and time permissions.	P3 with execution	Sandbox policy/configuration, escape and egress tests, resource-limit logs
OAIES-AGT-011	Generated code MUST pass deterministic tests, static analysis, dependency, license, and secret checks appropriate to the repository before merge or deployment.	P3 producing code	Required-check configuration, CI logs, branch protection, blocked-failure example
OAIES-AGT-012	Security-sensitive or production-impacting code changes MUST receive independent human approval from an authorized reviewer.	P3, I2–I3	CODEOWNERS/approval policy, pull-request approvals, reviewer authorization record
OAIES-SEC-010	Agent-selected dependencies MUST be resolved through approved registries and verified against integrity and vulnerability policy.	P3 adding dependencies	Registry policy, lockfile/signature or hash verification, SCA report, exception record

P4 — Transactional Agent Controls

Control ID	Normative requirement	Applicability	Objective evidence
OAIES-AGT-020	Every external action MUST pass deterministic authorization, schema validation, policy, and idempotency controls outside the model.	P4	Policy-as-code/configuration, action schema, replay/idempotency tests, allow/deny logs
OAIES-AGT-021	Consequential or irreversible actions MUST require informed human approval bound to the exact action payload before execution.	P4, I2–I3	Approval UX capture, signed payload/hash, approver identity, execution correlation ID
OAIES-AGT-022	Reversible actions MUST have a tested compensation or rollback path before autonomous production execution.	P4, A2–A3	Rollback procedure, test results, recovery objectives, exercise record
OAIES-AGT-023	Action limits MUST bound value, rate, scope, destination, and cumulative exposure independently of model instructions.	P4, A2–A3	Runtime limit configuration, boundary tests, limit alerts, blocked-action logs

P5 — Multi-Agent Controls

Control ID	Normative requirement	Applicability	Objective evidence
OAIES-AGT-030	Delegation MUST NOT increase permissions, data access, or action authority beyond the initiating principal and approved workflow.	P5	Delegation protocol, capability tokens/policies, privilege-escalation tests, trace sample
OAIES-AGT-031	Every inter-agent message and action MUST be attributable to agent identity, version, parent task, and initiating principal.	P5	Trace schema, immutable end-to-end trace, correlation tests
OAIES-AGT-032	Orchestration MUST enforce termination conditions for cycles, fan-out, cost, time, and repeated failure.	P5	Orchestrator limits, loop/fan-out tests, cutoff telemetry, incident procedure
OAIES-AGT-033	Conflicting agent outputs MUST be resolved by an explicit deterministic or human-governed policy before consequential action.	P5 producing consequential action	Conflict policy, scenario tests, decision records and trace

P6 / I3 — High-Impact Controls

Control ID	Normative requirement	Applicability	Objective evidence
OAIES-RSK-010	A high-impact system MUST complete an impact assessment covering affected groups, rights, safety, accessibility, discrimination, contestability, and cumulative effects before production use.	P6 or I3	Approved impact assessment, stakeholder input, mitigation tracking
OAIES-RSK-011	High-impact deployment MUST have independent pre-release assurance and an organization-approved reassessment interval derived from impact, change rate, incident history, applicable obligations, and claim period; that interval must be shorter than the approved interval for otherwise comparable lower-impact systems.	P6 or I3	Assessor independence declaration, assessment report, approved cadence decision with risk rationale and legal mapping, claim-period record, reassessment schedule
OAIES-RSK-012	Affected persons MUST have an accessible path to explanation, correction, contest, and human review of material adverse outcomes.	P6 or I3 affecting persons	Procedure, interface evidence, service metrics, sampled cases and resolutions
OAIES-MOD-020	High-impact performance MUST be evaluated for relevant subgroups, operating conditions, and foreseeable distribution shifts using domain-approved thresholds.	P6 or I3	Evaluation protocol, subgroup results, threshold approvals, drift tests
OAIES-OPS-010	The operator MUST maintain and test an immediate safe-stop, fallback, or service-withdrawal mechanism.	P6 or I3; A3–A4	Mechanism design, access authorization, exercise results, recovery record
OAIES-ASR-010	High-impact evidence MUST be retained under an approved records schedule that accounts for applicable jurisdictional, regulatory, contractual, claim-period, appeal, incident, investigation, and litigation-hold needs and receives independent legal or records-management approval before disposal.	P6 or I3	Approved records schedule and legal mapping, claim and appeal periods, hold register, disposition approval, integrity and retrieval tests

A2–A4 Autonomy Overlay

Control ID	Normative requirement	Applicability	Objective evidence
OAIES-AGT-040	Tool access MUST use explicit allowlists, least-privilege credentials, argument constraints, and default-deny behavior.	A2–A4	Tool registry, IAM/policy configuration, denied-tool and invalid-argument tests
OAIES-AGT-041	Memory that can influence future actions MUST have provenance, access control, retention, integrity protection, and a deletion mechanism.	A2–A4 with persistent memory	Memory schema, ACLs, integrity test, retention/deletion logs
OAIES-AGT-042	Operators MUST be able to suspend autonomous execution without model cooperation.	A2–A4	Out-of-band control design, authorized operator list, kill-switch exercise
OAIES-AGT-043	Autonomous decisions and actions MUST produce tamper-evident traces sufficient to reconstruct inputs, policy decisions, tool calls, approvals, outputs, and outcomes.	A2–A4	Trace specification, integrity controls, sampled reconstruction test

Guidance

Use policy-as-code for deterministic gates, append-only telemetry for action reconstruction, and automated evidence collection from source systems. Calibrate evaluation thresholds against domain harm, not generic benchmark performance. Guidance does not reduce or add controls.

Tradeoffs

Control posture	Benefit	Cost
Deterministic action gates	Prevents model output from becoming authority	Reduces flexibility and increases schema maintenance
Cumulative profile controls	Covers compound workload risk	Larger control set
Independent high-impact assurance	Stronger challenge and credibility	Cost, schedule, specialist availability
Tamper-evident traces	Reconstructable accountability	Storage, privacy, and redaction complexity

Anti-patterns

Model-only authorization: asking the model whether an action is allowed.
Benchmark compliance: treating one aggregate quality score as proof of safety.
Human-in-the-loop theater: approval without the exact payload, context, authority, or time to review.
Log dumping: collecting unstructured telemetry that cannot reconstruct a decision.
Supplier delegation: assuming a provider’s certification proves the integrated system conforms.

Enterprise Considerations

Implement controls through enterprise sources of truth: CMDB/system inventory, IAM, data catalog, model registry, CI/CD, GRC, SIEM, and records management. Preserve segregation between system ownership, risk acceptance, and independent assessment for I3 systems. Contract suppliers to provide incident notice, change notice, provenance, security assurance, audit access, and deletion evidence.

Checklist

Universal controls are mapped to owners and evidence.
Controls for every selected profile are applied cumulatively.
Autonomy and high-impact overlays are included.
Deterministic safeguards operate outside the model.
Evaluation thresholds are approved and release-blocking.
Action and decision traces are reconstructable.
High-impact controls have independent assurance.

Authoritative References

Changelog

Version	Date	Change
1.0.1	2026-07-16	Replaced fixed high-impact retention and reassessment periods with approved risk-, jurisdiction-, records-, and claim-based decisions.
1.0.0	2026-07-16	Established universal, profile, autonomy, and high-impact control baselines.