N · Checklists

Checklist: Change, Retirement and Audit

Classifying change honestly, retiring without losing the ability to answer questions, and a dry run that finds the gaps before someone else does.

Change is where governance quality is really tested: the classification determines the assurance, and the assurance determines whether the authorization still means anything.

The audit-readiness dry run at the end takes half a day and reliably finds three things. Run it before you are asked to.

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A completed checklist is not evidence. The evidence is the record it told you to complete — the templates hold those.

Classifying the change

  • Change described in the terms the authorized configuration uses System Owner
  • Dimensions touched identified before the assurance scope is chosen Risk Lead
  • Classified against the change-type table, with reasoning, not just a label System Owner
  • Autonomy change answered explicitly — any increase is never cosmetic System Owner
  • Second person confirms at Tier 3–4 where cosmetic or minor is claimed Risk Lead
  • Supplier-initiated changes recorded as changes even when nothing local moved System Owner
  • Population or user-group change treated as Major Risk Lead

Delta assurance

  • Scope states what is re-run and what is not, with the reason for each
  • Neither “full re-run” nor “no re-run” accepted as a default
  • Criteria unchanged from the original evaluation, so results are comparable
  • Rollback plan stated, with its duration
  • Post-change verification defined, with a date
  • Authorized configuration updated on completion — the most commonly skipped step

Retirement

  • Downstream consumers identified from telemetry, not documentation Architect
  • Data disposition confirmed, including indexes, embeddings, caches and evaluation sets Data Owner
  • Machine identities revoked Security Architect
  • Model weights, prompts and configurations disposed of or archived deliberately System Owner
  • Evidence archived and one retrieval tested in a readable format System Owner
  • Ability to explain historical decisions preserved for the liability window Risk Lead
  • Residual obligations identified and assigned to a named owner Risk Lead
  • Knowledge preservation note written, including what would be done differently System Owner

Audit-readiness dry run — half a day, once a quarter

  • Pick one Tier 3–4 system and one decision it made six months ago
  • Reconstruct which model version, instruction version and grounding sources were live that day
  • Produce the authorization record in force at the time, with its conditions
  • Produce the classification in force, and its countersignature
  • Produce the assurance evidence the authorization relied on, at the right version
  • Show what the system was permitted to do, and evidence that it stayed within it
  • Show what changed since, and how each change was classified and assured
  • Show the oversight evidence: who reviewed, how often they departed from the recommendation
  • Time the exercise, and record what could not be produced

After the dry run

  • Gaps recorded as findings with owners and dates, not as observations
  • Anything that took more than an hour to produce is a tooling or record-design problem
  • Records that could not be produced at all are escalated to the AI Governance Body
  • One improvement implemented before the next dry run