ADR-025: System card authority basis

Status: Accepted (2026-04-20)

Source: migrated from planning/swms-decisions.md ADR-035 as part of SPEC-270.

Context

The system card is a formal audit artifact. Its credibility depends on where its authority comes from. Two possible authority bases were considered: regulatory recognition of the reporting format, and the quality and provenance of the world model that the card’s claims are anchored against. The first path makes authority contingent on external bodies and a reporting format they bless. The second path makes authority contingent on the world model itself and on the ability of an external party to check the claims against it.

A third concern — the vendor-generated audit conflict of interest, where the system generating the card is the same system being evaluated — also needed resolution. The design interview resolved all three.

Decision

System card authority derives from the quality and provenance of the world model and from the traceability of the card’s claims back to a specific world model version, not from regulatory recognition of the reporting format. Methodology disclosure is mandatory. Structural independence, not organizational independence, resolves the vendor-audit conflict concern.

Authority basis

• The path to authority is methodology transparency, expert provenance at the rule level, the track record of world model evolution, and the joint-development relationship with domain expertise.
• Authority is built and demonstrated over time through the checkability of claims, not granted by external bodies.
• Regulatory recognition is not a design goal. If it arrives, it arrives as a consequence of demonstrated authority, not as its source.

Methodology disclosure

• Every system card must disclose the world model version it was assessed against, the provenance composition of the rules assessed (tier distribution), and the eval generation methodology used.
• This turns the authority claim into a checkable claim rather than an asserted one.
• Disclosure is at the card level, not a separate supplementary document.

Structural independence (vendor-audit conflict resolution)

• The world model is developed from authoritative and curated sources, governed by the provenance tier system, and evolved through a human-gated loop.
• Independence is structural, not organizational. The world model’s authority is not that a separate company produces it; the authority is that the model’s claims are traceable to independently-established sources and governed by a gated evolution process that no optimization signal can directly influence.

Consequences

• System card generation must emit the methodology disclosure fields as part of the base artifact, not as an optional add-on.
• The authority claim is checkable: a reader can inspect the world model at the disclosed version, inspect the provenance composition, and inspect the eval generation methodology, and either corroborate or challenge the card’s claims.
• Regulatory recognition is welcomed if it comes but is not a dependency of the design.
• The structural-independence framing means the system card remains coherent even when produced by the same organization that operates the system. The independence is in the governance structure and provenance chain, not in the org chart.
• The earlier SWMS decisions that the system card is an externally-generated audit artifact, and the SystemCard protocol (ADR-015), are preserved. This ADR specifies the basis of the authority those decisions reference.