ClearState

The common requirement across these frameworks is evidentiary: when a decision is questioned — by a regulator, auditor, or in litigation — the organization must show who decided, on what basis, under which rules, at which moment.

ClearState produces that evidence at the moment of the operational decision. The record is retrievable for the full retention period. The answer to "who authorized this, and why" is one query.

  • OutcomeALLOWED or NOT ALLOWED — binary, no score
  • AuthorityNamed role or individual whose mandate authorized the decision
  • RulebookVersioned rulebook active at decision time — locked at that moment
  • Blocking ruleWhen NOT ALLOWED: the rule that authorized or blocked, and what must change
  • TimestampExact moment of authorization — not the time of execution
Frameworks

Seven frameworks. One requirement in common.

Across these frameworks, the requirement is consistent: when a decision is questioned later, the organization must show who decided, on what basis, under which rules, at what moment. The frameworks differ in scope and sector. The evidentiary requirement does not.

AI governance

EU AI Act — Article 14 (Human Oversight)

For high-risk AI systems, the AI Act requires that a natural person can effectively oversee the system, intervene in its operation, and understand its output. ClearState is the layer where that oversight is exercised: a named human authority is bound to each decision, with the rule and rulebook version on record.

Source: EU AI Act — Regulation (EU) 2024/1689, Article 14

Asset management

AIFMD II — Decision records and mandate evidence

Alternative Investment Fund Managers must demonstrate, per trade, that the decision was authorized against the fund's mandate, investor restrictions, and applicable rules. ClearState produces that evidence at the moment of trade authorization, naming the conducting officer and the rulebook version active then.

Source: AIFMD II — Directive (EU) 2024/927

Financial services

MiFID II — Suitability and Categorization

Investment firms must document suitability assessments and client categorization decisions in a way that is reviewable years later. ClearState produces that record at the moment of the decision — not reconstructed from notes or system exports after the fact.

Source: MiFID II — Directive 2014/65/EU, Articles 25 and 30

Sanctions compliance

OFAC and EU Sanctions — Enforcement at record levels

Sanctions enforcement actions and fines have reached unprecedented levels over the past three years. When a sanctions screening is overridden, the override must be defensible. ClearState produces the override record with the named authority and the rule that authorized or blocked the decision.

Sources: OFAC enforcement actions · EU sanctions framework

Digital operational resilience

DORA — ICT risk and critical decision functions

The Digital Operational Resilience Act requires financial entities to demonstrate ICT risk controls and oversight on third-party providers performing critical decision functions. ClearState's authorization layer is itself on record — every decision the system authorizes can be retrieved and independently verified.

Source: DORA — Regulation (EU) 2022/2554

Data protection

GDPR — Article 22 (Automated decision-making)

Where decisions affecting individuals are made by automated means, the data subject has the right to human intervention and to contest the decision. ClearState is structured around named human authority — automation supports the authority, but the authority decides. The record proves it.

Source: GDPR — Regulation (EU) 2016/679, Article 22

Insurance

NAIC and EIOPA — Insurance and surety underwriting

US state insurance regulators (NAIC) and EIOPA increasingly require AI governance with named accountability for underwriting decisions. ClearState produces the underwriting record with the named underwriter, the rulebook version, and the rule that authorized or blocked the decision.

Sources: NAIC AI guidance · EIOPA AI governance principles

Independently observed

The same gap, named by the Big Four.

The 2025–2026 reports from Deloitte, KPMG, EY, and McKinsey identify the same pattern: organizations have governance policy, but lack per-decision authorization at the moment of execution. The frameworks above describe what is required. The reports below describe what is missing.

Additional references

Further reading for compliance and legal teams.

Internally

When you need to explain this to the business.

Most compliance, legal, and risk teams already know these frameworks. The question they get from operations is: what, concretely, do we do about it?

ClearState is a concrete answer. ClearState evaluates real operational decisions against your rulebook — producing the record at the moment of the decision. From there, the conversation with regulators and auditors shifts — from "we have a policy" to "we have a record."

The record ClearState produces is not a policy document or a system log. It is a structured authorization record created at the moment of the operational decision — with the named authority, the versioned rulebook, and the outcome.

It is the evidence the frameworks require. Produced at the moment it is needed.