Obligations mapped to controls — 7 frameworks, 40 requirements
EU AI Act, SR 26-2, RBI MRM Guidance, NIST AI RMF, DPDP Act 2023, SEBI, and ISO 42001 — each obligation linked to the Zytra module that addresses it and the evidence output it generates.
Framework
Obligation
Article / §
Applies to
Status
Zytra Module
Evidence Output
EU AI Act — High-Risk Systems (Art. 9–15) · Applies to high-risk AI providers & deployers under Annex III · Mandatory from 2 Dec 2027 (Annex III) / 2 Aug 2028 (Annex I product-related)
EU AI Act
Risk management system — continuous, iterative process throughout AI system lifecycle
Art. 9
High-risk AI providers & deployers (Annex III)
Production-ready
Risk Atlas · Assessment Engine
Risk tiering report · Control effectiveness scores
Regulatory status
Mandatory — Annex III high-risk systems from 2 Dec 2027; Annex I product-related high-risk from 2 Aug 2028
Effective date
2 Dec 2027 (Annex III) / 2 Aug 2028 (Annex I product-related)
Discovery crawls model registry and agent mesh to generate AI Bill of Materials (AIBOM). Data lineage and training dataset provenance tracked per model asset.
EU AI Act
Record-keeping — automatic logging of events, incidents, and periods of use throughout operational lifetime
Append-only structured event log with SHA-256 hash chain. Every inference, override, and governance decision recorded. 7-year retention. Exportable as PDF or OSCAL with regulator-ready evidence pack.
EU AI Act
Transparency & information provision — deployers receive sufficient information to ensure compliant use
Art. 13
High-risk AI deployers (Annex III)
Production-ready
Risk Atlas · Evidence Ledger
Model card · Risk transparency report
Regulatory status
Mandatory — Annex III high-risk deployers from 2 Dec 2027
Auto-generated model cards per asset. Risk transparency reports include capability statements, known limitations, and intended use scope. Exportable for supply-chain sharing.
EU AI Act
Human oversight — systems designed and deployed to enable effective human oversight and intervention
Art. 14
High-risk AI deployers (Annex III)
Production-ready
Continuous Monitoring · Aval Guardrails
Override log · Human-in-loop gate evidence
Regulatory status
Mandatory — Annex III high-risk deployers from 2 Dec 2027
Human-in-loop gates configurable per risk tier. Aval enforces policy at runtime — outputs requiring human review are flagged and routed. Override decisions logged in evidence ledger with timestamp and approver identity.
EU AI Act
Accuracy, robustness & cybersecurity — appropriate levels of accuracy, resilience to attacks and adversarial inputs
Art. 15
High-risk AI providers (Annex III)
Production-ready
Aval Guardrails · FinProof Harness
Benchmark results · Adversarial test report
Regulatory status
Mandatory — Annex III high-risk providers from 2 Dec 2027
Aval evaluated on FinProof v1 (6,171 entries; 5,389 adversarial) and AgentHarm benchmark. 0.5% false-positive rate at 11.6ms on RTX 4090. Signed test reports exportable per Art. 15 conformity documentation requirements.
EU AI Act — GPAI Model Providers (Art. 53–55) · Applies to general-purpose AI model providers only · Most BFSI deployers are NOT subject to Art. 53–55 directly
GPAI scope note: Art. 53–55 imposes obligations on providers of general-purpose AI models (e.g., foundation model vendors). Banks and financial institutions that deploy GPAI models — but do not train or distribute them — are subject to Art. 9–15 as deployers, not to Art. 53–55. Obligations in this section apply if your institution provides a GPAI model to third parties.
EU AI Act
GPAI model documentation — technical documentation, copyright summaries, training data disclosure
Art. 53
GPAI model providers only (not BFSI deployers)
Prototype
Discovery · Evidence Ledger
GPAI technical documentation pack
Regulatory status
Mandatory for GPAI model providers — from 2 Aug 2025
Prototype: Zytra can generate structured technical documentation from model registry metadata and AIBOM data. Third-party evaluation of documentation completeness pending. Relevant for BFSI institutions operating fine-tuned models distributed internally or to clients.
SR 26-2 / CA 26-2 (Fed, OCC, FDIC — Apr 2026) · Applies to statistical and traditional AI models in US banking · Footnote 3 explicitly excludes GenAI and agentic AI from new requirements
SR 26-2 Footnote 3: GenAI and agentic AI are explicitly excluded from the incremental requirements introduced by SR 26-2. Banks govern those systems under existing MRM practices (SR 11-7). All SR 26-2 rows in this table apply to statistical and traditional AI models only. Zytra's agentic security and guardrail capabilities address the SR 11-7 gap for GenAI separately.
SR 26-2
Model inventory — comprehensive, current inventory of all models in use
§III.A
Statistical / traditional AI models (US banking)
Production-ready
Discovery · AI Asset Registry
Model inventory report · AIBOM
Regulatory status
Mandatory — Fed/OCC/FDIC supervised institutions from 17 Apr 2026
Discovery crawls API endpoints, agent mesh, model registries, and cloud resources to build continuous model inventory. Auto-updated per scan. SHA-256 hash on each snapshot for audit integrity.
SR 26-2
Model risk tiering — classify models by inherent risk based on materiality and complexity
Governance SDK embeds policy gates in CI/CD pipeline. Each gate checks model risk tier, validation status, and approval requirements before deployment. Gate outcomes written to evidence ledger with signed timestamps.
SR 26-2
Model monitoring — ongoing performance monitoring proportionate to model risk tier
Continuous monitoring tracks model performance metrics, data drift, and outcome distributions. Alerts routed to model owner and risk committee. Monitoring cadence configurable per tier. Historical monitoring reports exportable for MRM committee review.
SR 26-2
Model governance — policies, procedures, and internal controls for model risk management
Policy framework mapped to risk atlas controls. Issues tracked from discovery through resolution with owner assignment and timeline. GRC workflow automation routes approvals to model risk committee. Signed evidence ledger records committee decisions.
Board-ready risk pack: residual risk heat map by domain, control effectiveness scores, open issue summary, and monitoring trend lines. Auto-generated from evidence ledger. One-click export as PDF or OSCAL. Committee approvals recorded in signed ledger.
RBI Draft Guidance on Model Risk Management (Jun 2026) · Applies to all RBI-regulated entities deploying AI/ML models · Final guidance pending — comments closed 24 Jul 2026
RBI MRM
Model governance framework — board-approved MRM policy, roles, and accountability structure
Governance framework documentation auto-generated from risk atlas and control assignments. Board approval workflows built into evidence ledger. Role-based access control with committee sign-off tracking.
RBI MRM
Model inventory — complete, current list of all models with risk classification
Auto-discovery populates inventory including model purpose, owner, risk tier, validation status, and deployment environment. Continuous — not point-in-time. API and agent mesh crawl ensures GenAI and agentic models are captured alongside traditional models.
RBI MRM
Model development standards — documentation, testing, and sign-off requirements pre-deployment
§4.1
All RBI-regulated entities
Production-ready
Governance SDK · Evidence Ledger
Development documentation · Pre-deployment gate log
Assessment engine runs automated validation tests against risk atlas controls. Results signed and timestamped in evidence ledger. Supports independent validation workflows: validator assigned separately from model developer, with conflict-of-interest gate in approval chain.
RBI MRM
Model monitoring — ongoing performance and drift monitoring with escalation thresholds
Configurable escalation thresholds per model tier. Drift alerts routed to model owner with SLA clock. Monitoring evidence auto-exported for RBI inspection on demand. Historical trend data retained 7 years.
RBI MRM
Model risk reporting — board and senior management reporting on AI risk exposure
Board reporting pack: residual risk by domain, open issue count and age, validation coverage rate, monitoring alert summary. Generated from live evidence ledger — not manual compilation. Exportable as PDF for board pack and as OSCAL for GRC integration.
NIST AI RMF 1.0 (Jan 2023) · Voluntary framework — four functions: GOVERN, MAP, MEASURE, MANAGE
NIST AI RMF
GOVERN 1.1 — Policies, processes, procedures, and practices are in place to address AI risks
GOVERN 1.1
All AI deployers (voluntary)
Production-ready
Risk Atlas · Evidence Ledger
Policy framework documentation · Control mapping
Regulatory status
Voluntary framework — widely used as baseline for regulatory alignment
Risk atlas provides the policy-to-control mapping GOVERN 1.1 requires. Each risk domain has assigned controls, owners, and implementation evidence. Framework crosswalk maps atlas controls to NIST AI RMF subcategories for audit alignment.
NIST AI RMF
MAP 1.1 — Context is established for the AI risk assessment to take place
Discovery establishes deployment context: purpose, affected stakeholders, capability pattern (RAG, agent, classifier), data inputs, and output modality. Context captured in asset registry and used to filter atlas to relevant risks per deployment.
NIST AI RMF
MAP 3.5 — Likelihood, impact, and prioritization of AI risks are documented and communicated
Aval measured on FinProof v1 (0.5% FPR, 11.6ms on RTX 4090) and AgentHarm benchmark. Continuous monitoring tracks live performance metrics. Signed benchmark results exportable as MEASURE 2.3 assurance evidence.
NIST AI RMF
MANAGE 1.3 — Responses to the AI risks deemed unacceptable are prioritized and managed
Planned: consent management integration for AI inference pipelines processing personal data. Consent Consent Manager provisions active from 13 Nov 2026 — Zytra roadmap targets Q4 2026 for consent audit log and withdrawal tracking.
DPDP Act
Data fiduciary obligations — accuracy, completeness, and purpose limitation for processed data
§8
Data fiduciaries processing personal data
Production-ready
Evidence Ledger · Continuous Monitoring
Data processing log · Purpose limitation audit trail
Regulatory status
Notified Nov 2025; processing obligations effective 13 May 2027
Evidence ledger tracks every AI inference that involves personal data: input data category, processing purpose, model used, output disposition. Purpose limitation enforced at policy gate level via SDK. In-tenant deployment ensures data does not leave the institution's cloud boundary.
DPDP Act
Data principal rights — right to access, correction, erasure, and grievance redressal
Planned: data subject rights workflow — access requests, correction workflows, and erasure pipelines integrated with AI model inputs and outputs. Target: Q2 2027 ahead of effective date.
DPDP Act
Data Protection Board — complaint mechanism and regulatory inquiry response capability
Evidence ledger generates on-demand regulatory inquiry packs: all AI processing events for a named data principal, with timestamps, purpose declarations, and control evidence. Exportable as PDF for Data Protection Board submissions.
DPDP Act
Exemptions — research, statistical, and archival purposes; national security carve-outs
§17
Research, statistical, and public-interest processors
Production-ready
Risk Atlas
Exemption classification record · Legitimate interest assessment
Risk atlas includes exemption classification for each AI use case: research/statistical/archival exemption claims documented with supporting rationale and reviewed annually. Legitimate interest assessments stored in evidence ledger.
SEBI Circular on AI/ML in Securities Market (2024) · Applies to SEBI-registered intermediaries using AI/ML for trading, surveillance, and client-facing systems
SEBI
Risk management — AI risk governance framework for market intermediaries
§3
SEBI-registered intermediaries using AI/ML
Production-ready
Risk Atlas · Assessment Engine
Market risk classification · Control effectiveness report
Regulatory status
Mandatory for SEBI-registered intermediaries — in force
Risk atlas includes SEBI-specific risk domain for market integrity, algorithmic risk, and manipulation detection. Assessment engine scores AI trading systems against SEBI risk criteria. Control effectiveness scores exportable for SEBI inspection.
SEBI
Algorithm accountability — explainability and auditability of AI/ML models used in trading
Algorithm accountability: SDK wraps trading model inference with structured audit events — inputs, outputs, confidence scores, and policy check results. Hash-chained log satisfies SEBI explainability and auditability requirements. Exportable per order or batch.
SEBI
Surveillance — real-time monitoring for market manipulation and anomalous AI behaviour
Aval detects policy violations in real time at 11.6ms. Continuous monitoring layer tracks volume anomalies, drift, and out-of-pattern AI behaviour. Alerts routed to compliance and risk teams. Alert log retained and exportable for SEBI surveillance submissions.
SEBI
Audit trail — complete, tamper-evident trail of all AI-driven trading decisions
Discovery maps AI system boundaries: every model, agent, and pipeline with its interfaces, data inputs, and output dependencies. Stakeholder map generated from organizational roles in asset registry. Context document auto-generated for §4.1 audit readiness.
ISO 42001
Leadership & commitment — top management demonstrates AI governance leadership and resources
Assessment engine systematically evaluates inherent risk × control effectiveness = residual risk per domain. Opportunity register tracks where AI deployment can create value within risk tolerance. Full §6.1 risk assessment exportable as structured report for certification body review.
ISO 42001
AI system impact assessment — process for assessing impact of AI systems on individuals and society