When an authenticated agent attempts an action outside its mandate, the refusal should survive as more than an error message in one application. The parties need a record of the attempted event, the authority boundary that stopped it, the evidence and policy then in force, and the resulting state. What follows is a proposed design, not an existing standard.
A payment API that must not pay
Consider a hypothetical asset-financing workflow with six actors: an asset owner, an arranger, an evidence provider, an investor, a payment provider and an AI agent operated by the arranger.
The agent collects documents, checks ownership records, evaluates cash flows, reviews transfer restrictions and recommends terms. It has access to the payment API. The payment provider can authenticate it and execute a well-formed call. The asset package appears complete.
The transaction must still stop. The principal’s mandate allows the agent to prepare a release request, but not to execute one.
At that moment, every participant can have a locally correct record:
- the model gateway records the recommendation;
- the evidence provider records a current registry extract;
- the arranger records an internal approval;
- the identity provider records a valid login and token;
- the payment provider records a well-formed API request;
- the investor records an expectation that closing conditions were met.
None alone answers whether this actor was entitled to cause this transfer for this principal, asset, counterparty, amount and time. Authentication established access, while the institutional chain around the output requires delegated authority before action.
Bind the attempted action to one event bundle
The proposed control object is a portable bundle for the attempted release:
| Field | Minimum content | Question preserved |
|---|---|---|
| Event | Event ID, type, transaction ID, timestamp, prior state | Which attempted state change is under review? |
| Actors | Principal, agent, operator, relying parties | Who acted for whom? |
| Mandate | Identifier, version, action, asset and counterparty scope, value and time limits, revocation status | Was execution inside delegated authority? |
| Evidence | Source, issuer, digest, version or as-of time, disclosure conditions | Which facts were available at the decision point? |
| Policy | Rule-set ID and version, inputs, result, exceptions | Which rule converted evidence into a decision? |
| Outcome | Allowed or refused, resulting state, approvals, signatures | What did the systems actually do? |
| Governance | Retention rule, challenge route, correction link | How can the record survive review and dispute? |
The actor fields bind the software agent to its operator and to the legal entity on whose behalf it acts. The mandate is scoped and revocable: preparing, approving and executing a payment are distinct permissions, further bounded by asset, counterparty, amount and time. A token is useful evidence of system access, but the bundle must refer to the commercial mandate version separately.
Evidence and policy references need stable identifiers, timestamps and versions. A later reviewer should see the material actually used, not whatever the database happens to contain then. The policy result should record exceptions and required approvals as well as a pass or fail. NIST’s Generative AI Profile similarly treats provenance, human-oversight information and records of third-party changes with sources, timestamps and metadata as connected governance concerns.1
Enforce the mandate before execution
The control must sit in the transaction path. A post-hoc explanation cannot reliably reverse a transfer. The payment provider or another unavoidable policy gate should compare the attempted release with the active mandate and evidence requirements before funds move.
In this scenario the result is refused: execution outside mandate. The payment remains unreleased, the prepared request remains available for a properly authorized actor, and the record points to the rule that stopped the call. The system should not describe the refusal as fraud. The agent may have followed a bad plan, received a malformed instruction or simply reached a boundary it was expected to respect.
Refusals must be retained alongside successful actions. A history containing only completed payments cannot show that revocations, value limits or separation of duties were enforced. The rejected attempt is often the strongest evidence that the mandate changed what the system was capable of doing.
Logging requirements depend on legal scope. For AI systems classified as high-risk under the EU AI Act, Article 12 requires technical capabilities for automatic event logging over the system’s lifetime. Its more specific minimum fields apply to the remote-biometric-identification systems identified in Annex III, point 1(a), not to every AI system. Article 26 separately requires deployers of high-risk systems to retain logs under their control for an appropriate period of at least six months unless other law provides differently.2 These duties do not turn this proposed bundle into a general legal requirement.
Recognition and correction are part of the design
Who issues, retains and relies on the bundle cannot be implicit. In this reference design, the arranger and payment provider sign the events they produce. The investor and asset owner retain the portions their agreements require. Each named party receives a defined route to challenge the event or attach a correction. A regulator or auditor may rely on the record only where the governing rules make its issuers, fields, signatures and retention procedure admissible.
Correction should preserve the link to the original event instead of silently rewriting it. Revocation should likewise identify the mandate version, effective time and authority responsible. This lets a reviewer distinguish a control that failed from a control that acted correctly on information later found to be wrong.
Retention cannot mean collecting everything forever. The evidence references must resolve under controlled access, and disclosure can be selective where another party needs to test a condition without receiving the underlying confidential document. The bundle needs retention and deletion rules appropriate to its agreements, data, parties and jurisdictions.
A schema cannot prove that an issuer was honest, a registry was lawful or a policy was sensible. It cannot allocate liability, make a signature admissible or create legal finality across jurisdictions. Those properties come from operating rules and institutional recognition. Nor does every transaction need an independent shared record; existing systems may be enough.
The bundle has done its job when a later reviewer can establish the attempted action, the agent’s principal, the mandate and evidence versions, the rule applied and the resulting state without reconstructing the transaction from email. For this hypothetical release, the correct result is a recorded refusal: the agent could prepare the payment, but the system did not let it execute one.
Footnotes
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NIST AI 600-1, Artificial Intelligence Risk Management Framework: Generative Artificial Intelligence Profile, section 1 and suggested actions GV-1.6-003 and GV-6.1-008. Published July 2024; last reviewed 2 September 2026. ↩
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Regulation (EU) 2024/1689, Article 12(1)–(3), Annex III point 1(a), and Article 26(6). Official consolidated text; last reviewed 2 September 2026. ↩