All courses / AI Governance / Module 3 / Chapter 11
Learning objectives
After the lesson the participant can:
- Distinguish attestation from evidence and name the four characteristics of evidence as code.
- Describe the contents of an evidence bundle and the two design decisions that make the chain trustworthy.
- Design an inference log that separates the record of events from content containing personal data.
- Draft an evidence-pack index and an audit test procedure with a design test and an operating effectiveness test.
Key concepts
- Attestation versus evidence
- Attestation is a person asserting that a control operated. Evidence is a machine-generated artefact that demonstrates it. The auditor's question about which model served decisions on a given date should be answered from evidence within an hour.
- Evidence manifest
- The record that ties the chain together for one release: hashed subjects such as model, dataset and prompt bundle, evaluation reports, controls mapped to obligations and artefacts, approvals, a cryptographic attestation and retention periods.
- Events separated from content
- The event record, proving the system operated within its declared bounds, is kept for the regulatory period in append-only storage. Content with personal data is pseudonymised at ingestion, held under shorter retention and linked by a reference under a documented access procedure.
- Evidence pack
- A set of artefacts generated by query for one system and period. Its index lists each audit question, the artefacts that answer it and their hashes, and records the query and generator commit so that a second auditor can regenerate it.
- AI-specific incident classification
- A step in the incident process for every production incident touching an AI system, recording the answer and the reasoning whatever the outcome, so that the fifteen-day deadline of Article 73 can be met and a negative assessment can be reviewed.
Interactive exercises
Do them here and get feedback at once. Choose a card and then where it belongs, or drag it.
Interactive exercise 1 · Put in order
The five stages of the evidence chain
Put the stages of the evidence chain in order, from where the truth is kept to who reads the result.
Interactive exercise 2 · Scenario
An incident that is probably not serious
Apply the chapter's incident process for AI systems in a financial entity.
Teaching plan
| 10 min | Opening: the teacher puts the auditor's question to the room: which model version served decisions on a given date, on what data, with what evaluation, approved by whom. Participants estimate how long the answer would take. |
| 25 min | Teacher presentation of the evidence chain, the manifest, Annex IV as queries against the repository, logging and retention, and the table of artefacts that serve both the AI Act and DORA. |
| 15 min | Guided reading of audit test procedure TP-AI-014 and Hansa Mutual's incident classification record INC-2026-0457; discussion of why steps O4 and O5 carry the most value. |
| 30 min | Exercise in pairs: build an evidence-pack index for one system and write a test procedure for one of its controls. |
| 10 min | Debrief: pairs report which sections of their index are empty and treat each empty section as a finding. |
Discussion
- Evidence as code lets auditors spend their time on questions that need judgement. Which three questions about your AI systems can no event log answer?
- Hansa Mutual recorded that Article 73 did not apply to its incident. What is the value of recording a negative assessment, and who reads it?
- For Modes 0 to 2 the evidence is largely what the supplier lets the organisation export. What should your contracts say about audit logs, and what is the strongest evidence you hold today for those modes?
Written exercise
Exercise · 30 minutes
Build an evidence-pack index and a test procedure
Choose one AI system and a two-month period. Draft the index of an evidence pack in the form of Nordvik Region's EP-2026-011: at least four sections, each headed by an audit question tied to an obligation, such as use per intended purpose, human oversight operating as designed, and logs complete and retained for at least six months, with the artefacts that would answer it. Mark honestly which artefacts exist today. Then write a test procedure for one control, modelled on TP-AI-014: a design test with two steps, an operating effectiveness test with a sample size, a step that recomputes a metric from raw events, one interview step, and the conditions under which the control is judged deficient.
Deliverable: An evidence-pack index with at least four audit questions and their artefacts, gaps marked, and a one-page audit test procedure for one control.
Self-test
Choose an answer to see whether it is right, or open the answer below each question.
Which two design decisions make the evidence chain trustworthy, according to the chapter?
Show the answer
C. Evidence is written once and never edited, and it is signed inside the pipeline with an identity bound to the run
Artefacts sit in an append-only store with retention locks and each manifest references the previous one. Signing uses an identity bound to the pipeline run, not a key an engineer holds.In audit test procedure TP-AI-014, why does the auditor recompute the weekly override rate from raw events?
Show the answer
B. Because it tests the metric pipeline as well as the control, so a broken dashboard cannot hide a broken control
Step O4 requires the recomputed rate to match the published metric exactly. That tests the metric pipeline together with the control, which is why the chapter says it carries the most value alongside O5.Within what period must a provider report a serious incident under Article 73 of the AI Act, as the chapter states it?
Show the answer
A. Immediately after establishing a causal link or its likelihood, and at most fifteen days after becoming aware
The chapter gives the deadline as immediately after establishing a causal link or its reasonable likelihood and in any case within fifteen days of awareness, with shorter deadlines for the gravest incidents.