The controls matrix

Each control below names the obligations it answers and the record it produces. Most records are items in the evidence pack. The rest stay in your repository or your CI, and an auditor can ask for them.

§01

How an audit grades each control

An audit gives every control one of four grades, listed here in the order a report sorts them, worst first.

Fail: The control is missing, or it exists and cannot produce its evidence.
Partial: The control exists, but it is not yet running in production, its evidence has a gap for the period, or an exception is open.
Pass: The control runs in production, and its evidence for the last full period can be exported today.
Not applicable: The obligation does not bind you for this system, and the reason is written down.

§02

The twenty-one controls

Control	What it does
GD-01	Every paid model call is metered through one function, and the ledger is the only record of spend Obligations Art. 12, Art. 26(6), GDPR Art. 5(2), DORA Art. 9, ISO/IEC 42001 A.6, ISO/IEC 42001 A.4, NIST AI RMF MEASURE, PRA SS1/23 Principle 2 Record produced Ledger extract: time, subject, model version, estimated and actual cost, outcome Evidence Evidence pack item 1: Ledger extract
GD-02	An append-only audit log, hash-chained Obligations Art. 12, Art. 26(6), Art. 11 + Annex IV, GDPR Art. 5(2), GDPR Art. 30, DORA Art. 9, DORA Art. 17, ISO/IEC 42001 A.6, NIST AI RMF GOVERN, PRA SS1/23 Principle 5 Record produced Chain verification output for the period Evidence Evidence pack item 2: Audit log integrity proof
GD-03	A human approves before any consequential output leaves the system Obligations Art. 14, Art. 26(2), GDPR Art. 22, ISO/IEC 42001 A.9, ISO/IEC 42001 A.6, NIST AI RMF MANAGE, PRA SS1/23 Principle 5 Record produced Approval log: who, when, what they saw, what they decided Evidence Evidence pack item 3: Approval log
GD-04	No message, document or notice leaves the organisation until a person sends it Obligations Art. 14, Art. 26(2), Art. 26(11), GDPR Art. 22, ISO/IEC 42001 A.9, NIST AI RMF MANAGE Record produced Gate log: each item held, released or rejected Evidence Evidence pack item 3: Approval log
GD-05	A killswitch read on every paid call, tested by breaking it on purpose Obligations Art. 14(4)(e), Art. 26(5), Art. 73, DORA Art. 11, ISO/IEC 42001 A.6, NIST AI RMF MANAGE 2.4, PRA SS1/23 Principle 5 Record produced Drill record: date, operator, what stopped, recovery time, the safe-state behaviour observed Evidence Evidence pack item 4: Killswitch test record
GD-06	Every model response is checked against a versioned schema, and a rejection is logged rather than quietly corrected Obligations Art. 15, Art. 26(4), ISO/IEC 42001 A.6, NIST AI RMF MEASURE, PRA SS1/23 Principle 2 Record produced Schema registry with version history, and reject counts for the period Evidence Evidence pack item 8: Schema registry
GD-07	A ceiling on each unit of work, and rolling 24-hour ceilings for each organisation and for the whole system Obligations Art. 9, DORA Art. 9, DORA Art. 10, ISO/IEC 42001 A.6, NIST AI RMF MANAGE Record produced Ceiling configuration under version control, and every breach Evidence Evidence pack item 5: Ceiling configuration and breaches
GD-08	Personal data is hashed or left out before anything is logged, under a written list of what may be kept Obligations Art. 26(4), GDPR Art. 25, GDPR Art. 32, GDPR Art. 5(1)(c), NIST AI RMF GOVERN, ICO guidance on AI and data protection Record produced The redaction rules in force, and a test showing no raw personal data reaches a log Evidence Evidence pack item 9: Redaction rules and test results
GD-09	A tenant boundary, with egress only to named providers Obligations Art. 15, GDPR Art. 32, GDPR Art. 44 to 49, DORA Art. 9, DORA Art. 28, DORA Art. 29, ISO/IEC 42001 A.10, ISO/IEC 42001 A.4, NIST AI RMF GOVERN, PRA SS1/23 Principle 4 Record produced The provider list, and the code test showing no unmetered egress Evidence Evidence pack item 7: Provider list and egress proof
GD-10	Each part of the system checks its own settings when it starts, and no secret crosses from one part to another Obligations Art. 15, GDPR Art. 32, DORA Art. 9, ISO/IEC 42001 A.4, ISO/IEC 42001 A.6, NIST AI RMF GOVERN Record produced The settings schema for each part, and the smoke test output Evidence Held outside the pack, in the client's repository (the schema) and CI (the smoke test output), and available on request
GD-11	Each component's model is pinned to a version, and every change is dated with its reason Obligations Art. 11 + Annex IV, Art. 13, Art. 72, ISO/IEC 42001 A.6, NIST AI RMF MAP, PRA SS1/23 Principle 1, PRA SS1/23 Principle 2 Record produced Model version manifest: which model answered which component, and when it changed Evidence Evidence pack item 6: Model version manifest
GD-12	Model providers are reachable from one fenced part of the code, and a test proves no call goes around the meter Obligations Art. 15, DORA Art. 28, DORA Art. 29, ISO/IEC 42001 A.10, NIST AI RMF GOVERN Record produced The provider list and the policy test output Evidence Evidence pack item 7: Provider list and egress proof
GD-13	A test suite with fixed thresholds must pass before every merge, and CI runs the same checks Obligations Art. 9, Art. 17, ISO/IEC 42001 A.6, NIST AI RMF MEASURE, PRA SS1/23 Principle 3 Record produced CI history for the period Evidence Held outside the pack, in the client's CI run history, and available on request
GD-14	An append-only decisions log, where a correction keeps the line it replaces Obligations Art. 11 + Annex IV, Art. 18, Art. 72, ISO/IEC 42001 A.6, NIST AI RMF GOVERN, PRA SS1/23 Principle 5 Record produced The decisions log Evidence Held outside the pack, in the client's repository, where the log itself is kept, and available on request
GD-15	Every control in the matrix must point at evidence that exists, or the build fails Obligations Art. 17, GDPR Art. 5(2), ISO/IEC 42001 A.6, NIST AI RMF GOVERN Record produced The matrix, the register of what is not covered, and the build check over both Evidence Evidence pack item 11: The controls matrix Evidence pack item 12: The not-covered register Held outside the pack, in the client's CI run history, and available on request
GD-16	Each outside data source has a written contract, and every record says where it came from Obligations Art. 13, Art. 26(11), Art. 50, Art. 50(2), GDPR Art. 13, GDPR Art. 14, DORA Art. 30, ISO/IEC 42001 A.8, NIST AI RMF GOVERN Record produced The contract for each source, versioned with the code Evidence Held outside the pack, in the client's repository, beside the code it describes, and available on request
GD-17	Incidents are recorded as typed events in the audit log, with a written path to your incident process and to the authorities where required Obligations Art. 26(5), Art. 73, GDPR Art. 33, DORA Art. 17, DORA Art. 19, ISO/IEC 42001 A.8, NIST AI RMF MANAGE, PRA SS1/23 Principle 5 Record produced Incident register for the period, open and closed Evidence Evidence pack item 10: Incident log
GD-18	One script exports the evidence pack Obligations Art. 26(12), Art. 11 + Annex IV, GDPR Art. 5(2), DORA Art. 30, ISO/IEC 42001 A.8, NIST AI RMF GOVERN, PRA SS1/23 Principle 5 Record produced The pack: twelve items in a dated folder, generated rather than written Evidence Every item in the evidence pack
GD-19	Webhooks and ingest jobs can be replayed safely, and a replay test runs in CI Obligations Art. 15, DORA Art. 9, ISO/IEC 42001 A.6, NIST AI RMF MEASURE Record produced Replay test output Evidence Held outside the pack, in the client's CI run history, and available on request
GD-20	Any pipeline can run end to end without a paid call, booking each step at zero cost Obligations Art. 9, ISO/IEC 42001 A.6, NIST AI RMF MEASURE, PRA SS1/23 Principle 3 Record produced Ledger rows for each dry run, at zero actual cost Evidence Evidence pack item 1: Ledger extract
GD-21	An agent's tool, API and MCP calls get the same controls: metered, logged, gated where it matters, and stoppable Obligations Art. 3, Art. 12, Art. 15, Art. 25, ISO/IEC 42001 A.6, NIST AI RMF MANAGE, NIST AI RMF MANAGE 2.4, NIST AI RMF MEASURE Record produced Action log rows per tool call, with the same fields as the ledger, and the gate decision where a call is consequential Evidence Evidence pack item 1: Ledger extract Evidence pack item 3: Approval log

§03

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