Pillar 15: Monitoring, Logging & Evidence

Control question: Can we see, and later reconstruct, what the AI did? Surface: observes See, Decide, and Do.


Purpose

This pillar makes AI behavior observable and reconstructable. It requires that activity be logged sufficiently to reconstruct what an AI saw, produced, decided, and did; that those logs be tamper-evident and retained; and that anomalous or policy-violating behavior be detectable and alertable. Assurance (14) proves controls hold before go-live; monitoring proves what actually happened after.


Why it matters

When an AI use case fails, a boundary breach, a bad decision, an unauthorized action, the first questions are always the same: what did it see, what did it do, when, and on whose authority? If the logs cannot answer, you have an incident you cannot scope, a breach you cannot bound, and an audit you cannot pass. Worse, without monitoring you do not know a failure happened at all until its consequences surface elsewhere. Evidence is also what turns the rest of the architecture from assertion into proof: the boundary sources, the decisions, the actions, all of it depends on a durable, trustworthy record.


Control objectives

  • Log activity sufficiently to reconstruct what AI saw, produced, decided, and did.
  • Keep logs tamper-evident and retained per policy.
  • Make anomalous or policy-violating behavior detectable and alertable.

Requirements

From the Requirements Catalogue:

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

Key controls

  • Reconstruction-grade logging: capture the See/Decide/Do trail: inputs and retrieved context (or references to them), outputs, decisions and their human validation, and every action with its identity, inputs, and outcome. Enough to answer "what happened" without guesswork.
  • Integrity & retention: logs are tamper-evident and retained to policy, so they hold up as evidence and cannot be quietly altered.
  • Detection & alerting: surface anomalies and policy violations (boundary-escape attempts, unauthorized action attempts, injection signatures, unusual volume or scope) to the people and systems that can respond.
  • Feed the response path: monitoring is the trigger for containment; interdictions and hostile-flagged behavior should reach the SOC/response function.
  • Privacy-aware: log what is needed for reconstruction and control, minimizing sensitive content; reference rather than duplicate regulated data where possible.

The metrics and reporting how-to lives in the operating guide (Metrics & Reporting); this pillar defines the monitoring and evidence that are required.


Tier guidance

  T1 T2 T3 T4 T5
Reconstruction-grade logging Basic Required (verified) Required (verified) Required (verified) Required (verified)
Tamper-evidence & retention - Recommended Required Required Required
Anomaly detection & alerting - - Recommended Required Required
Response-path integration - - Recommended Required Required

Evidence

The AI Monitoring, Logging & Evidence template captures the logging design, integrity/retention, and detection. This pillar produces the durable record that every other pillar's evidence ultimately rests on, and that an assurance or audit pass consumes.


Standards crosswalk

Maps to NIST AI RMF Measure/Manage, ISO/IEC 42001 (logging, monitoring, operational control), EU AI Act (automatic logging and record-keeping, Art. 12; post-market monitoring), NYDFS Part 500 (audit trails, monitoring), and SR 11-7 (ongoing monitoring). See mappings/.


Failure modes

  • Logs that cannot reconstruct what the AI saw or did.
  • Records that can be altered, or that were not retained long enough to matter.
  • A failure that ran undetected because nothing was watching.
  • Monitoring that fires but reaches no one who can act.

Next: 16 · Incident Containment & Recovery

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