Obligations, point by point.

Last updated 1 November 2026.

Invarians provides audit inputs, not compliance. Whether an obligation is met is determined by your compliance function, on your facts; accountability is not outsourceable. What follows is the mapping: what each text asks, what changes when the actor is an AI agent, and the input a route record provides.

Obligation What changes with an agent The input Invarians provides In your files
MiCA record-keeping RTS (CDR (EU) 2025/1140), art. 7(1): records kept immediately after the transaction The actor is software; there is no human contemporaneous witness Route-state records timestamped at observation; third-party verifiable signatures arrive with the next version Audit trail
MiCA record-keeping RTS, art. 2(1): reconstitution of each key stage, corrections ascertainable Agent decisions interleave with market state at machine speed Signed, timestamped context series; integrity between the parties today Records reconstitution
DORA, art. 10(1): detection of anomalous activities and potential material single points of failure Route anomalies can stay invisible on status pages; the September 3rd case is the documented example Per-route envelopes and dated deviations Anomaly detection
DORA, art. 11(8): records before and during disruption when continuity plans activate Reconstruction after the fact is forensics, not testimony Continuous archive, no missing day on the ten CCTP corridors measured Records before and during
DORA, art. 17(2): all ICT incidents recorded Agent-induced slowdowns must be evidenced or they do not exist Deviation census against each route's measured baseline Incident records
AI Act, art. 26(6): deployer keeps system logs at least six months, for high-risk systems; whether a settlement agent is classified high-risk is for your legal analysis Internal logs are produced by the agent's own operator An independent source of operational evidence alongside those logs Independent evidence
FSB sound practices on AI agents (Oct 2026; non-binding guidance, paraphrased): oversight scaled to autonomy, human-approval thresholds Thresholds need a neutral input or they reference the agent's own view Signed context consumable by your own policy, before the agent acts Guardrails input
SR 26-2 (Federal Reserve, Apr 2026, superseding SR 11-7): ongoing model monitoring and effective challenge The agent's view of the world needs external challenge data Route-state series usable as model monitoring MI Ongoing monitoring MI

Everything above describes the service as it runs. The one exception is stated where it occurs: third-party verifiable signatures belong to the next version, built with our first design partner.