Licence to Actthe control plane for AI agents
The sources

Where each statement on this site comes from

The claims register of the presenter pack, as published. Confidence: firm, a primary source checked; sourced, a reliable secondary source; ours, the Hub’s own reading or proposal; check, cited in working papers and to be verified before quoting.

Research and market

#ClaimWhere it appearsSourceScope and dateConfidenceSay it like thisDo not say
1The harness explained 7.8 times more of the variance in results than the modelPart three, essential 1Zhang, Wang, Ge, Xu, Hamm, Reddy, Stop Comparing LLM Agents Without Disclosing the Harness, arXiv 2605.23950, 7 May 2026, section 4.2harness-induced against model-induced variance, 18.48 against 2.37 pp², on a 100-task subset of SWE-bench Verified with three near-tied frontier models and three harness configurations; the authors say the ratio is not universalfirm"In a controlled study on coding tasks, the harness mattered several times more than the model. So a firm approves a release, not a model."that it was measured on financial decisions, or that the model does not matter
2No product we found keys a decision record to both the mandate version and the buildPart three, essential 5 and the three joinsthe Hub's vendor review, public product documentation, September 202623 vendors; documentation, not testsours"In the products we reviewed in September, we found none that does this; Credo AI's Agent Governor records the policy version in force, in research preview."that no product can do it, or that we tested the products
3Vendor placements on the map (product sold for this; feature inside a broader product; named, not seen shipped)Explorer, "Who sells what" and the vendor lensthe Hub's vendor review, September 2026public descriptions; an initial readingours"These are placements from public documentation, to check against the version a firm runs. They are not an assessment."that a vendor is compliant, certified, or ranked
4Narrow or widen, the step that moves the mandate on evidence, appears in none of the products reviewedExplorer, "Who sells what"as row 3as row 3ours"None of the products we reviewed moves the mandate on evidence; that return path is one of the three joins a firm builds."that it cannot be bought in future
4aNo product we found reads the standing of the basis at the moment of commit, which is what joins the second essential to the fourth essentialChapter 05, what you govern when you govern claimsthe Hub's vendor review, public product documentation, September 2026; the knowledge-plane products read against the check's six inputs23 vendors and the knowledge-plane category; documentation, not testsours"In the products we reviewed in September, management planes inventory the agents, control planes gate the tool call, and knowledge planes hold what the agent knows; we found none that reads the standing of the basis when the act commits."that no product can, or that we tested them
4bNone we found sells either rule: autonomy may not rise above evidence, or standing scales with consequenceChapter 05, the second rule; part three, essential 6as row 4aas row 4aours"We found no product that decides either rule for a firm; both are the firm's to write, and the products supply inputs to them."that the rules are a product feature, or that a vendor is missing them
5Each platform brings its own control plane, for its own agentsPart one, the question; part four, the estatevendor documentation (Microsoft Agent 365 and Entra Agent ID; Google Agent Gateway, Agent Identity, Agent Registry; AWS Bedrock AgentCore)September 2026sourced"Each platform governs its own agents. Nobody owns the identity across them unless the firm does."that any platform is insufficient for its own agents
6Rules-based sanctions screening produces mostly false positivesPayments casevendor statementsvendors cite around 99%check"Most hits are false positives; vendors cite figures near 99%. The case's own rates are assumptions."a precise industry rate
6aDocumented AI incidents rose from 233 in 2024 to 362 in 2025; the adoption of AI reached 88 percent of organisations surveyed in 2025The opening, capability and controlStanford HAI, AI Index 2026, 14 April 2026: the responsible AI chapter (incidents, from the AI Incident Database) and the economy chapter (adoption, from the McKinsey Global Survey on AI 2025: 1,993 respondents in 105 countries, fielded June to July 2025, published 5 November 2025)incidents as reported to one public database, so a count of what was documented, not of what happened; adoption as regular use in at least one business functionfirm"Documented incidents went from 233 to 362 in a year, up by more than half, while adoption reached 88 percent. The database counts what was reported."that incidents rose 55 percent in the world, or that 88 percent of firms run agents
6bOne firm in five among those planning agents within two years, 21 percent, has a mature governance model for themThe opening, capability and controlDeloitte, The State of AI in the Enterprise: The Untapped Edge, 21 January 2026; 3,235 business and IT leaders in 24 countries, director to C-suite, fielded August to September 2025; the 21 percent is of the respondents planning to deploy agentic AI within two yearsself-reported maturity, on agentic AI specifically, among the firms planning itfirm"Among the firms planning agents within two years, 21 percent said they had a mature governance model for them, in a survey of 3,235 leaders in 24 countries. In Deloitte's words, agents are scaling faster than their guardrails."that 21 percent of all firms have one, that four in five firms have no governance, or that the figure was measured
6cThe next agents carry a world model and plan an act by predicting its consequences ("like JEPA"); the map does not move for thatPart one, what the map does not draw yet; the research pageLeCun, A Path Towards Autonomous Machine Intelligence, OpenReview, 27 June 2022 (the position); Assran et al., I-JEPA, CVPR 2023, pp. 15619–15629; Bardes et al., V-JEPA, TMLR 2024; Assran et al., V-JEPA 2, arXiv 2506.09985, June 2025 (the line of work)a research direction, stated by its author and shown on images, video, and robot planning; no agent in a regulated decision runs on it todaysourced"The next generation of agents is being built to predict the consequences of its own acts, the world-model line of work, like JEPA. For the map that changes nothing: a predicted consequence is one more claim the check reads, with a standing."that LLM agents plan this way today, that JEPA is a product, or that a world model makes the check unnecessary
6dNIST's AI Risk Management Framework organises AI risk work in four functions: govern, map, measure, and manageThe reference model, the frameworksNIST AI 100-1, Artificial Intelligence Risk Management Framework (AI RMF 1.0), January 2023a voluntary framework; US, used internationallyfirm"NIST's framework is a risk workflow: govern, map, measure, manage."that it is binding, or that following it meets the AI Act
6eISO/IEC 42001 is a management system standard for AI: policy, roles, evidence, review, and improvement, certified and audited like other management systemsThe reference model, the frameworksISO/IEC 42001:2023, Information technology - Artificial intelligence - Management system, December 2023an international standard; certification is voluntaryfirm"ISO/IEC 42001 makes AI management a management system, audited like the others."that certification to it shows an agent is safe to act
6fIn networking, the control plane instructs devices how to process and forward traffic; the management plane monitors, configures, and maintains themThe reference model, the plane strictly; part one, the questionIETF RFC 7426, Software-Defined Networking (SDN): Layers and Architecture Terminology, January 2015, the terminology sectiona definition from networking, borrowed by analogyfirm (read 12.10.2026)"Networking defined the term first: the control plane instructs, the management plane monitors and configures."that a standard defines the AI control plane
6gThe autonomy levels A.0 to A.5 follow Kasirzadeh and Gabriel's agentic profilesThe reference model, the rule; part three, essential 6; the research pageKasirzadeh A., Gabriel I., Characterizing AI Agents for Alignment and Governance, arXiv 2504.21848, 30 April 2025; published in Nature in August 2026 according to the reference model outlinethe levels are theirs; the evidence levels and the rule are the Hub'ssourced (the preprint read 12.10.2026; check the Nature version before citing it)"The autonomy levels follow Kasirzadeh and Gabriel; the evidence levels and the rule between them are our proposal."that the authors endorse the rule or the evidence levels
6hKubernetes admission control intercepts a request after it is authenticated and authorised and before the object is stored, and can reject it on policyThe reference model, the plane strictlyKubernetes documentation, Admission Control in Kubernetes (kubernetes.io)the API server's admission phase, as documentedfirm"Kubernetes admission control can still refuse a request that is authenticated and authorised, on policy, before it is written."that every architect uses it, or that it governs AI agents

The cases and their figures

#ClaimWhereSourceConfidenceSay it like thisDo not say
7The use cases, their firms and the city, the claims, payments, conversations, and applications, and their figuresPart two, the dossier, the explorerinvented for illustrationours"These cases are invented. What a real workshop marks is the firm's own workflow."
7aThe city case's guidance versions, their content, and the allowance amountsPart two, the city caseinvented for illustrationours"The guidance and the amounts are invented. The point is that the law as read changes on a known date, and the check asks which version applies."
8Business case: 96,000 claims, 25 minutes saved, €60 an hour, 65% realised, €0.6m to run, €0.9m to set up, about €0.96m a yearPart two, the decision; part four, the valuethe motor case packours"Illustrative figures; the point is the chain, and what happens to it when less of the saving is realised."
9Thresholds: three referrals in seven days, restored after 20 clean proposals, a weekly evaluation samplePart two, the loop; the explorerthe case packsours"The numbers are illustrations of a rule written in advance. A firm sets its own."
9aCuration costs half to one person per domain once it runs, a domain being one product line's wordings, one list service, or one legal register; the first load is the pilot's own costChapter 05, how knowledge is preparedthe Hub's own estimate from the Governed Intelligence work, not measured in a deploymentours"An illustration, from our own reading: budget in that order per domain, after a first load the pilot measures. It is not a benchmark, and the run rate is not the backlog."that a bank with five hundred product lines needs five hundred people; the domain is the unit, and a firm counts its own
9bMost programmes we have seen stop at a library and a search index, buy capture and structure and call it done, have not staffed curation, and have not written the e2 charterChapter 05: the opening, the jobs that share one word, and how knowledge is preparedthe Hub's reading of its own client work and the programmes it has reviewed, 2025 to 2026; not surveyed, not countedours"In the programmes we have seen, the knowledge work stops at retrieval; we have not counted it.""most firms" as a market statistic; any percentage
9cMost pilots we have seen keep K0 evidence, logs without attribution; most firms we have seen can show K1, which licenses A.1 and A.2The opening, the ladder; part three, essential 6; the reference model, the levels and the rulethe Hub's reading of its own client work and the programmes it has reviewed, 2025 to 2026; not surveyed, not countedours"In the programmes we have seen, pilots log without attribution, and the firms that have gone further can show every act recorded and attributed."a share of the market, or "most firms" as a statistic

Law and supervision

#ClaimWhereSourceConfidenceSay it like thisDo not say
10SR 26-2 replaced SR 11-7 and puts generative and agentic AI out of its scopeReference model, supervisory annex; the reference model page, slide 1SR 26-2, Federal Reserve, OCC, and FDIC, 17.04.2026; summaries by CIMCON, Management Solutions, Moody'ssourced: quote the footnote from the primary text"The US model risk guidance of April 2026 leaves agentic AI out of its scope and tells banks to govern it with their own risk management."that it exempts agents from control, or that it applies in the EU
11Motor claims are not high-risk under the AI Act; a collections conversation is arguablePart four, the law; the motor caseRegulation (EU) 2024/1689, Annex III point 5: (b) creditworthiness of natural persons, (c) risk assessment and pricing for natural persons in life and health insurancefirm"Annex III lists credit scoring of individuals and life and health pricing; motor claims are not on it. A collections agent that weighs affordability is arguable, so the bank records its reasoning."that the AI Act does not matter to insurers
11aThe AI Act's duties depend on the use and on the firm's role, provider or deployerThe reference model, the frameworksRegulation (EU) 2024/1689, Article 3(3) and (4) (the definitions), Article 16 (providers of high-risk systems), Article 26 (deployers), Article 6 and Annex III (the high-risk uses)firm"The Act sets duties by the use and by the firm's role: a provider's duties differ from a deployer's."that a firm is only ever one of the two, or that every agent is high-risk
12Article 22 GDPR applies to a decision based solely on automated processing with a legal or similarly significant effectPart four, the law; the dossierRegulation (EU) 2016/679, Article 22; CJEU C-634/21 SCHUFA (07.12.2023)firm"Whether a settlement falls under Article 22 is a test the firm applies, decision type by decision type."that every agent decision is covered, or none is
13For an automated decision within Article 22, the explanation must describe the procedure and principles actually appliedPart four, the law; part three, the recordCJEU C-203/22 Dun & Bradstreet Austria, 27.02.2025, on Article 15(1)(h)firm"Where a decision falls under Article 22, the court asks for the procedure and principles actually applied, in a form the person can understand. A decision record keyed to its versions can produce that."that every decision must be explained this way, or that the firm must disclose its model
14For instant euro payments, EU-list sanctions screening moves to the bank's own customers, checked daily and after every new measurePayments case notes and lensRegulation (EU) 2024/886, Article 5dsourced"For instant euro payments, banks check their customers daily instead of screening each payment; our case is a payment to a bank outside the EU, screened as it leaves."that the rule covers payments to banks outside the EU
15EBA guidelines ask for trained analysts and two people for higher exposurePayments caseEBA/GL/2024/15, paragraphs 32(d) and 33sourced"The guidelines want alerts analysed by trained staff, and two people above an exposure. Automated clearance in approved categories is the bank's own reading, written into its screening policy."that the guidelines permit automated clearance
16The Consumer Credit Directive II gives consumers a right to human intervention, an explanation, and a review, and asks for reasonable forbearance before enforcement, for agreements concluded from 20 November 2026; earlier agreements stay under Directive 2008/48, which since 30 December 2023 carries a forbearance duty of its own (Article 16a, inserted by Directive 2021/2167)Part four, the law; credit and collections casesDirective (EU) 2023/2225, Articles 18, 35, and 47; Directive 2008/48/EC, Article 16asourced (Article 16a checked by a second reader, 10.10.2026)"For credit agreements concluded from 20 November 2026, a consumer can ask for a person, an explanation, and a review, and lenders show forbearance before enforcement. Older agreements already carry a forbearance duty under the 2008 directive."that it applies to lending to companies, or that older loans carry no forbearance duty
17EIOPA's opinion on AI governance and risk management sets expectations for insurers using AI outside the AI Act's high-risk list; it is addressed to national supervisors and binds no one on its ownPart four, the lawEIOPA, Opinion on artificial intelligence governance and risk management, 6 August 2025sourced (date and addressees checked by a second reader, 10.10.2026)"EIOPA's opinion of August 2025 expects proportionate governance, data quality, oversight, and explanations from insurers using AI, in a risk-based way."that it is binding, or that it covers high-risk systems, which the AI Act does
18AI literacy: providers and deployers take measures to support the AI literacy of their staff, without having to guarantee any level for any individualPart four, the lawAI Act, Article 4(1) as reworded by Regulation (EU) 2026/1744 (the omnibus)sourced (the reworded text read on EUR-Lex by a second reader, 10.10.2026; quote it before publishing)"The AI Act asks firms to support the AI literacy of the people who use it; since the 2026 omnibus the duty stays, and no particular level has to be guaranteed."that the Act requires a training programme, or that the omnibus removed the duty
19A German works council co-determines technical systems able to monitor employee performancePart four, the peopleBetriebsverfassungsgesetz §87(1) no. 6firm"In Germany the works council has a say before a system that can monitor performance is introduced; the decision record names handlers."that the works council can veto the agent itself
20The FSB declined continuous human monitoring (10.06.2026) and Breeden said the same (30.06.2026)Reference model outline, A.4cited in the reference model outline v02checkdo not quote until checked against the primary texts
20aAI systems intended to be used by or on behalf of public authorities to evaluate the eligibility of natural persons for essential public assistance benefits, or to grant, reduce, revoke, or reclaim them, are high-risk unless Article 6(3) takes them out; after the 2026 omnibus these obligations apply from 2 December 2027 to systems put into service from then; a system already in service follows on its next significant change in design, and one used by a public authority by 2 August 2030 at the latestPart two, the city case; part four, the lawRegulation (EU) 2024/1689, Annex III point 5(a), Article 111(2); Regulation (EU) 2026/1744 of 8 July 2026 (the AI omnibus), published in the Official Journal on 24.07.2026, in force 27.07.2026firm for the list; sourced for the dates (quote the Official Journal before publishing)"An AI system a public authority uses to decide an essential benefit is high-risk under the AI Act. After this year's omnibus, those obligations apply from 2 December 2027 to new systems; one already running follows on its next significant change, and by August 2030 at the latest."that the obligations apply today, that the omnibus removed them, or that a system already in service escapes them
20bA public body deploying such a system has duties that include human oversight by trained people, logs kept for at least six months, telling the people it decides about, a fundamental-rights impact assessment before first use, and registering its use in the EU databaseThe city case notes and its regulation lensAI Act Articles 26, 27, and 49check: confirm against the text as amended by the omnibus"A city that deploys it assigns trained people to oversee it, keeps the logs, tells residents, assesses the impact on their rights before it starts, and registers the use."article numbers or periods after the omnibus without checking
20cIn Germany, a benefit decision may be issued fully automatically where there is no reason for an official to handle the case, taking into account facts from the applicant the procedure cannot evaluate; in general administrative law only where a statute permits it and there is no discretion or margin of appreciationThe city case, its regulation lens and notes§ 31a SGB X; § 35a VwVfGfirm"Whether a machine may decide at all is national law. Germany allows it for benefits where no official needs to look at the case, and elsewhere only where a statute allows it and leaves no discretion."that the rule is EU-wide, or that German law forbids automated benefit decisions
20dAustralia's Robodebt scheme raised welfare debts by averaging annual income over fortnights, was found unlawful, and was the subject of a Royal Commission that reported in July 2023The city case notesRoyal Commission into the Robodebt Scheme, report, July 2023sourced"Automated reclaims at scale are where benefit systems have done the most harm; Robodebt is the case everyone in the public sector knows."figures for the debts or the settlement without checking
20eA German benefit notice states the essential factual and legal reasons; where the Land keeps the objection procedure, an objection within one month is decided by the objection authority, and the administrative court is open after it or directly where the Land has abolished the objection; housing allowance disputes go to the administrative courtsPart four, the law, the city case§ 35 SGB X; §§ 68 to 70 VwGO; § 40 VwGO and the absence of housing allowance from § 51 SGG; Land laws abolishing the objection in some matterssourced (second reader, 10.10.2026; a public-law reader should confirm before external use)"The notice gives its reasons, and the household can object within a month, or go to the administrative court; a person decides the objection, never the machine."that the objection is decided by the same caseworker, or that the procedure exists in every Land
20fUnder Article 22(2)(b) GDPR a decision authorised by Member State law escapes the ban on solely automated decisions only where that law itself lays down suitable safeguards; the safeguards of Article 22(3) attach to (2)(a) and (c)Part four, the law, the city caseRegulation (EU) 2016/679, Article 22(2)(b) and (3), recital 71firm"For a benefit decision authorised by national law, the safeguards come from that law: here the duty to weigh what the applicant states, the reasons in the notice, and the objection."that Article 22(3)'s trio applies by itself to a decision under (2)(b)
20gArticle 50 of the AI Act applies since 2 August 2026 to an AI system that interacts directly with natural persons; the 2026 omnibus did not postpone itPart four, the law, every case where the agent answers the customerRegulation (EU) 2024/1689, Article 50(1) and Article 113; Regulation (EU) 2026/1744sourced (second reader, 10.10.2026)"Where the agent answers the customer itself, it says it is an AI system; that duty is in force since August 2026."that the omnibus delayed Article 50, or that a corporate client's staff are not natural persons
20hThe AML Regulation applies from 10 July 2027; until then the AML duty is Directive 2015/849 as transposed; the Regulation brings the check of customers against targeted financial sanctions into customer due diligencePart four, the law, the payment caseRegulation (EU) 2024/1624, Articles 3 and 20(1)(d), and its date of application; Directive (EU) 2015/849sourced (second reader, 10.10.2026)"Today the bank's AML duty is the directive as transposed; from July 2027 the regulation applies, and checking customers against the sanctions lists becomes part of due diligence."that the AML Regulation applies today
20iThe EBA guidelines on restrictive measures address institutions the EBA supervises and payment and crypto-asset service providers, not insurers; the sanctions regulations themselves bind every firm that holds or moves fundsPart four, the law, the motor caseEBA/GL/2024/14 and EBA/GL/2024/15, applying from 30 December 2025; Council regulations on restrictive measuressourced (second reader, 10.10.2026)"The EBA guidelines are written for banks and payment firms. An insurer is bound by the sanctions regulations themselves, so claim payees are screened."that an insurer is outside sanctions law
20jDORA reaches identity management and access control, p3, through its technical standard on the ICT risk management frameworkPart four, the law; the explorer's DORA lensRegulation (EU) 2022/2554; Commission Delegated Regulation (EU) 2024/1774, the RTS on the ICT risk management framework, its articles on identity management and access controlcheck (raised by the third panel's CISO, 11.10.2026; verify the article numbers before quoting)"DORA's risk management standard covers who may access what, so agent identity and access sit under it as well as incidents, testing, and third parties."the article numbers until read

Statements about the set itself

#ClaimSay it like this
21What the map is"A proposal for discussion from the Hub's research. It is not a product, and it certifies nothing."
22What the control plane is"It instructs, and can say no before the act. Platforms already instruct: identity, routing, guardrails, access. The part that refuses is the mandate and the check, joined to the record and the loop. The map is everything the plane needs to be right."
23The reference model and its levels"Autonomy levels A.0 to A.5 and evidence levels K0 to K3 are a proposal under review, with a first version planned for the fourth quarter of 2026."
24Who wrote it"Hub research by Witold Reichhart."