diff --git a/docs/verification.md b/docs/verification.md index ead7679..7ec8998 100644 --- a/docs/verification.md +++ b/docs/verification.md @@ -141,18 +141,57 @@ before this field existed valid and correctly interpreted. ### Profile floors -Deployment profiles select the minimum acceptable verified depth: +Deployment profiles select the minimum acceptable verified depth. Every floor below is a +choice this specification makes for deployments that describe themselves as operating under +the named regime, rather than a requirement derived from that regime. Neither regulation +discussed in the next section requires a verification depth at all. | Profile | Floor | |---|---| | Default, SLSA L0 to L1 | `surface` | | SLSA L2 and above | `builder` | -| FIPS-aligned, EU AI Act Annex IV high-risk, HIPAA | `transitive` | +| FIPS-aligned, EU AI Act Article 6 high-risk, HIPAA | `transitive` | | cMCP reference profile | `builder`, with `transitive` recommended where ecosystem coverage permits | A verifier whose configured floor is not met by `provenance_depth_verified` sets `appraisal.status` to `contraindicated`. +### Regulatory context for the profile floors (informative) + +The floors above name the EU AI Act. This section records what that Regulation actually +requires, together with the Cyber Resilience Act, which is the instrument most often reached +for in its place. Verification at any depth is not evidence of compliance with either of +them, and neither is a floor that is met. + +**Regulation (EU) 2024/1689.** Annex IV is the technical documentation schedule whose +elements Article 11(1) requires the technical documentation to contain at a minimum. It is +not a classification annex, since high-risk classification runs through Article 6 with +Annexes I and III, and neither Article 11 nor Annex IV imposes a verification obligation of +the kind `provenance_depth_verified` records. Two adjacent provisions are sometimes read as +supplying one, and neither does. Article 25(4), as amended by Regulation (EU) 2026/1744, +requires the provider of a high-risk AI system and a third party supplying an AI system, AI +model, tools, services, components or processes used or integrated in it to specify by +written agreement the information, capabilities, technical access and other assistance the +provider needs, and it does not apply to third parties making tools, services, processes or +components other than general-purpose AI models publicly available under a free and +open-source licence. Article 15(5) requires technical solutions addressing, where +appropriate, data poisoning, model poisoning, adversarial examples, confidentiality attacks +and model flaws, which is stated as an outcome rather than as a depth of supply-chain +verification. Articles 11, 15 and 25 sit in Sections 2 and 3 of Chapter III, whose +application Regulation (EU) 2026/1744 moved to 2 December 2027 for systems high-risk under +Article 6(2) and Annex III, and to 2 August 2028 for systems high-risk under Article 6(1) +and Annex I, subject to the Article 111(2) grace period for units of a type and model +already placed on the market. + +**Regulation (EU) 2024/2847.** Annex I Part II point 1 requires manufacturers to identify +and document vulnerabilities and components, including by drawing up a software bill of +materials in a commonly used and machine-readable format covering at the very least the +top-level dependencies of the product. That is a component inventory obligation, so it does +not by itself establish `builder` or `transitive` verification, both of which are claims +about provenance rather than about composition. Its Annex I obligations apply from +11 December 2027, with the reporting obligations in Article 14 applying from +11 September 2026. + ### Why depth is recorded rather than assumed A SLSA attestation produced by a trusted builder is signature-valid even when a maintainer's CI