FWD-2 The record of an AI decision

Fijishi Working Draft 2 - 14 October 2026

Stage 1 of 4: working draft. Not yet open for public comment, not a numbered version, and not the criteria Fijishi certifies against. This draft replaces, as a new version, the earlier paper "AI Auditability & Compliance Framework (AAC)" (2023-2026); the earlier text is available on request. Standards in development

The question

For any single AI decision, can the firm produce a record of what went in, what came out, which model version produced it, and what a person did with it?

Why it matters to firms

Every other question about an AI decision – was it lawful, who was accountable, could it be explained, could it be stopped – is answered from its record. Without one, the firm can describe its process but cannot show what happened in a particular case. Claims and complaints can arrive years after the decision.

Principles

  1. Complete – the record covers inputs, output, model version, settings and human action.
  2. Intact – changes to the record leave a trace.
  3. Kept long enough – for as long as the applicable rules and the firm's exposure to claims require.
  4. Held by the firm – or obtainable by it, including after a vendor relationship ends.
  5. Retrievable – the record of one decision can be found within a time the firm sets.

What a firm should be able to show (draft criteria)

  • FWD-2.1 For each decision: a reference to the input data used, the output, the model and version, the time, and the thresholds or settings in force.
  • FWD-2.2 Any human action on the decision – review, override, confirmation – with who and when.
  • FWD-2.3 A retention period for each decision type, set against the applicable rules and the period in which claims or complaints can arise.
  • FWD-2.4 Controls under which records cannot be altered or deleted without trace.
  • FWD-2.5 Retrieval of the record of one named decision within a time the firm sets, shown on a sample.
  • FWD-2.6 Where a vendor holds the records, a contractual right to obtain them, during the contract and on exit.
  • FWD-2.7 A dated log of model and settings changes, so each decision can be linked to the version that made it.
  • FWD-2.8 Regular checks, on a sample, that records are complete.

How it relates to existing rules and standards

  • It is meant to operate inside an AI management system such as one certified to ISO/IEC 42001, whose documented-information requirements it makes specific to single decisions.
  • The EU AI Act requires high-risk AI systems to allow the automatic recording of events. For the insurance systems the Index covers, that obligation applies from 2 December 2027; where it applies, it governs.
  • Retention must also respect data protection law, which limits how long personal data may be kept.

Where it is used now

It informs the Constitutional Baseline Review, and is the base record for the other drafts (FWD-7).

What happens next

Public comment follows FWD-1. Comments are welcome now: protocol@fijishi.com