01
Agents as employees
An AI agent is modeled the way a regulated company models a person: it is an identity that holds exactly one role at a time. The role is the unit of authority. Nothing an agent does is anonymous, and nothing it can do is implicit — capability flows only through the role it wears.
Maps toAttributability — the ALCOA “Attributable” principle.
02
Versioned skill grants
A role is a key ring. Each grant opens one specific door — a tool, a connector, a skill — and everything not granted is denied. Grants are versioned, so you can reconstruct exactly what any agent was permitted to do on any past date. This is the difference between a control and a fence: a tool list hard-coded by the developers who built the agent has no record of who approved it, no history, and no revocation trail.
Maps toAccess limited to what is explicitly granted; authority checks (e.g. 21 CFR §11.10(d)/(g)).
03
Structural segregation of duties
If an agent prepared the work, it is impossible — not discouraged, impossible — for that agent’s role to approve it. The separation is enforced structurally inside the run, at runtime, by construction. The attempt is refused and the refusal lands in the log. No tracker, content filter, or scoped credential can express “may prepare or approve, but never both on the same item.”
Maps toMaker-checker; quality-unit independence (e.g. 21 CFR §211.22).
04
Human approval gates
A gate is a step in the workflow, not a notification bolted on afterward. It demands a quorum — n of m named approvers — and the human who requested the action can never be one of them. When a person signs, their reason is captured verbatim and bound to the decision, so the signature carries its meaning.
Maps toSignature with recorded meaning (e.g. 21 CFR §11.50).
05
Role limits
A role carries the limits of its authority: a monetary threshold above which a human must sign, a cap on how many times a skill may fire, a budget on tokens. Limits are set and owned by the compliance side, not the developers who build the agent — and when a limit is reached, the system fails closed.
Maps toDelegated-authority limits.
06
Signed audit ledger
Every action, every model call, every approval lands in a sealed, append-only chain. Change one record and the whole chain visibly breaks. You can export a signed evidence bundle that a regulator verifies offline — with zero access to our systems or yours — against a published, open formula anyone can reimplement. Trust does not depend on trusting us.
Maps toAudit trails and signature linking (e.g. 21 CFR §11.10(e), §11.70).