Requirements Catalogue

This is the normative backbone of the architecture: the numbered, testable control requirements that the pillars implement, the templates capture evidence for, and the crosswalks map to external standards. Where the earlier documents explain what control means and why, this document states what is required.


How to read a requirement

Every requirement has a stable ID and a normative statement:

ACA-<pillar>-<n> e.g. ACA-09-02
  • ID: ACA + two-digit pillar (07–16) + sequence. IDs are stable; requirements are never renumbered, only deprecated.
  • Statement: written with SHALL (required), SHOULD (expected unless justified), MAY (permitted), in the RFC 2119 sense.
  • From tier: the lowest risk tier at which the requirement applies (see below). It also applies to every higher tier.
  • Boundary: the minimum boundary source expected: Declared, Evidenced, Verified, Enforced.
  • Crosswalk: the external provisions it helps satisfy (see mappings/).

Each pillar document (07–16) is the authoritative source for its own requirements and their guidance; this catalogue is the consolidated, citable index.


Risk tiers

Requirements are graduated by tier. Tier is set in pillar 07 from a use case's consequence (See/Decide/Do) and autonomy.

T1 Low-risk productivity or public-data use     public or non-sensitive data, no decision impact, no tool or action capability
T2 Internal productivity with enterprise data   internal enterprise data or vendor AI for productivity, no decision influence or actions
   or vendor AI
T3 Decision-supporting AI                        influences human decisions, judgments, or records
T4 Action-capable AI                             can call tools, trigger workflows, or perform actions in enterprise systems
T5 High-impact autonomous or regulated AI        affects employment, credit, legal, safety, healthcare, regulated, or hard-to-reverse outcomes

Tier is set from the highest material risk driver, not an average. A requirement marked From T3 applies to T3, T4, and T5, not T1 or T2.


Tiers and pillars: depth, not on/off

Tiers do not map one-to-one to pillars. All ten pillars remain relevant at every tier; what rises with the tier is the depth of control each pillar requires. The rule is simply: control depth scales with the risk tier, and the highest material risk driver sets the tier.

A pillar does not "switch on" at a threshold. Containment, for example, applies even at Tier 2, where it may mean disabling a vendor feature; at Tier 4 it means revoking an agent identity, cancelling pending actions, and rolling back changes. Same pillar, very different depth.

Which pillars become decision-critical at each tier:

Tier Pillars that dominate What changes
T1 07 Inventory, 09 Data, 11 Output, 13 Accountability Keep the use case visible, restrict it to low-risk or public data, and keep a human owner over the final output.
T2 T1 + 08 Identity, 09 Data, 15 Monitoring & Evidence Enterprise or vendor data enters, so access, retention and reuse, vendor configuration, and evidence matter more.
T3 T2 + 11 Output & Decision, 13 Accountability, 14 Assurance, 15 Evidence AI now influences judgment: meaningful human review, decision ownership, validation, escalation, and proof of what informed the recommendation.
T4 T3 + 08 Identity, 12 Tool & Action, 15 Evidence, 16 Containment AI can act: delegated authority, tool restrictions, approval gates, action logs, rollback, and a tested kill switch.
T5 All ten, at enhanced depth High-impact, regulated, autonomous, or hard-to-reverse: full review, stronger assurance, evidence, accountability, and risk acceptance.

Read as a progression: Tiers 1–2 control what AI can See (inventory, identity, data, inputs); Tier 3 controls what it can Decide or influence (output, accountability, assurance, evidence); Tier 4 controls what it can Do (identity, action authority, logging, rollback, containment); Tier 5 proves the whole chain — from access through decision and action to evidence and recovery — can be defended and reconstructed.

So the From tier on each requirement below marks where that specific control becomes a distinct, required provision, not where its pillar begins to matter. Lower tiers still exercise the same pillars at lighter depth, and a "-" in a pillar's tier-guidance table means "no distinct required control at this tier," not "pillar absent."


The catalogue

Representative requirements per pillar. This set is normative and versioned; it grows as the pillar documents are completed, and full guidance for each lives in its pillar.

07, AI Inventory & Classification

ID Requirement From Boundary
ACA-07-01 The organization SHALL maintain an inventory of all AI use cases, including embedded and vendor AI. T1 Evidenced
ACA-07-02 Each use case SHALL have a named accountable owner recorded at intake. T1 Declared
ACA-07-03 Each use case SHALL be assigned a risk tier before controls are selected. T1 Evidenced
ACA-07-04 The inventory SHALL be reconciled on a defined cadence and on material change. T2 Evidenced

08, AI Identity & Access Control

ID Requirement From Boundary
ACA-08-01 AI SHALL act under a distinct non-human identity, not a user's standing credentials. T4 Verified
ACA-08-02 AI identities SHALL be granted least-privilege access scoped to the use case. T4 Verified
ACA-08-03 AI access SHALL be revocable promptly and completely. T4 Verified
ACA-08-04 Consequential actions SHALL be attributable to the identity and grant that authorized them. T4 Enforced

09, Data Boundary Control

ID Requirement From Boundary
ACA-09-01 The data sources an AI may access SHALL be explicitly defined and approved. T2 Evidenced
ACA-09-02 Retrieval SHALL be scoped so AI cannot surface data the requester is not entitled to. T2 Verified
ACA-09-03 Sensitive data classes SHALL be excluded or masked unless explicitly permitted. T2 Verified
ACA-09-04 Third-party processing and retention of data SHALL be known and bounded. T2 Evidenced

10, Prompt & Input Control

ID Requirement From Boundary
ACA-10-01 Untrusted input, including retrieved content, SHALL be treated as potentially adversarial. T3 Evidenced
ACA-10-02 Prompt-injection and manipulation SHALL be mitigated proportionate to tier. T3 Verified
ACA-10-03 System instructions SHALL be protected from override by user or retrieved content. T4 Enforced

11, Output & Decision Control

ID Requirement From Boundary
ACA-11-01 Output that influences a consequential decision SHALL be identified as such. T3 Evidenced
ACA-11-02 High-impact decisions SHALL require human validation before effect. T3 Enforced
ACA-11-03 AI-influenced decisions SHALL be recorded with the output and rationale. T3 Evidenced

12, Tool & Action Control

ID Requirement From Boundary
ACA-12-01 The tools and actions an AI may invoke SHALL be explicitly allow-listed. T4 Verified
ACA-12-02 High-impact actions SHALL require approval or step-up before execution. T4 Enforced
ACA-12-03 No action class SHALL be enforced live without a defined containment or compensation path. T4 Enforced
ACA-12-04 Every action SHALL be logged with the requesting identity, inputs, and outcome. T4 Verified

13, Human Accountability Model

ID Requirement From Boundary
ACA-13-01 A named human SHALL own each consequential outcome, decision, approval, and exception. T1 Declared
ACA-13-02 Risk acceptance for a use case SHALL be recorded and attributable. T3 Evidenced
ACA-13-03 Recovery ownership SHALL be assigned before go-live for action-capable use cases. T4 Declared

14, AI Assurance & Testing

ID Requirement From Boundary
ACA-14-01 Controls SHALL be tested before go-live, proportionate to tier. T3 Verified
ACA-14-02 High-impact and autonomous use cases SHALL undergo adversarial testing of input, output, and action controls. T5 Verified
ACA-14-03 Test results SHALL be retained as evidence and re-run on material change. T3 Verified

15, Monitoring, Logging & Evidence

ID Requirement From Boundary
ACA-15-01 Activity SHALL be logged sufficiently to reconstruct what AI saw, produced, decided, and did. T2 Verified
ACA-15-02 Logs SHALL be tamper-evident and retained per policy. T3 Verified
ACA-15-03 Anomalous or policy-violating behavior SHALL be detectable and alertable. T4 Verified

16, Incident Containment & Recovery

ID Requirement From Boundary
ACA-16-01 Each tiered use case SHALL have a tested means to disable the AI capability quickly. T4 Enforced
ACA-16-02 High-impact actions SHALL have a containment or compensation/rollback path. T4 Enforced
ACA-16-03 Recovery from an AI incident SHALL be owned, documented, and exercised. T4 Evidenced

Using the catalogue

  • Assessing a use case: tier it (07), then apply the requirements at or below that tier, recording the boundary source achieved for each.
  • Proving control: each requirement's boundary column is the bar; a requirement met only at Declared when Verified is expected is a finding.
  • Mapping obligations: the crosswalks tie these IDs to NIST AI RMF, ISO/IEC 42001, EU AI Act, SR 11-7, NYDFS, and OWASP, so one pass serves many.

Machine-readable form

This catalogue is also published as data, generated from this document, in controls/:

controls/aca-requirements.yaml
controls/aca-requirements.json

Assessment tooling, agents, and GRC systems can consume that single source rather than re-transcribing the requirements. This document remains authoritative; the data files are built from it and checked against every pillar's table. A future version is expected to add an OSCAL profile.


Next: 07 · AI Inventory & Classification

Version 0.1.0 · Licensed under the terms in LICENSE.md.