PRACTICAL TRUST / FINANCIAL SERVICES PREVIEW

Financial-services regulatory library

I connect AI, cyber and privacy obligations to the financial activity, accountable decision and evidence that matter. This public edition covers Financial services & insurance, including relevant international and cross-sector research.

How to navigate / scope and jurisdiction cautions

Choose a financial activity, then refine by issuing region, jurisdiction and instrument. The remaining filter choices are drawn only from the selected financial research set. No result means no mapped public match, not an exemption.

NAICS is an activity-navigation aid, not a legal-applicability test. A banking charter, MSB registration and insurance license differ. Headquarters alone does not determine applicable law; assess entity, activities, customers, data, product, territorial nexus and local implementation. Shared frameworks remain available when relevant. HIPAA appears where the inherited insurance/PBM activity mapping calls for it.

Public records retain their own review dates and limitations. This access revision is not a new legal-source audit. Read the official source before relying on a summary. The preview can be read and copied; it is not a subscriber database.

More below: choose filters, then scroll to the matching references.

86 public financial-services records. JavaScript adds filtering; the readable public subset follows.

United States - federal / Law

FTC Act, Section 5

Businesses within Federal Trade Commission jurisdiction. Sectoral exemptions and the distinction between commercial conduct and regulated banking or nonprofit activity matter.

Duties, evidence, limitations & official sources

Status / timing

In force; case-specific enforcement

Duties / expectations

Prohibits unfair or deceptive acts or practices. AI performance, privacy, security and bias representations must match actual practices; using AI does not displace consumer-protection duties.

Evidence to consider

Maintain substantiation for public claims, tested security/privacy controls, complaint handling and documented corrective action. Evaluate actual consumer injury rather than relying on an AI label.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

15 USC 45

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - California / Law

California Consumer Privacy Act / CPRA

For-profit businesses meeting statutory California thresholds; service-provider and contractor duties differ. Exemptions are often data-specific, not blanket exemptions for an entire enterprise.

Duties, evidence, limitations & official sources

Status / timing

CCPA/CPRA in force; 2025 final regulations effective January 1, 2026 with later compliance/submission dates

Duties / expectations

Includes notice, access, correction, deletion, sale/sharing opt-out and sensitive-information protections, subject to statutory scope and exceptions. Covered risk-assessment duties begin January 1, 2026, with assessment attestations and summaries due April 1, 2028. Covered ADMT requirements begin January 1, 2027. Initial cybersecurity-audit certifications are phased to April 1 of 2028, 2029 or 2030 according to the applicable revenue tier.

Evidence to consider

Data/use inventory; verified request workflow; opt-out signals; purpose/retention limits; vendor contracts; risk-assessment and audit applicability records.

Scope qualification

First determine whether each activity and audit/ADMT threshold is in scope. Revenue tiers determine the schedule only after audit applicability is established; exemptions are often data-specific rather than entity-wide.

Source locator

California Civil Code 1798.100 et seq.

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - New York / Law

New York SHIELD Act and breach notification

Persons and businesses holding covered private information of New York residents; reasonable-security duties and notification triggers should be assessed separately.

Duties, evidence, limitations & official sources

Status / timing

In force

Duties / expectations

Requires reasonable administrative, technical and physical safeguards and notifications for qualifying breaches. Outsourcing data handling does not eliminate safeguarding responsibilities.

Evidence to consider

Data classification, risk assessment, supplier diligence, safeguards testing, disposal schedules and incident notification decision records.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

GBL 899-aa and 899-bb

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - Virginia / Law

Virginia Consumer Data Protection Act

Controllers meeting Virginia resident-data or revenue thresholds, subject to statutory entity and data exemptions.

Duties, evidence, limitations & official sources

Status / timing

In force

Duties / expectations

Requires notices, consumer rights, processor contracts and assessments for specified high-risk processing, including certain profiling. Sensitive-data consent and appeals requirements require operational workflows.

Evidence to consider

Processing inventory, rights/appeal case records, purpose limits, processor agreements and documented assessments.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Title 59.1, Chapter 53

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - Colorado / Law

Colorado Privacy Act

Controllers meeting statutory coverage tests with Colorado nexus; not every small business or employment record falls in scope.

Duties, evidence, limitations & official sources

Status / timing

In force; distinct from Colorado AI legislation

Duties / expectations

Regulates consumer rights, sensitive data, targeted advertising and high-risk processing. Covered controllers must honor applicable universal opt-out mechanisms and complete required data-protection assessments.

Evidence to consider

Data inventory, consent/opt-out evidence, profiling reviews, consumer appeals and vendor processing terms.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Colorado Revised Statutes 6-1-1301 et seq.

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - Connecticut / Law

Connecticut Data Privacy Act

Covered controllers processing Connecticut resident data; thresholds, exemptions and child/teen protections must be evaluated under the current text.

Duties, evidence, limitations & official sources

Status / timing

In force; consult amended coverage and youth provisions

Duties / expectations

Creates consumer rights, consent and security duties, processor obligations and assessments for designated risky processing. Opt-out mechanisms and sensitive-data handling are important to AI personalization.

Evidence to consider

Rights and consent records, assessments, data-purpose controls, deletion propagation and supplier evidence.

Scope qualification

July 1, 2026 amendments broaden coverage to specified controllers processing at least 35,000 consumers, selling personal data or processing sensitive data, subject to exclusions. Review the amended youth, neural-data and other sensitive-data provisions rather than an older threshold summary.

Source locator

Connecticut General Statutes 42-515 et seq.

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - Texas / Law

Texas Data Privacy and Security Act

Persons conducting business in Texas or producing products/services consumed by residents, subject to small-business and other statutory exclusions and exceptions.

Duties, evidence, limitations & official sources

Status / timing

In force; separate from Texas AI law

Duties / expectations

Requires consumer rights, notices, reasonable security, processor contracts and assessments for specified processing; sensitive-data sale restrictions can reach otherwise exempt small businesses.

Evidence to consider

Coverage memo, privacy notices, rights/appeal workflows, opt-out handling and high-risk processing assessments.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Business & Commerce Code Chapter 541

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - Illinois / Law

Illinois Biometric Information Privacy Act

Private entities collecting or holding covered biometric identifiers/information, with statutory exclusions. Face recognition and voiceprint applications need classification beyond ordinary photos/audio.

Duties, evidence, limitations & official sources

Status / timing

In force; amended liability provisions require current-text review

Duties / expectations

Requires informed written release for covered collection, a public retention/destruction policy, restrictions on disclosure/profit and protective handling. Private litigation exposure is distinct from general privacy laws.

Evidence to consider

Biometric purpose/retention policy, releases, vendor disclosures, destruction logs and security evidence.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

740 ILCS 14

Review limitation

October 13, 2026 source check: the primary page was blocked, unavailable or not machine-readable. The earlier synopsis is retained for orientation, not represented as a newly verified current legal or technical requirement. Validate the current primary text before reliance.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - federal / Law

Title VII and employment discrimination

Covered employers, employment agencies and labor organizations. AI recruitment, assessment, promotion and termination tools remain employment-selection practices.

Duties, evidence, limitations & official sources

Status / timing

In force

Duties / expectations

Prohibits specified discrimination. Assess disparate treatment and legally cognizable disparate impact under governing law; no vendor assurance substitutes for employer responsibility.

Evidence to consider

Job-related validation, selection-rate analysis, accommodation/escalation channels, vendor testing rights and decision records.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

42 USC 2000e et seq.

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - federal / Law

Americans with Disabilities Act

Covered employers, public entities and public accommodations under the relevant ADA title. Disability-sensitive algorithmic screening and digital accessibility need separate assessments.

Duties, evidence, limitations & official sources

Status / timing

In force

Duties / expectations

Prohibits disability discrimination and establishes applicable accommodation/access obligations. Test whether automated assessments screen out qualified people or inaccessible interfaces prevent participation.

Evidence to consider

Accessibility and accommodation procedures, validated selection criteria, alternative assessments and complaint resolution.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

ADA Titles I, II and III as applicable

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - New York City / Law / regulation

New York City Local Law 144 - automated employment decisions

Employers and employment agencies using an AEDT within the law and rules' definition and geographic scope; not every workplace AI tool qualifies.

Duties, evidence, limitations & official sources

Status / timing

Enforced since July 5, 2023

Duties / expectations

Requires an independent bias audit within one year, public availability of required audit information and candidate/employee notices before covered use.

Evidence to consider

AEDT scope analysis, audit independence and methodology, published summary, notice evidence and periodic review.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Local Law 144 of 2021

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - Texas / Law

Texas Responsible Artificial Intelligence Governance Act

Entities and AI systems within Texas jurisdiction as defined; government, healthcare and other provisions have differing scopes. Do not confuse this with TDPSA.

Duties, evidence, limitations & official sources

Status / timing

Effective January 1, 2026

Duties / expectations

Prohibits specified harmful/manipulative and unlawful discriminatory uses; includes targeted disclosure and enforcement provisions. This is not a universal mandate that every AI user obtain certification.

Evidence to consider

Use-case screening, prohibited-use controls, disclosure review, documented intent/purpose and provider/deployer responsibility allocation.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

HB 149, 89th Legislature

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - Colorado / Law

Colorado automated decisionmaking law - SB26-189

Developers and deployers of covered automated decisionmaking technology used for consequential decisions, subject to defined exclusions and exceptions.

Duties, evidence, limitations & official sources

Status / timing

Enacted; operative January 1, 2027; replaces SB24-205 framework

Duties / expectations

Requires relevant technical documentation, notices and consumer review/reconsideration procedures; distinguishes developer and deployer duties. Preserve required decision records and evaluate the amended scope rather than relying on old SB24-205 summaries.

Evidence to consider

Coverage register, technical documentation, human-review process, notices, material-update tracking and record retention.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

SB26-189

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - California / Law

California Transparency in Frontier Artificial Intelligence Act

Frontier developers and large frontier developers meeting statutory model/developer thresholds. Not a general certification requirement for enterprise AI users.

Duties, evidence, limitations & official sources

Status / timing

In force; frontier-developer and large-frontier-developer classifications control

Duties / expectations

Requires covered safety frameworks, transparency disclosures, critical-safety-incident reporting and whistleblower protections. Disclosure duties differ by developer category.

Evidence to consider

Frontier-model threshold assessment, approved framework, evaluation records, release disclosures, incident reporting procedure and protected employee reporting.

Scope qualification

The Attorney General describes framework, incident and employee-reporting provisions. Separate the developer categories; this is not a general certification obligation for every enterprise using an AI tool.

Source locator

Business & Professions Code 22757.10 et seq.; Labor Code 1107 and 1107.1

Review limitation

Source-level review is limited to the available official material; organization-specific applicability and implementing details still require assessment.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - California / Law

California AI Transparency Act - SB942, AB853 and 2026 amendments

Generative-AI providers and staged platform/hosting/device requirements. The Governor confirms signing SB1000 and AB2713 on September 30, 2026, further amending the transparency regime. Do not rely on the older provider definition or user threshold without checking the amended text.

Duties, evidence, limitations & official sources

Status / timing

Operative statute; September 30, 2026 amendments require consolidated-text review before reliance

Duties / expectations

The regime addresses synthetic-content provenance, disclosures and verification/detection capabilities, with actor-specific requirements. AB853 introduced a chapter-wide August 2, 2026 operative date and staged platform/device requirements. The September 2026 legislation further changes the regime. The chaptered/consolidated text was not retrievable in this review, so exact amended thresholds, exceptions and commencement details remain an explicit validation item.

Evidence to consider

Provider/platform classification, provenance tests, disclosure persistence, detection access and staged implementation records.

Scope qualification

Publication boundary: enactment and the subject of the amendments are supported by the official signing announcement. This entry does not certify the post-September 30 requirements or assume that all original SB942 duties remain unchanged.

Source locator

Business & Professions Code Chapter 25; SB942 / AB853; SB1000 and AB2713 (2026)

Review limitation

Source-level review is limited to the available official material; organization-specific applicability and implementing details still require assessment.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - New York / Law

New York Responsible AI Safety and Education (RAISE) Act

Frontier and large frontier developers within Article 44-B definitions and scope; applicability is not equivalent to deploying any enterprise LLM.

Duties, evidence, limitations & official sources

Status / timing

Enacted; operative January 1, 2027

Duties / expectations

Creates transparency, safety-incident reporting, disclosure and related accountability obligations. Use the amended consolidated law rather than an earlier bill version.

Evidence to consider

Compute/revenue threshold analysis, safety framework, disclosure approvals, critical-incident escalation and preservation of evaluation evidence.

Scope qualification

Article 44-B applies to defined large developers and covered frontier models, not every New York AI user. Confirm statutory thresholds, exemptions and implementing directions before treating an enterprise deployment as covered.

Source locator

GBL 1420-1429

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - New York / Regulation

NYDFS Cybersecurity Regulation

Entities operating under covered NY financial-services laws; limited exemptions and Class A requirements require a documented scope determination.

Duties, evidence, limitations & official sources

Status / timing

In force; amended requirements and exemptions apply

Duties / expectations

Requires a risk-based cybersecurity program, policies, CISO/governing-body oversight, controls, incident reporting and annual compliance submission. AI data flows and suppliers belong in the risk assessment.

Evidence to consider

Board reporting, asset inventory, risk assessment, control tests, MFA/PAM evidence, incident decisions, recovery tests and third-party reviews.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

23 NYCRR Part 500

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - federal / Law / regulation

GLBA and FTC Safeguards Rule

Financial institutions subject to the FTC's GLBA jurisdiction, including covered nonbank financial activities. Banking-agency rules govern other covered institutions.

Duties, evidence, limitations & official sources

Status / timing

In force

Duties / expectations

Requires a written security program led by a qualified individual, risk assessment, safeguards, service-provider oversight and reporting. Specific notification duties have their own trigger.

Evidence to consider

Written program, governing-body reports, inventory, encryption/MFA rationale, testing, supplier monitoring and incident-notification record.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

16 CFR 314

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - federal / Regulation

SEC Regulation S-P

Covered broker-dealers, funding portals, investment companies, SEC-registered investment advisers and covered transfer agents. Size classifications differ by registrant type; the adviser AUM threshold is not a universal threshold for all entities.

Duties, evidence, limitations & official sources

Status / timing

2024 amendments: larger entities December 3, 2025; smaller entities June 3, 2026; both dates elapsed

Duties / expectations

Requires written incident-response policies, safeguards/disposal, service-provider oversight and compliance records. Covered notification is due as soon as practicable, generally no later than 30 days after awareness of the triggering unauthorized access/use, subject to the rule's investigation-based exception and authorized delay provisions. Do not equate every security alert with the notification trigger.

Evidence to consider

Incident-response program, affected-information analysis, notice decisions, service-provider records, retention and supervisory review.

Scope qualification

Verify the affected information and covered individuals before deciding notice. A contract alone does not demonstrate service-provider oversight.

Source locator

17 CFR Part 248

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - federal / Regulation

SEC cybersecurity disclosure rules

Public-company registrants subject to the relevant Exchange Act reporting forms; domestic and foreign private issuer mechanisms differ.

Duties, evidence, limitations & official sources

Status / timing

In force for covered registrants

Duties / expectations

Requires specified material incident disclosures and periodic descriptions of cyber risk management, strategy and governance. The materiality determination and disclosure timetable are distinct from technical incident severity.

Evidence to consider

Documented materiality/escalation process, disclosure controls, board/management role evidence and consistency between filings and actual practice.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Regulation S-K Item 106; Form 8-K Item 1.05

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - federal / Supervisory guidance

Interagency model risk management guidance - SR26-2

Interagency guidance most relevant to supervised banking organizations with more than $30 billion in total assets; smaller organizations with significant model exposure should consider applicability. The guidance covers complex quantitative models, including non-generative, non-agentic AI models. Footnote 3 expressly excludes generative and agentic AI from its scope.

Duties, evidence, limitations & official sources

Status / timing

Issued April 17, 2026; supersedes SR11-7 and SR21-8

Duties / expectations

Recommends risk-based model development, use, validation and governance. It does not create enforceable legal requirements and must not be represented as a generative-AI or agentic-AI compliance framework. Separate governance, consumer-protection, privacy, safety-and-soundness and contractual duties may still apply to those uses.

Evidence to consider

Model inventory, materiality and limitations, independent challenge, validation, change control and risk acceptance.

Scope qualification

Keep the covered-model inventory distinct from the broader AI-system inventory. Exclusion from this guidance is not exemption from other law or sound risk management.

Source locator

SR26-2, April 17, 2026; applicability statement and revised guidance footnotes 1 and 3

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - federal / Supervisory guidance

Interagency third-party relationship risk management

Banking organizations supervised by the Federal Reserve, FDIC or OCC; lifecycle practices scaled to the risk of each relationship.

Duties, evidence, limitations & official sources

Status / timing

Final interagency guidance, 2023

Duties / expectations

Addresses planning, diligence, contracting, monitoring and termination. AI-model APIs, cloud platforms and data/agent suppliers should be evaluated as relationships, not just purchased software.

Evidence to consider

Risk tiering, diligence exceptions, enforceable audit/incident/exit terms, monitoring evidence and termination plans.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

SR23-4

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - federal / Law / regulation

Equal Credit Opportunity Act / Regulation B

Covered creditors making credit decisions, including AI-enabled underwriting. Technology choice does not eliminate statutory notification duties.

Duties, evidence, limitations & official sources

Status / timing

In force; current regulation controls

Duties / expectations

Prohibits specified discrimination and requires accurate principal reasons for adverse actions. Use the current regulation; agency circulars are interpretation, not the statute itself.

Evidence to consider

Credit decision provenance, reason-code validation, fair-lending testing and adverse-action notices.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

12 CFR 1002, especially 1002.9

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - federal / Law

Fair Credit Reporting Act

Consumer reporting agencies, furnishers and users of consumer reports as defined; AI scoring vendors can create reporting-law obligations depending on their actual functions.

Duties, evidence, limitations & official sources

Status / timing

In force

Duties / expectations

Regulates permissible purpose, accuracy, disputes and relevant notices. Employment screening and eligibility scoring need classification before deployment.

Evidence to consider

Purpose controls, accuracy/dispute workflows, source lineage, notice records and vendor-role analysis.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

15 USC 1681 et seq.

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - federal / Law / regulation

Bank Secrecy Act / AML program requirements

Covered financial institutions, including covered MSBs. AML program, customer due-diligence and reporting obligations differ by institution type.

Duties, evidence, limitations & official sources

Status / timing

In force; institution-specific rules apply

Duties / expectations

AI-assisted monitoring does not transfer accountability for required programs, suspicious activity reporting or recordkeeping. Protect confidentiality and validate alert/decision workflows.

Evidence to consider

AML governance, risk assessment, model/threshold validation, investigator records, independent testing and SAR handling controls.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

31 USC 5311 et seq.; 31 CFR Chapter X

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - federal / Law / regulation

US economic sanctions / OFAC compliance

US persons and transactions subject to applicable sanctions jurisdiction; extraterritorial and secondary-sanctions issues are fact-specific.

Duties, evidence, limitations & official sources

Status / timing

In force; program-specific rules change frequently

Duties / expectations

AI-enabled onboarding, payment, supplier or export workflows must respect applicable prohibitions. A screening score is not a legal determination or a substitute for escalation.

Evidence to consider

Current list/program screening, false-positive review, licensing analysis, escalation and auditable transaction decisions.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Applicable sanctions program regulations

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - state insurance / Model / adoption-dependent

NAIC model bulletin on insurer use of AI

Insurers in states adopting the bulletin or related guidance. NAIC publication alone is not a nationwide enforceable statute.

Duties, evidence, limitations & official sources

Status / timing

Model bulletin; state adoption and variations control

Duties / expectations

Calls for a written AI-systems program, governance, risk controls, testing and documentation supporting compliance with insurance law. Third-party systems remain relevant to insurer accountability.

Evidence to consider

AI inventory, consumer-impact review, written program, validation, vendor evidence and state-by-state applicability matrix.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

AI Model Bulletin; individual state adoption

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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International / payment ecosystem / Standard / contractual

PCI DSS v4.0.1

Entities storing, processing or transmitting payment-card account data, and entities able to affect its security, as scoped by payment-brand/acquirer obligations.

Duties, evidence, limitations & official sources

Status / timing

Contractual standard; not a general statute

Duties / expectations

Requires scoped controls for account-data security, access, testing, monitoring and secure development. AI integrations can alter scope or create unauthorized storage.

Evidence to consider

Card-data flow maps, segmentation tests, access reviews, vulnerability management and assessment evidence.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

PCI DSS v4.0.1; future-dated requirements applied March 31, 2025

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - federal / Law / regulation

HIPAA Privacy and Breach Notification Rules

Covered entities and business associates handling protected health information. Not every wellness app or AI-generated health inference is HIPAA-covered.

Duties, evidence, limitations & official sources

Status / timing

In force; scope and exceptions are specific

Duties / expectations

Limits uses/disclosures and establishes individual rights and breach-notification duties. AI vendors require appropriate roles, contracts and permitted purposes.

Evidence to consider

BAAs, minimum-necessary analysis, access/amendment workflows, risk-of-compromise assessment and notice decisions.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

45 CFR Parts 160 and 164

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - federal / Regulation

HIPAA Security Rule

Covered entities and business associates safeguarding electronic PHI. Security-rule obligations are separate from general medical-device and consumer-app regulation.

Duties, evidence, limitations & official sources

Status / timing

Existing rule in force; do not treat the 2025 NPRM as final law

Duties / expectations

Requires administrative, physical and technical safeguards, risk analysis and risk management. Assess AI data stores, remote processing, model access and incident response.

Evidence to consider

ePHI inventory, risk analysis, access controls, audit records, contingency tests and vendor safeguards.

Scope qualification

The existing Security Rule remains the operative baseline in the reviewed HHS material. The January 2025 strengthening proposal is not labeled final here; verify any subsequent final rule and compliance date before presenting proposed controls as current law.

Source locator

45 CFR 164 Subpart C

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - federal / Law / rulemaking

Cyber Incident Reporting for Critical Infrastructure Act

Entities and incidents ultimately covered by CISA's implementing regulations. Consult the live rulemaking record before assigning a compliance start date.

Duties, evidence, limitations & official sources

Status / timing

Implementing final rule under OIRA review; no operative final-rule reporting commencement verified

Duties / expectations

CIRCIA authorizes covered-entity cyber-incident and ransom-payment reporting. OIRA record RIN 1670-AA04 shows a final-rule submission received October 1, 2026 under pending review. A submission for review is not a published effective final rule. Do not present the statutory 72-hour/24-hour framework as a currently operative reporting duty for every critical-infrastructure organization.

Evidence to consider

Coverage watchlist, notification decision tree, preservation capabilities and reconciliation with other reporting regimes.

Scope qualification

Existing sector-specific, state, contractual and federal reporting duties continue independently. Check the Federal Register final text and effective/compliance dates before activating a CIRCIA reporting clock.

Source locator

CIRCIA; RIN 1670-AA04; OIRA review record 1550967

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - Delaware / Case law

Delaware fiduciary oversight jurisprudence

Directors/officers and entities governed by relevant Delaware law. Applicable duties, exculpation and pleading standards require case-specific advice.

Duties, evidence, limitations & official sources

Status / timing

Fact-specific; not automatic liability after an incident

Duties / expectations

Good-faith oversight includes appropriate reporting systems and responses to significant warnings in context. An adverse AI outcome alone does not establish a fiduciary breach.

Evidence to consider

Board information flows, mission-critical risk escalation, documented challenge, resourcing and follow-through on identified deficiencies.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Caremark / Stone / Marchand line of authority

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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European Union / EEA relevance / Regulation

European Union Artificial Intelligence Act

Providers, deployers, importers, distributors and other covered actors; certain non-EU actors are included. System role, prohibited use, high-risk classification and GPAI status determine duties.

Duties, evidence, limitations & official sources

Status / timing

In force; current amended application dates and legacy-system transitions differ by provision

Duties / expectations

AI literacy and most prohibitions have applied since February 2, 2025; GPAI and specified governance provisions since August 2, 2025. Many transparency duties apply from August 2, 2026. Under the current consolidated Article 113 display, Annex III high-risk duties apply December 2, 2027 and Annex I product-related high-risk duties August 2, 2028. Article 111 gives pre-August 2, 2026 systems a December 2, 2026 transition for Article 50(2) marking/detection; new Article 5 prohibitions also have that later date.

Evidence to consider

Role/use-case classification, AI inventory, risk and data governance, oversight, logs, supplier documentation, testing and change/incident records.

Scope qualification

These are not one universal compliance date. Classify actor, use case, product regime, market-placement date, legacy status and subsequent changes. The Commission Service Desk displays the July 27, 2026 consolidated version; its summaries are explanatory, not a substitute for the legal text.

Source locator

Regulation (EU) 2024/1689 as amended

Review limitation

Source-level review is limited to the available official material; organization-specific applicability and implementing details still require assessment.

Source check: 2026-10-13 / Text revision: 2026-10-13

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European Union / EEA / Regulation

General Data Protection Regulation

Controllers/processors within Article 3 territorial scope; non-EU establishments can be covered by offering goods/services or monitoring people in the Union.

Duties, evidence, limitations & official sources

Status / timing

Applicable since May 25, 2018

Duties / expectations

Requires lawful, fair and transparent processing, minimization, security, rights and accountability. Assess DPIAs, Article 22 safeguards, special-category data and international transfers for relevant AI use.

Evidence to consider

ROPA, lawful-basis analysis, DPIA, processor terms, transfer assessments, rights handling, security testing and breach decisions.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Articles 5-6, 9, 12-22, 25, 28, 30, 32-35, 44-49

Review limitation

Source-level review is limited to the available official material; organization-specific applicability and implementing details still require assessment.

Source check: 2026-10-13 / Text revision: 2026-09-17

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European Union / Directive / national law

ePrivacy Directive and national implementing laws

Electronic communications and related storage/access or direct-marketing activities under applicable member-state legislation.

Duties, evidence, limitations & official sources

Status / timing

National implementation controls

Duties / expectations

Addresses communications confidentiality, terminal-equipment storage/access and marketing rules. Consent exceptions and national implementations must be assessed rather than treating all analytics as automatically exempt.

Evidence to consider

Cookie/SDK inventory, consent and exemptions analysis, preference controls, marketing lists and vendor configurations.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Directive 2002/58/EC as amended

Review limitation

October 13, 2026 source check: the primary page was blocked, unavailable or not machine-readable. The earlier synopsis is retained for orientation, not represented as a newly verified current legal or technical requirement. Validate the current primary text before reliance.

Source check: 2026-10-13 / Text revision: 2026-09-17

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European Union / Regulation

Digital Operational Resilience Act

Covered financial entities and designated critical ICT third-party providers, subject to the Act's proportionality/exemptions and implementing measures.

Duties, evidence, limitations & official sources

Status / timing

Applicable since January 17, 2025

Duties / expectations

Requires ICT risk governance, incident reporting, resilience testing and third-party controls. AI providers and cloud dependencies must be considered in the ICT service and concentration-risk model.

Evidence to consider

ICT register, management-body decisions, critical-function mapping, contract clauses, testing and incident classification/reporting records.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Regulation (EU) 2022/2554; Articles 5-16, 17-23, 24-30

Review limitation

October 13, 2026 source check: the primary page was blocked, unavailable or not machine-readable. The earlier synopsis is retained for orientation, not represented as a newly verified current legal or technical requirement. Validate the current primary text before reliance.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United Kingdom / Law

UK GDPR / Data Protection Act 2018 / DUAA 2025

Controllers/processors within UK territorial scope. The UK regime is not identical to the EU GDPR after domestic amendments.

Duties, evidence, limitations & official sources

Status / timing

UK GDPR and DPA in force; all DUAA data-protection provisions in force by June 19, 2026

Duties / expectations

The DUAA amends rather than replaces UK GDPR, DPA 2018 and PECR. Significant automated decisions still require safeguards, with additional protection for special-category data. Organizations must facilitate data-protection complaints, acknowledge them within 30 days and respond without undue delay. UK lawful-basis, rights and transfer analysis must be distinct from EU GDPR analysis.

Evidence to consider

UK-specific lawful-basis/DPIA review, meaningful contest/review, notices, complaints and transfer documentation.

Scope qualification

Current status and changes checked against the ICO's June 19, 2026 update. The underlying UK legislation page was not assessed clause by clause; the ICO summary does not establish applicability to every overseas operator.

Source locator

UK GDPR as amended; DPA 2018; DUAA 2025

Review limitation

Source-level review is limited to the available official material; organization-specific applicability and implementing details still require assessment.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United Kingdom / Regulation

Privacy and Electronic Communications Regulations

Electronic marketing and covered communications/terminal-equipment activities. Apply current exemptions and DUAA-related changes.

Duties, evidence, limitations & official sources

Status / timing

In force as amended

Duties / expectations

Governs marketing communications and storage/access technologies alongside UK data-protection law. A banner alone is not evidence that tracking respects consent.

Evidence to consider

Cookie/SDK audit, lawful-exemption register, consent records and suppression lists.

Scope qualification

DUAA amends PECR. Any storage/access exception is purpose- and safeguard-specific; it does not permit unrestricted tracking, profiling or advertising cookies without the otherwise required consent. Consult the current ICO storage/access guidance.

Source locator

SI 2003/2426 as amended

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United Kingdom / Regulation / supervisory rules

FCA operational resilience rules

FCA firms within SYSC 15A scope and corresponding prudential requirements where applicable.

Duties, evidence, limitations & official sources

Status / timing

In force; March 31, 2025 transition completed for covered firms

Duties / expectations

Requires identification of important business services, impact tolerances, mapping, scenario testing and remediation. AI and cloud concentration must be assessed at service level.

Evidence to consider

Important-service map, tolerance approvals, severe-but-plausible tests, third-party dependencies and self-assessment.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

FCA SYSC 15A; related PRA rules

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United Kingdom / Regulation / supervisory rules

FCA Consumer Duty

Firms and products/services within the FCA's retail-market scope, including relevant distribution-chain roles.

Duties, evidence, limitations & official sources

Status / timing

In force for covered retail business

Duties / expectations

Requires focus on good retail-customer outcomes, including understanding and support. AI-driven pricing, personalization or support should be tested against customer harm, not only efficiency.

Evidence to consider

Outcome monitoring, vulnerability analysis, product reviews, customer comprehension/support testing and governing-body oversight.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Principle 12; PRIN 2A

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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Canada - federal private sector / Law

PIPEDA

Commercial personal-information processing within federal scope and cross-border activity; exemptions and provincial allocation require review.

Duties, evidence, limitations & official sources

Status / timing

In force; substantially similar provincial regimes may apply

Duties / expectations

Requires accountable, appropriate collection/use/disclosure, consent, safeguards, access/correction and qualifying breach reporting/records.

Evidence to consider

Purpose/consent records, privacy officer accountability, security, vendor controls and significant-harm assessment.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

S.C. 2000, c.5

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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Canada - Quebec / Law

Quebec private-sector privacy law (Law 25 reforms)

Enterprises holding personal information within Quebec private-sector law; separate public-sector statute applies to public bodies.

Duties, evidence, limitations & official sources

Status / timing

Reforms phased through 2024; current consolidated law controls

Duties / expectations

Requires privacy governance, impact assessments for specified systems/transfers, transparency for exclusively automated decisions and individual rights.

Evidence to consider

Privacy roles, PIA/transfer assessments, notices, decision-review mechanisms and retention/destruction evidence.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Act respecting the protection of personal information in the private sector

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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Canada - federally regulated finance / Supervisory guidance

OSFI B-13 - technology and cyber risk

Federally regulated financial institutions and relevant foreign branches, applied proportionately to their Canadian operations.

Duties, evidence, limitations & official sources

Status / timing

Current supervisory guideline

Duties / expectations

Expects governance, technology operations/resilience and cyber-security management. Senior management must assign clear responsibilities and maintain risk-based controls.

Evidence to consider

Technology inventory, board reporting, secure development/change records, incident response, recovery and supplier controls.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Guideline B-13

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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Australia / Law

Australian Privacy Act and Australian Privacy Principles

APP entities including covered agencies/businesses; turnover and sector exceptions matter. Not every small business is exempt.

Duties, evidence, limitations & official sources

Status / timing

In force; new ADM privacy-policy duties commence December 10, 2026

Duties / expectations

Requires open/transparent management, purpose limits, quality, security and access/correction. New APP 1 automated-decision disclosures address significant decisions involving personal information.

Evidence to consider

APP scope, data maps, privacy policy, collection notices, ADM inventory, access/correction and breach response.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Privacy Act 1988; APPs; Notifiable Data Breaches scheme

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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Australia / Prudential standard

APRA CPS 234 - Information Security

APRA-regulated entities, with responsibilities for information assets managed by related parties and third parties.

Duties, evidence, limitations & official sources

Status / timing

Mandatory for covered APRA entities

Duties / expectations

Requires security capability, implementation/testing of controls and notification of qualifying incidents/control weaknesses. Governing-body accountability is explicit.

Evidence to consider

Information classification, control testing, board oversight, third-party assurance and notification decisions.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Prudential Standard CPS 234

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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Australia / Prudential standard

APRA CPS 230 - Operational Risk Management

Covered APRA-regulated entities; current standard and service-provider transition arrangements apply.

Duties, evidence, limitations & official sources

Status / timing

Current version in force July 1, 2026

Duties / expectations

Requires operational-risk controls, critical-operation tolerances, continuity and material-service-provider management. Boards approve key plans and oversee remediation.

Evidence to consider

Critical operations map, tolerance decisions, scenario tests, service-provider agreements and board reporting.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Prudential Standard CPS 230

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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Singapore / Law

Singapore Personal Data Protection Act

Organizations processing personal data within PDPA scope; public agencies have a different governance regime.

Duties, evidence, limitations & official sources

Status / timing

In force

Duties / expectations

Requires accountability, notice/consent or applicable exceptions, purpose limitation, security, retention limits, access/correction, transfer controls and qualifying breach notification.

Evidence to consider

DPO accountability, purpose/exception analysis, vendor terms, security/retention records and rights handling.

Scope qualification

Source-review boundary (September 17, 2026): Direct full text was not retrievable; the entry is orientation only. No assumption that a planned rule is operative.

Source locator

Personal Data Protection Act 2012

Review limitation

October 13, 2026 source check: the primary page was blocked, unavailable or not machine-readable. The earlier synopsis is retained for orientation, not represented as a newly verified current legal or technical requirement. Validate the current primary text before reliance.

Source check: 2026-10-13 / Text revision: 2026-09-17

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Singapore / Regulatory guidance

Singapore PDPC guidance on AI use of personal data

Organizations developing/deploying AI systems using personal data, including recommendations, decisions and generative uses where PDPA applies.

Duties, evidence, limitations & official sources

Status / timing

Guidance interprets existing PDPA duties; not a separate AI statute

Duties / expectations

Explains personal-data use across development and deployment, including purposes, consent/exceptions and information to individuals. Model architecture does not remove data-protection duties.

Evidence to consider

Data-purpose and lawful-use register, notices, safeguards, testing and vendor accountability.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

2024 AI advisory guidelines; check later PDPC supplements

Review limitation

October 13, 2026 source check: the primary page was blocked, unavailable or not machine-readable. The earlier synopsis is retained for orientation, not represented as a newly verified current legal or technical requirement. Validate the current primary text before reliance.

Source check: 2026-10-13 / Text revision: 2026-09-17

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Singapore / Supervisory guidance

MAS Technology Risk Management Guidelines

Financial institutions within MAS supervision, with institution-specific cyber hygiene and technology notices where applicable.

Duties, evidence, limitations & official sources

Status / timing

January 2021 Technology Risk Management Guidelines; current official publication page accessible

Duties / expectations

Sets governance, secure development, operations, resilience and cyber-risk expectations. AI outsourcing and model services should fit the technology-risk framework.

Evidence to consider

Technology governance, secure design/testing, critical-service mapping, outsourcing diligence and incident/recovery evidence.

Scope qualification

The official guidance page was accessible on October 13, 2026, resolving the earlier retrieval limitation. Separate the guidelines from binding notices applicable to a particular licensee and from incident-notification instructions.

Source locator

TRM Guidelines and relevant MAS notices

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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Japan / Law

Japan Act on the Protection of Personal Information

Business operators and other entities within APPI scope; overseas handling and cross-border transfers have specific requirements.

Duties, evidence, limitations & official sources

Status / timing

In force as amended; Japanese original controls

Duties / expectations

Requires specified purposes, appropriate acquisition/security, rights handling and controls on third-party/cross-border provision. AI data processing needs purpose and transfer review.

Evidence to consider

Purpose notices, special-care information handling, third-party records, security, rights and breach decisions.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

APPI and PPC rules/guidelines

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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China / Law

China Personal Information Protection Law

Personal-information handlers within territorial/extraterritorial statutory scope. Localization and transfer obligations depend on thresholds and current implementing measures.

Duties, evidence, limitations & official sources

Status / timing

In force; official Chinese text controls

Duties / expectations

Requires lawful processing, notice/consent or other grounds, rights, security and relevant impact assessments. Automated decisions have transparency/fairness and contest-related protections.

Evidence to consider

Processing grounds, sensitive-data assessment, automated-decision review, transfer mechanism and rights evidence.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

PIPL, including Article 24

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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China / Law

China Data Security Law

Data activities within statutory scope, with important/core-data and national-security implications beyond personal information.

Duties, evidence, limitations & official sources

Status / timing

In force; classification/export rules require current local review

Duties / expectations

Requires classification-based data security and risk management, with additional duties for relevant important-data processing. Distinguish personal-information and industrial/security data requirements.

Evidence to consider

Data classification, risk assessments, access controls, incident handling and cross-border authorization analysis.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Data Security Law 2021

Review limitation

October 13, 2026 source check: the primary page was blocked, unavailable or not machine-readable. The earlier synopsis is retained for orientation, not represented as a newly verified current legal or technical requirement. Validate the current primary text before reliance.

Source check: 2026-10-13 / Text revision: 2026-09-17

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China / Regulation

China Interim Measures for Generative AI Services

Generative AI services provided to the public in China; the measures exclude certain nonpublic internal research/application uses from their specific scope.

Duties, evidence, limitations & official sources

Status / timing

Effective August 15, 2023

Duties / expectations

Addresses lawful training sources, personal information/IP, content obligations, service protection and oversight. Other cyber/data/sector laws still apply to excluded internal use.

Evidence to consider

Dataset provenance, consent/rights, content safeguards, complaint/incident handling and provider filing/security assessment where applicable.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

CAC and six other agencies, Order 15

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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India / Law / regulation

India Digital Personal Data Protection Act and Rules

Digital personal-data processing within the Act's territorial/extraterritorial scope. Confirm which statutory/rule provisions have commenced before treating all duties as operative.

Duties, evidence, limitations & official sources

Status / timing

Rules notified November 2025; phased 18-month implementation

Duties / expectations

Provides notice/consent and specified legitimate uses, data-fiduciary safeguards, individual rights, breach handling and additional duties for designated significant data fiduciaries.

Evidence to consider

Data-purpose/consent records, security controls, child-data review, rights/grievance workflow and phased compliance plan.

Scope qualification

The official November 2025 government explanation describes an 18-month phased implementation. The MeitY page did not yield readable current text in this review; consult the Gazette commencement notifications for the exact provisions operative on the relevant date. Do not label every substantive duty already effective.

Source locator

DPDP Act 2023; Rules 2025; commencement notifications

Review limitation

Source-level review is limited to the available official material; organization-specific applicability and implementing details still require assessment.

Source check: 2026-10-13 / Text revision: 2026-10-13

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India / Regulatory direction

India CERT-In cybersecurity directions

Covered service providers, intermediaries, data centers, bodies corporate and government organizations; additional duties apply to specified services.

Duties, evidence, limitations & official sources

Status / timing

2022 directions; applicable scope and exemptions matter

Duties / expectations

Requires specified incident reporting, log retention, time synchronization and other records. Map Indian legal duties to overseas cloud/AI service architectures.

Evidence to consider

Incident classification/escalation, log availability, time controls, contact designation and required subscriber records.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

IT Act Section 70B directions, April 28, 2022

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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Brazil / Law

Brazil General Personal Data Protection Law

Personal-data processing within LGPD nexus; different lawful bases and public/private-sector rules may apply.

Duties, evidence, limitations & official sources

Status / timing

In force; ANPD regulations supplement the law

Duties / expectations

Requires legal basis, transparency, data-subject rights, safeguards and accountability. Article 20 addresses review of solely automated decisions affecting interests.

Evidence to consider

Legal-basis register, rights/review workflow, security, transfer controls and impact reports where required.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Law 13.709/2018 as amended

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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South Africa / Law

South Africa Protection of Personal Information Act

Responsible parties and operators within POPIA scope; special personal information and child data have additional constraints.

Duties, evidence, limitations & official sources

Status / timing

In force

Duties / expectations

Sets processing conditions, security safeguards, rights, cross-border rules and restrictions on specified automated decisions.

Evidence to consider

Information-officer governance, purpose/ground records, operator contracts, safeguards, rights and compromise notifications.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

Act 4 of 2013; Section 71 automated decisions

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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Switzerland / Law

Swiss Federal Act on Data Protection

Private persons and federal bodies within FADP scope; cantonal public-sector regimes can differ.

Duties, evidence, limitations & official sources

Status / timing

Revised Act effective September 1, 2023

Duties / expectations

Requires proportionate transparent processing, security, rights and relevant DPIAs; covers specified automated decisions and international disclosures.

Evidence to consider

Processing inventory, notices, impact assessments, automated-decision review, transfers and breach escalation.

Scope qualification

Source-review boundary (September 17, 2026): Direct full text was not retrievable; the entry is orientation only. No assumption that a planned rule is operative.

Source locator

Federal Act on Data Protection of September 25, 2020

Review limitation

October 13, 2026 source check: the primary page was blocked, unavailable or not machine-readable. The earlier synopsis is retained for orientation, not represented as a newly verified current legal or technical requirement. Validate the current primary text before reliance.

Source check: 2026-10-13 / Text revision: 2026-09-17

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New Zealand / Law

New Zealand Privacy Act

Agencies and organizations within statutory scope, including relevant overseas agencies carrying on business in New Zealand.

Duties, evidence, limitations & official sources

Status / timing

Privacy Act 2020 in force; IPP3A indirect-collection notice commenced May 1, 2026

Duties / expectations

Privacy principles govern collection, notice, security, accuracy, rights, retention, use, disclosure and overseas transfers. New IPP3A extends notice obligations to covered indirect collection.

Evidence to consider

Privacy notices, indirect-data provenance, security, access/correction, serious-harm breach assessment and transfer controls.

Scope qualification

IPP3A adds an indirect-collection notification duty subject to its exceptions. Existing principles, including the conditions for collecting indirectly, remain relevant; notice is not a blanket permission to collect.

Source locator

Privacy Act 2020; Privacy Amendment Act 2025

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - NIST / Standard / framework

NIST AI Risk Management Framework 1.0

Organizations designing, developing, deploying or using AI; voluntary unless incorporated into law, procurement or contract.

Duties, evidence, limitations & official sources

Status / timing

AI RMF 1.0 remains the published final framework; revision work is ongoing

Duties / expectations

Organizes work through Govern, Map, Measure and Manage; trustworthiness is contextual and involves trade-offs. It does not certify an AI system or replace jurisdiction-specific law.

Evidence to consider

AI inventory, risk governance, evaluations, response plans, ownership and documented residual risk.

Scope qualification

NIST states that AI RMF 1.0 is being revised. A revision project or critical-infrastructure concept note is not a final replacement framework or a certification program.

Source locator

AI RMF 1.0 / NIST AI 100-1

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - NIST / Standard / framework

NIST Generative AI Profile

Organizations using generative models and applications; companion profile to the AI RMF.

Duties, evidence, limitations & official sources

Status / timing

NIST AI600-1 final, July 26, 2024; voluntary Generative AI Profile

Duties / expectations

Identifies generative-AI risks and potential actions, including content integrity, privacy, security, value-chain and information risks. Actions need context-specific selection.

Evidence to consider

Threat/use-case analysis, test plans, content provenance, supplier evidence and monitoring.

Scope qualification

The profile supplements AI RMF 1.0 and recommends risk-management actions. It is not a universal safety guarantee or an independent certification scheme.

Source locator

NIST AI 600-1

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - NIST / Standard / framework

NIST Cybersecurity Framework

Organizations managing cyber risk, including business processes supported by AI.

Duties, evidence, limitations & official sources

Status / timing

Published guidance or standard; binding only where adopted

Duties / expectations

Provides Govern, Identify, Protect, Detect, Respond and Recover outcomes. Profiles and tiers guide communication; mapping a control is not proof that an outcome is achieved.

Evidence to consider

Current/target profiles, risk priorities, control evidence and improvement tracking.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

CSF 2.0

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - NIST / Standard / framework

NIST Privacy Framework - final 1.0 / draft 1.1

Organizations managing privacy risk across data-processing ecosystems.

Duties, evidence, limitations & official sources

Status / timing

Version 1.0 final; version 1.1 Initial Public Draft remains draft in the reviewed publication record

Duties / expectations

Connects data-processing activities to privacy outcomes and governance. It is voluntary and distinct from a checklist for GDPR or US state-law compliance.

Evidence to consider

Data processing maps, privacy risk assessment, controls and communication.

Scope qualification

Use 1.0 as the final adoption baseline unless an organization explicitly adopts draft material. A closed comment period does not make version 1.1 final.

Source locator

Privacy Framework 1.0; NIST CSWP40 (1.1 Initial Public Draft)

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - NIST / Standard / framework

NIST SP800-53 Rev.5 - security and privacy controls

Information systems within adopted security/privacy baselines; federal use and nonfederal contractual uses differ.

Duties, evidence, limitations & official sources

Status / timing

Revision 5 final; minor Release 5.2.0 issued August 27, 2025

Duties / expectations

Defines control families for access, audit, assessment, incident response and more. Tailoring, implementation and assessment are required; a crosswalk alone proves nothing.

Evidence to consider

Control applicability, implementation statements, assessments, POA&M and continuous monitoring.

Scope qualification

Select and tailor controls under the applicable authorization/risk process. A minor catalog release is not automatic amendment of every existing contract, authorization baseline or organizational control set.

Source locator

SP 800-53 Rev.5 with updates

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - NIST / Standard / framework

NIST SSDF - SP800-218 v1.1 / v1.2 draft

Software producers and acquirers, including AI harnesses, toolchains and dependencies.

Duties, evidence, limitations & official sources

Status / timing

SSDF v1.1 final (2022); SP800-218 Rev. 1 / SSDF v1.2 Initial Public Draft (December 2025)

Duties / expectations

Recommends secure development practices and vulnerability response throughout the lifecycle. Contractual attestations and acquisition requirements are separate obligations.

Evidence to consider

Secure builds, code review, provenance, dependency controls, testing and vulnerability records.

Scope qualification

SP800-218A is a separate final AI-model development profile. Do not describe SSDF v1.2 draft practices as an adopted contractual requirement unless the relevant instrument expressly incorporates them.

Source locator

SP800-218 final; SP800-218 Rev.1 Initial Public Draft; SSDF publications list

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - NIST / Standard / framework

NIST incident response recommendations

Organizations integrating cyber incident response into risk management.

Duties, evidence, limitations & official sources

Status / timing

SP800-61 Rev.3 final, April 2025; a CSF 2.0 Community Profile

Duties / expectations

Connects preparation, detection, response and recovery with CSF 2.0. Use for agentic containment and evidence plans, not as a substitute for mandatory notification rules.

Evidence to consider

Incident playbooks, exercise records, containment authorization, recovery verification and lessons learned.

Scope qualification

Revision 3 supersedes Revision 2. Adapt response activities to the organization; the publication is not itself a statutory incident-notification timetable.

Source locator

SP 800-61 Rev.3

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - NIST / Standard / framework

NIST post-quantum cryptography standards

Cryptographic implementations and organizations with mandated or risk-based migration needs.

Duties, evidence, limitations & official sources

Status / timing

Published guidance or standard; binding only where adopted

Duties / expectations

Standardizes ML-KEM key encapsulation and ML-DSA/SLH-DSA signatures. Standards do not by themselves certify a whole product or mandate a single global migration date.

Evidence to consider

Cryptographic inventory, data-secrecy horizon, vendor readiness, interoperability and migration testing.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

FIPS 203, 204 and 205

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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International / technical framework / Standard / framework

ISO/IEC 42001 AI management systems

Organizations adopting an AI management system, optionally subject to independent certification.

Duties, evidence, limitations & official sources

Status / timing

ISO/IEC 42001:2023; voluntary management-system standard unless incorporated

Duties / expectations

Specifies management-system requirements for responsible AI development/use and continual improvement. Certification scope does not establish universal AI Act or product compliance.

Evidence to consider

AI policy, roles, risks/impacts, objectives, operational controls, audits and corrective action.

Scope qualification

Publisher summary reviewed, not the licensed full standard. Certification concerns a defined management-system scope; it does not establish the safety or legal compliance of every model, product or use case.

Source locator

ISO/IEC 42001:2023

Review limitation

Source check covers publication identity and available summary, not a licensed clause-by-clause assessment.

Source check: 2026-10-13 / Text revision: 2026-10-13

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International / technical framework / Standard / framework

ISO/IEC 23894 AI risk management

Organizations managing risks associated with AI products, systems and services.

Duties, evidence, limitations & official sources

Status / timing

ISO/IEC 23894:2023 risk-management guidance

Duties / expectations

Provides risk-management guidance tailored to AI. It is not a standalone certifiable management-system requirement.

Evidence to consider

Risk criteria, assessments, treatments, monitoring and stakeholder communication.

Scope qualification

Publisher abstract reviewed; licensed full text not assessed. Guidance does not create a standalone AI product certification or substitute for applicable legal duties.

Source locator

ISO/IEC 23894:2023

Review limitation

Source check covers publication identity and available summary, not a licensed clause-by-clause assessment.

Source check: 2026-10-13 / Text revision: 2026-10-13

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International / technical framework / Standard / framework

ISO/IEC 27001 information security management

Organizations establishing an information security management system.

Duties, evidence, limitations & official sources

Status / timing

ISO/IEC 27001:2022 information-security management-system standard

Duties / expectations

Requires risk-based management, scoped controls and continual improvement. An ISMS certificate does not mean every AI use or vendor has been technically validated.

Evidence to consider

ISMS scope, risk treatment, statement of applicability, audits and corrective actions.

Scope qualification

Publisher summary reviewed; licensed normative text and applicable amendments require an authorized copy. A certificate must be checked for scope, issuing body and validity; it is not evidence that all controls always operate.

Source locator

ISO/IEC 27001:2022

Review limitation

Source check covers publication identity and available summary, not a licensed clause-by-clause assessment.

Source check: 2026-10-13 / Text revision: 2026-10-13

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International / technical framework / Standard / framework

OWASP AI security guidance

Teams threat-modeling, testing and operating generative and agentic applications.

Duties, evidence, limitations & official sources

Status / timing

Published guidance or standard; binding only where adopted

Duties / expectations

Catalogs risks such as injection, supply-chain compromise, excessive agency and insecure output handling. It is community technical guidance, not legislation or certification.

Evidence to consider

Attack-surface map, adversarial tests, permission controls and detection/response evidence.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

LLM / agentic security projects

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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International / technical framework / Standard / framework

MITRE ATLAS

Security teams analyzing adversarial techniques against AI-enabled systems.

Duties, evidence, limitations & official sources

Status / timing

Published guidance or standard; binding only where adopted

Duties / expectations

Provides a knowledge base of adversary behavior and case studies. Mapping a technique supports threat analysis; it does not demonstrate control effectiveness.

Evidence to consider

Threat models, coverage analysis, exercises and observed detection/containment results.

Scope qualification

Source-review boundary (September 17, 2026): Living catalog; no exhaustive current technique count or identifier validation is claimed.

Source locator

Adversarial Threat Landscape for AI Systems

Review limitation

October 13, 2026 source check: the primary page was blocked, unavailable or not machine-readable. The earlier synopsis is retained for orientation, not represented as a newly verified current legal or technical requirement. Validate the current primary text before reliance.

Source check: 2026-10-13 / Text revision: 2026-09-17

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International / technical framework / Standard / framework

OECD AI Principles

Governments and organizations using the OECD policy framework and definitions.

Duties, evidence, limitations & official sources

Status / timing

Published guidance or standard; binding only where adopted

Duties / expectations

Promotes human-centered, transparent, robust and accountable AI. The recommendation is not directly enforceable as a private-sector statute.

Evidence to consider

Principles-to-control mapping, stakeholder review, transparency and accountability mechanisms.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

OECD Recommendation on Artificial Intelligence

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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International / technical framework / Standard / framework

Web Content Accessibility Guidelines

Web content and applications; legal incorporation and required level vary by jurisdiction and contract.

Duties, evidence, limitations & official sources

Status / timing

Published guidance or standard; binding only where adopted

Duties / expectations

Provides testable accessibility criteria including keyboard access, focus, contrast and reflow. Automated testing alone is not a complete conformance assessment.

Evidence to consider

Accessibility tests, assistive-technology review, issue remediation and documented scope.

Scope qualification

Applicability requires an entity-, activity- and jurisdiction-specific review.

Source locator

WCAG 2.2

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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International - OWASP / Community risk taxonomy

OWASP Top 10 for Agentic Applications 2026

Technical reference for behavioral conformance. Evaluate the sequence of plans, tool requests, retries, delegations and outcomes against an approved operating envelope. A plausible final answer is not evidence that the route taken was authorized.

Duties, evidence, limitations & official sources

Status / timing

Community risk taxonomy, published December 2025; not legislation

Duties / expectations

This entry describes technical guidance or specification context, not a standalone statutory duty. Define expected actions, prohibited means, materiality thresholds and escalation conditions for the use case before granting autonomy.

Evidence to consider

Task and session lineage; tool and policy decisions; versioned evaluation sets and results; quality/permission metrics; exception dispositions; comparisons between claimed completion and the actual system of record.

Scope qualification

Scope reconstructed from the saved v11 crosswalk. This review supports the published orientation summary, not complete legal applicability, implementation certification or every clause of the full instrument.

Source locator

OWASP Top 10 for Agentic Applications 2026

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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International - MCP / Technical specification

MCP authorization specification (2026-07-28)

Technical reference for action interlocks. Place enforceable checks between a proposed operation and its side effects. Tool availability, a model request and transport-level access must not be mistaken for business authorization.

Duties, evidence, limitations & official sources

Status / timing

Pinned specification edition; transport authorization is not business-action approval

Duties / expectations

For applicable HTTP-based MCP authorization, validate the token audience, use resource indicators and follow the specified discovery/issuer checks. Tokens must not be placed in query strings or passed through for another resource. Independently authorize the actual tool action, destination, scope and business effect; successful OAuth access is not approval for a payment, disclosure or destructive operation.

Evidence to consider

A tool/version inventory; argument-validation and authorization decisions; action-specific approval; execution receipt and reconciliation; exception or denial records; test evidence for bypass, replay and target substitution.

Scope qualification

Pinned July 28, 2026 reference. Transport authorization and business-action authorization are separate. The site is an educational diagram and does not implement or operate an MCP server.

Source locator

MCP authorization specification (2026-07-28)

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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International - OpenTelemetry / Technical specification

OpenTelemetry GenAI span conventions

Technical reference for decision evidence. Create an independently protected record connecting the mandate, relevant inputs, versions, policy decisions, actions and observed outcomes. Make uncertainty and missing evidence explicit.

Duties, evidence, limitations & official sources

Status / timing

Technical conventions; many GenAI attributes/operations remain Development stability

Duties / expectations

Pin the semantic-convention revision used by each instrumentation pipeline and test schema changes. Capture trace context, model/version, operation, authorization and outcome metadata as appropriate. Prompt, response and tool-content capture requires a separately justified purpose, access control and retention decision; hashes are not necessarily anonymous.

Evidence to consider

A synchronized event chain; model/tool/policy version identifiers; downstream execution receipts; integrity and access records; collection-gap alerts; retention/hold decisions; disclosed reconstruction limitations.

Scope qualification

Do not assume that fields on a mutable main branch are stable or that OpenTelemetry automatically produces an OCSF mapping. Preserve the mapping/version and validate the evidence pipeline.

Source locator

OpenTelemetry GenAI span conventions

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - NIST / Guidance

NIST SP 800-218A: AI-model secure development profile

Technical reference for lifecycle accountability. Keep use cases, dependencies, obligations, control owners and material changes under accountable governance from procurement through retirement. Repeatable evidence supports decisions; it does not transfer accountability.

Duties, evidence, limitations & official sources

Status / timing

Final, July 2024; complements SSDF, not a complete deployer compliance standard

Duties / expectations

This entry describes technical guidance or specification context, not a standalone statutory duty. Maintain a use-case register and SBOM/AIBOM scope covering relevant software, models, data, tools, connectors and hosting dependencies. Record known unknowns and validate provenance and critical components.

Evidence to consider

An accountable inventory; applicability analysis; component provenance and validation; release/change approvals; vendor obligations; exception and remediation decisions; board reporting and retirement evidence.

Scope qualification

Scope reconstructed from the saved v11 crosswalk. This review supports the published orientation summary, not complete legal applicability, implementation certification or every clause of the full instrument.

Source locator

NIST SP 800-218A: AI-model secure development profile

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - NCCoE / Draft concept paper

NCCoE: software and AI-agent identity and authorization

Technical reference for authority lineage. Keep the initiating person, each delegated agent and the executing service attributable. A handoff should narrow or preserve authorized scope, not silently create new authority.

Duties, evidence, limitations & official sources

Status / timing

NCCoE concept paper, February 2026; not a final practice guide or mandatory standard

Duties / expectations

This entry describes technical guidance or specification context, not a standalone statutory duty. Bind the principal, tenant, task purpose, permitted resources, duration and onward-delegation limits to each handoff.

Evidence to consider

An attributable delegation chain; policy version and decision identifier; requested versus granted scope; credential issuance and expiry; revoked-child and denied-action records. Protect identifiers and tokens: evidence should not become a secrets repository.

Scope qualification

The paper frames software/AI-agent identity and authorization work. Its presence in a crosswalk does not certify an implementation or create a new legal duty.

Source locator

NCCoE: software and AI-agent identity and authorization

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - CISA / Guidance

CISA / international partners: SBOM for AI minimum elements

Technical reference for lifecycle accountability. Keep use cases, dependencies, obligations, control owners and material changes under accountable governance from procurement through retirement. Repeatable evidence supports decisions; it does not transfer accountability.

Duties, evidence, limitations & official sources

Status / timing

Recommendations, May 12, 2026; not a universal legal mandate; official indexed publication reviewed, full page access restricted

Duties / expectations

This entry describes technical guidance or specification context, not a standalone statutory duty. Maintain a use-case register and SBOM/AIBOM scope covering relevant software, models, data, tools, connectors and hosting dependencies. Record known unknowns and validate provenance and critical components.

Evidence to consider

An accountable inventory; applicability analysis; component provenance and validation; release/change approvals; vendor obligations; exception and remediation decisions; board reporting and retirement evidence.

Scope qualification

Scope reconstructed from the saved v11 crosswalk. Publication identity and described scope only. The full current document was not independently checked.

Source locator

CISA / international partners: SBOM for AI minimum elements

Review limitation

October 13, 2026 source check: the primary page was blocked, unavailable or not machine-readable. The earlier synopsis is retained for orientation, not represented as a newly verified current legal or technical requirement. Validate the current primary text before reliance.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - CISA / Guidance

CISA: 2026 minimum elements for an SBOM

Technical reference for lifecycle accountability. Keep use cases, dependencies, obligations, control owners and material changes under accountable governance from procurement through retirement. Repeatable evidence supports decisions; it does not transfer accountability.

Duties, evidence, limitations & official sources

Status / timing

Guidance, July 29, 2026; complements, rather than substitutes for, component testing; official indexed publication reviewed, full page access restricted

Duties / expectations

This entry describes technical guidance or specification context, not a standalone statutory duty. Maintain a use-case register and SBOM/AIBOM scope covering relevant software, models, data, tools, connectors and hosting dependencies. Record known unknowns and validate provenance and critical components.

Evidence to consider

An accountable inventory; applicability analysis; component provenance and validation; release/change approvals; vendor obligations; exception and remediation decisions; board reporting and retirement evidence.

Scope qualification

Scope reconstructed from the saved v11 crosswalk. Publication identity and described scope only. The full current document was not independently checked.

Source locator

CISA: 2026 minimum elements for an SBOM

Review limitation

October 13, 2026 source check: the primary page was blocked, unavailable or not machine-readable. The earlier synopsis is retained for orientation, not represented as a newly verified current legal or technical requirement. Validate the current primary text before reliance.

Source check: 2026-10-13 / Text revision: 2026-09-17

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United States - California / Law / implementation development

California SB813 - independent AI verification organizations

Establishes a framework for independent verification organizations assessing AI systems/models. Enactment is supported by the official signing announcement.

Duties, evidence, limitations & official sources

Status / timing

Signed September 9, 2026; detailed operative requirements require chaptered-text validation

Duties / expectations

Treat the announcement as an implementation development, not a claim that every AI deployer must immediately purchase an audit. Determine the final covered actors, recognition criteria and implementation dates from the chaptered text.

Evidence to consider

For planning: assessor-independence criteria, evaluation scope, conflict disclosures and procurement review.

Scope qualification

Official signing summary reviewed; chaptered full text and agency implementation not independently verified. No claim that Rich or this site is a state-recognized verifier.

Source locator

SB813 (2025-2026 session)

Review limitation

Source-level review is limited to the available official material; organization-specific applicability and implementing details still require assessment.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - California / Law / implementation development

California AB1405 - AI auditor registry and independence

Creates an AI auditor registry and an independence/transparency framework, as described in the official signing announcement.

Duties, evidence, limitations & official sources

Status / timing

Signed September 9, 2026; registry implementation and operative details require validation

Duties / expectations

Do not infer a current registration status or universal enterprise audit obligation. Check the enacted scope, regulator implementation and auditor eligibility before relying on registry language.

Evidence to consider

For planning: qualifications, independence, conflicts, audit-method documentation and accurate representations about registration.

Scope qualification

Signing announcement supports this orientation; the registry's operational status and full statutory text were not independently verified.

Source locator

AB1405 (2025-2026 session)

Review limitation

Source-level review is limited to the available official material; organization-specific applicability and implementing details still require assessment.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - California / Executive direction / policy development

California September 2026 AI oversight executive direction

Directs state work on independent oversight and recommendations for stronger frontier-AI safeguards.

Duties, evidence, limitations & official sources

Status / timing

September 18, 2026 executive direction; further proposals are not blanket private-sector mandates

Duties / expectations

The Governor calls for accelerated implementation work and recommendations on independent verification and emergency interruption. Recommendations under consideration are not treated as an already operative universal kill-switch requirement.

Evidence to consider

For planning: monitor agency implementation, interruption testing, independent evidence and clearly assigned response authority.

Scope qualification

Differentiate state-agency directions, enacted law, and potential future private-sector requirements.

Source locator

Executive direction announced September 18, 2026

Review limitation

Source-level review is limited to the available official material; organization-specific applicability and implementing details still require assessment.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - California / Law / regulation

California Delete Act / DROP data-broker deletion system

Registered data brokers within the Delete Act's scope; not every business maintaining an internal AI dataset is a data broker.

Duties, evidence, limitations & official sources

Status / timing

DROP regulations effective January 1, 2026; broker processing duties started August 1, 2026

Duties / expectations

Covered brokers must access/process DROP requests on the required cycle, generally at least every 45 days, and propagate applicable deletions. Validate exceptions, identity matching and downstream treatment under the final rules.

Evidence to consider

Broker status assessment, request-processing logs, matching/deletion decisions, downstream instructions and exception records.

Scope qualification

This is a broker-specific deletion mechanism, not a substitute for other CCPA rights workflows.

Source locator

Delete Act; DROP regulations

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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United States - NIST / Concept note / framework development

NIST AI RMF critical-infrastructure profile - concept stage

AI-enabled capabilities used by critical-infrastructure operators.

Duties, evidence, limitations & official sources

Status / timing

Concept note released April 7, 2026; not a final replacement for AI RMF 1.0

Duties / expectations

The NIST project identifies work toward sector-relevant AI risk-management practices. Use published final frameworks as the baseline; label concept material and proposed mappings explicitly.

Evidence to consider

For planning: use-case criticality, safety/continuity dependencies, risk ownership and documented feedback on draft practices.

Scope qualification

Project direction is not a standard, certification or legal obligation.

Source locator

AI RMF Profile for Trustworthy AI in Critical Infrastructure

Review limitation

Source identity and the published orientation were reviewed; this is not an exhaustive clause-level or jurisdiction-specific legal opinion.

Source check: 2026-10-13 / Text revision: 2026-10-13

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