{"what_this_is":"Where language models are and are not used on this platform, with the live call ledger and the AI laws a reviewer will ask about.","position":{"the_record":"Receipts, rosters, Receipt Watch diffs, held-file reads and the Audit Handover file are produced by deterministic code that fetches a named official source and copies what it printed. No language model reads a source, decides what a source printed, builds a receipt, computes a hash, signs or timestamps anything, or decides whether two names are the same party. Every receipt body carries this statement with model_calls_during_build = 0, inside the hashed and signed body.","the_guard":"Every model call on this platform passes through one ledger function (aillog.record). That function refuses, and writes the refusal down, if it is reached while a receipt is being built. The ledger is public in aggregate at /api/public/ai-calls and per receipt at /api/public/ai-calls?receipt_id=.","no_decisions":"The platform makes no determination about any person or organization — no score, flag, rating, clearance, eligibility, compliance, credit, employment, tenant, insurance or risk conclusion — by model or otherwise. Model output here is explanation or draft, labelled as such, optional, and never an input the platform acts on.","ai_off_mode":"Any account can switch AI off (/account/ai-mode or POST /api/account/ai-mode). In AI-off mode every AI surface returns 403 before any model is touched for requests bearing that account's session; the receipt product is unchanged because it never involved a model. Buyers who must avoid procuring an 'AI system' can take the product this way and the contract says so."},"surfaces":{"explain":{"calls":0,"refused":0,"models":[],"who":"visitor or customer","what":"plain-English explanation of a receipt or record already fetched; the model sees only numbered facts from that record","route":"/api/explain"},"record_reader":{"calls":0,"refused":0,"models":[],"who":"visitor or customer","what":"reading and Q&A over numbered lines lifted from a receipt or Audit Handover file; determinations are refused before the model is called","route":"/api/ai"},"forms_desk":{"calls":0,"refused":0,"models":[],"who":"visitor or customer","what":"draft answer to a form question from the register, the eCFR text and the filer's own public filing; each sentence cited","route":"/api/forms-desk"},"free_guide":{"calls":0,"refused":0,"models":[],"who":"visitor","what":"plain-words help and translation pointing to the official free sources on /free; never fills or submits a form","route":"/api/free-guide"},"advisory_desk":{"calls":0,"refused":0,"models":[],"who":"operator only","what":"internal consultants briefed on a standard's public text and our own SOPs; nothing customer-facing","route":"/api/advisors"},"daily_replay_summary":{"calls":2,"refused":0,"models":["claude-sonnet-5-5"],"who":"operator only","what":"plain-English summary written FROM the daily self-check results after they are computed","route":"/api/audit"},"source_scout":{"calls":0,"refused":0,"models":[],"who":"operator only","what":"memo per Federal Register item for the owner's decision; recommends, never publishes","route":"/api/audit/sentinel"},"social_caption":{"calls":0,"refused":0,"models":[],"who":"operator only","what":"caption draft for our own posts; a person reviews before anything is published","route":"/api/social"}},"ledger":{"window_days":30,"calls_in_window":2,"refused_inside_receipt_build_all_time":0,"ledger_began":"2026-10-25T10:05:35.768001+00:00"},"inventory":[{"id":"AI-001","surface":"explain","description":"Plain-English explanation of a receipt or record already fetched","determination":"None. Output is a labelled explanation of facts already printed; the platform acts on nothing in it.","human_role":"A reader reads it; nothing is issued, changed or decided from it.","off_switch":"AI-off mode (account) / EMERGENT_LLM_KEY unset (global)"},{"id":"AI-002","surface":"record_reader","description":"Reading aloud and Q&A over numbered lines lifted from a receipt or Audit Handover file","determination":"None. Questions that ask for a determination are refused before the model is called.","human_role":"Same as AI-001.","off_switch":"same"},{"id":"AI-003","surface":"forms_desk","description":"Draft answer to a form question from the register, eCFR text and the filer's own public filing","determination":"None. A draft; the filer fills and signs their own form.","human_role":"The filer edits and submits; the draft is logged with its citations.","off_switch":"same"},{"id":"AI-004","surface":"free_guide","description":"Plain-words help and translation pointing to official free sources","determination":"None. Never fills or submits a form.","human_role":"Visitor reads; nothing is filed.","off_switch":"same"},{"id":"AI-005","surface":"advisory_desk","description":"Operator-only internal consultants on a standard's public text and our SOPs","determination":"None. Advice to the operator about our own documents.","human_role":"Operator decides; nothing customer-facing.","off_switch":"global"},{"id":"AI-006","surface":"daily_replay_summary","description":"Summary written FROM the daily self-check results after they are computed","determination":"None. The checks are computed first; the model narrates them.","human_role":"Operator reads.","off_switch":"global"},{"id":"AI-007","surface":"source_scout","description":"Memo per Federal Register item for the owner's source decision","determination":"None. Recommends a source to read; the owner adds or declines.","human_role":"Owner decides.","off_switch":"global"},{"id":"AI-008","surface":"social_caption","description":"Caption drafts for our own posts","determination":"None.","human_role":"A person reviews before anything is published.","off_switch":"global"}],"declined":[{"proposed":"Candidate match triage ranked by a deterministic fuzzy score","why_not":"RULES.md forbids fuzzy, probabilistic or similarity matching and any score. Receipts match on exact key or exact printed name only; two rows under the same name are never asserted to be the same party. A ranked candidate list is an identity determination with a number on it."},{"proposed":"Draft narrative on whether a candidate match is the same entity","why_not":"That is an identity determination, which no surface here makes. The record reader refuses determination questions before the model is called."},{"proposed":"Recommendation: clear / escalate / request_more_info","why_not":"'Clear' is on the forbidden-words list of the Receipt Format, and a recommendation is a decision input. The platform issues receipts, not recommendations; decisions belong to the customer's named officer, who records them on a decision record we countersign for hash and time only."},{"proposed":"Anomaly flagging in transaction clusters","why_not":"'Anomaly' and 'red flag' are forbidden words in the Receipt Format; a flag is a verdict. We print what a source printed and when."},{"proposed":"Tracking divergence between AI recommendations and officer decisions","why_not":"There are no recommendations to diverge from. The measurable things are published: calls per surface, model per call, prompt and output hashes, refusals inside a receipt build (zero)."}],"nist_ai_rmf":[{"function":"GOVERN","control":"RULES.md in the repository and the AI & Automation Policy (/legal/ai-usage) state what no model may touch; this inventory names a surface, a route and an owner for every model use; the owner is the operator of record."},{"function":"MAP","control":"Eight surfaces, each tied to one route and one purpose (table above). None sits in the receipt build path: aillog.ReceiptBuildGuard makes a model call inside a build a logged, raised error."},{"function":"MEASURE","control":"Every call is one ledger row: surface, provider, model, time, subject, prompt SHA-256, output SHA-256 and length, or the error class. Aggregates are public (/api/public/ai-calls); the texts live in the surface's own log. No recommendation-vs-decision metric exists because no recommendation exists."},{"function":"MANAGE","control":"AI-off mode per account (403 before any model call); global off by removing the model key; the deterministic record path and every issued receipt are unaffected either way."}],"omb_m_25_21_status":[{"requirement":"AI use case inventory","status":"Published on this page (AI-001…AI-008) with route, purpose and off switch; JSON at /api/public/ai-position for a customer's own documentation."},{"requirement":"High-impact / consequential-decision determination","status":"No surface makes or materially shapes any decision about a person or organization; the platform makes none. Reasoning: each row's 'determination' column. We do not grade this as a risk level — there is no scored risk here."},{"requirement":"Risk management (NIST AI RMF)","status":"Controls per function listed above; no certification claimed."},{"requirement":"Human oversight","status":"Receipts need no signature from anyone — they are deterministic reads, and that is the point: there is no AI step for a human to oversee in the record path. Where a customer records a decision, the customer's named officer types and signs it; we countersign hash and time."},{"requirement":"Audit logging","status":"Model identifier, prompt hash, output hash and length, time, subject and receipt linkage (calls ABOUT a receipt) are retained in the ledger; prompt and output texts in the surface logs. No model output contributes to a receipt, so 'officer decision vs. AI recommendation' is not a field."},{"requirement":"AI can be disabled","status":"Yes — per account (AI-off mode) and globally. The deterministic path is untouched."}],"laws":[{"instrument":"EU AI Act, Regulation (EU) 2024/1689 — Article 50 (transparency) and Annex III (high-risk)","turns_on":"Art. 50: a person interacting with an AI system, or reading AI-generated text, must be told. Annex III: systems that make or materially shape decisions on credit, employment, essential services, law enforcement and similar.","our_facts":"Every model output is labelled 'explanation', 'reading' or 'draft' with the provider and model named. No system here makes or shapes an Annex III decision; the Terms and Acceptable Use Policy prohibit using anything here for such decisions about individuals.","we_do_not_claim":"That we have conducted an EU conformity assessment, or that a customer's own use is outside the Act — the customer's use is the customer's.","check":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj"},{"instrument":"Colorado Artificial Intelligence Act (SB 24-205, as amended by later session bills)","turns_on":"Developers and deployers of 'high-risk' AI systems — systems that make or are a substantial factor in a consequential decision about a consumer (education, employment, financial or lending, essential government services, health care, housing, insurance, legal services).","our_facts":"The receipt is not an AI system. The AI surfaces here explain or draft text and are not a factor in any consequential decision the platform makes, because the platform makes none; the Acceptable Use Policy bars using the service for such decisions about a consumer.","we_do_not_claim":"An exemption. We state facts; whether a customer's workflow is a 'deployment' is the customer's determination. The compliance date has moved more than once — read the Attorney General's page for the current one.","check":"https://coag.gov/ai/"},{"instrument":"Texas Responsible Artificial Intelligence Governance Act (HB 149, TRAIGA), effective 2026-01-01","turns_on":"Disclosure when a government agency's AI interacts with a consumer; prohibited uses (manipulation, social scoring, certain biometric identification, discrimination with intent).","our_facts":"Every AI output is labelled as model output at the point it appears. None of the prohibited uses is present: no scoring of persons, no biometric identification, no profiling.","we_do_not_claim":"To be a government agency or to speak for one; a Texas agency that buys the product with AI surfaces on must make its own disclosure, or buy it in AI-off mode.","check":"https://www.oag.state.tx.us/consumer-protection/file-consumer-complaint/consumer-ai-rights"},{"instrument":"California AI Transparency Act (SB 942, as amended by AB 853) and AB 2013 (training-data transparency)","turns_on":"SB 942: 'covered providers' of generative AI systems with over one million monthly users must offer detection tools and latent disclosures. AB 2013: developers of generative AI systems must publish training-data documentation.","our_facts":"We do not develop or train a generative AI system and do not have one million monthly users; we call third-party models (OpenAI, Anthropic, Google) and label the output.","we_do_not_claim":"That the model providers' own obligations are ours, or that our labels are the providers' latent disclosures.","check":"https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=BPC&division=8.&title=&part=&chapter=25.&article="},{"instrument":"Utah Artificial Intelligence Policy Act (SB 149, 2024, as amended)","turns_on":"Disclosure that a person is interacting with generative AI when asked, and always for regulated occupations.","our_facts":"Disclosure is not on request here; every AI output carries the label and model name every time.","we_do_not_claim":"That the labels satisfy any regulated-occupation duty of a customer who is a licensed professional.","check":"https://le.utah.gov/~2024/bills/static/SB0149.html"},{"instrument":"OMB Memoranda M-25-21 (agency use of AI) and M-25-22 (acquisition of AI) — bind federal agencies","turns_on":"Agencies must inventory AI use cases, manage 'high-impact' AI, and apply acquisition terms when they buy AI.","our_facts":"The receipt product contains no AI and is available with every AI surface off (AI-off mode), so an agency can procure it as software. If an agency uses the AI surfaces, the facts an inventory needs — surfaces, providers, models, logging, what the model sees — are on this page and in the ledger.","we_do_not_claim":"That this page satisfies any agency's AI governance plan; those duties bind the agency.","check":"https://www.whitehouse.gov/omb/information-for-agencies/memoranda/"},{"instrument":"GDPR Article 22 (decisions based solely on automated processing)","turns_on":"A decision with legal or similarly significant effect on a person made solely by automated means, including profiling.","our_facts":"No decision is made here about anyone; no profiling or scoring occurs. Customer decision records are typed and signed by the customer's named officer; we countersign the hash and time only.","we_do_not_claim":"Anything about the customer's downstream processing.","check":"https://eur-lex.europa.eu/eli/reg/2016/679/oj"},{"instrument":"NIST AI Risk Management Framework 1.0 (voluntary)","turns_on":"Govern / Map / Measure / Manage functions for organizations that design, develop, deploy or use AI.","our_facts":"Map: eight named surfaces, listed below with who reaches them. Measure: every call in one ledger with provider and model. Manage: the receipt-build guard and AI-off mode. Govern: RULES.md and the AI & Automation Policy.","we_do_not_claim":"Certification against the framework; there is none to claim.","check":"https://www.nist.gov/itl/ai-risk-management-framework"}],"not_claimed":["This page is a statement of facts about this platform, not legal advice and not a compliance certification of any kind.","It says nothing about whether a customer's use of a receipt, an explanation or a draft meets the customer's own obligations under any of these instruments.","Laws and effective dates change; each row links the official page. Where this page and the official page differ, the official page is right and this is a corrections matter (/corrections)."],"policy":"https://alphacovenantholdings.com/legal/ai-usage","ledger_url":"https://alphacovenantholdings.com/api/public/ai-calls","html":"https://alphacovenantholdings.com/api/public/ai-position.html"}