From 6f67655af29ddac201090b58319fee1dcb0f96d5 Mon Sep 17 00:00:00 2001 From: Ioana Valea Date: Wed, 9 Sep 2026 09:44:49 +0300 Subject: [PATCH] docs(verification): state profile floors as specification choices and correct the Annex IV attribution Annex IV is the technical documentation schedule referred to in Article 11(1) rather than a classification annex, so "Annex IV high-risk" names no category a reader can look up. High-risk classification runs through Article 6 with Annexes I and III. No provision of the Regulation requires a verification depth, so the floor is stated as a choice this specification makes rather than a derivation from any regime. The regulatory detail moves into an informative section recording what each instrument requires and nothing beyond it. Documentation only. No normative delta, no schema change, no conformance test IDs. Signed-off-by: Ioana Valea --- docs/verification.md | 43 +++++++++++++++++++++++++++++++++++++++++-- 1 file changed, 41 insertions(+), 2 deletions(-) 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