In EAB, every governance stage has an approval gate. Every gate requires a named supervisor. Every decision — including bypasses — is logged with identity, timestamp, and justification.
This is not an access control layer. It is the mechanism by which accountability is made structural — before any AI system reaches the obligation management stage.
“An approval without a named author is not an approval. It is a gap in the record — and gaps are exactly what auditors look for.”
EAB separates what different roles can do by design. A business operator can register a system. An AI system owner can complete the technical profile. But no single actor can move a system through the full governance chain alone. The supervisor approval gate enforces this separation at every critical transition.
When a supervisor approves a screening result, their identity is anchored to that record — not as a metadata field that could be edited, but as a sealed part of the immutable record. If a supervisor bypasses a screening gate or overrides an Art. 5 concern, the bypass is logged with their identity, the timestamp, and the justification they provided. There is no silent override.
The bypass log is visible to auditors in the read-only workspace. Every non-standard decision is reconstructable — who made it, when, and why. An auditor does not need to interview anyone to determine whether the approval chain was followed.
Supervisors are the accountability anchor in EAB — every critical decision flows through their approval.
Only a supervisor can initiate a screening session. On completion, the supervisor reviews the result and approves or rejects it. Approval seals the screening record — it cannot be modified after this point.
The Art. 5 review is conducted by the supervisor as the first stage of every screening. Each of the seven categories must be explicitly stated. A confirmed prohibition blocks further progression — an override is possible but permanently logged.
When a supervisor bypasses a gate, overrides a prohibition concern, or approves under exceptional conditions, the action is logged with their identity, the exact timestamp, and the justification they provided. This log is immutable and visible to auditors independently.
Operators register. Owners complete technical profiles. Supervisors screen and approve. No role can perform another role's gate action. The separation is enforced at the system level — not by policy documents.
As obligation areas are completed and evidence attached, the supervisor reviews and approves completion. A partially evidenced obligation cannot be approved — the gate requires explicit per-obligation sign-off.
The complete approval chain — every gate, every bypass, every identity — is visible in the auditor's read-only workspace without any preparation from the compliance team. The record reconstructs itself.
When approval is enforced by the system — not by a process document — it cannot be skipped, forgotten, or reconstructed after the fact.
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