Auditing Agents Under NIS2, DORA, and the EU AI Act: Compliance by construction, when architecture becomes the audit evidence

Regulators no longer ask whether an agent action happened. They ask the deploying organization to reconstruct who or what authorized it, scoped to what, valid until when, and how the boundary was held across the delegation chain. Application logs answer the first question. Only architecture-produced evidence answers the second.NIS2 Article 21, DORA Articles 6 / 8 / 17-19, and EU AI Act Annex IV name different obligations under different enforcement regimes but demand the same artifact: a cryptographically chained receipt of authority that survives partial-chain compromise. The capability-token + ZKP + attenuation-discipline architecture from Papers #1-4 of the Non-Human Identity Series produces that artifact by construction.Paper #5 of the Non-Human Identity Series. Series I closure. Bridges to Series II (PQC for AI Agent Systems), opening late June 2026.

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Publication Details

Journal
Zenodo (CERN European Organization for Nuclear Research)
Published
2026-05-19
DOI
https://doi.org/10.5281/zenodo.20271636
Primary Topic
Ethics and Social Impacts of AI
Type
preprint
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preprint

Auditing Agents Under NIS2, DORA, and the EU AI Act: Compliance by construction, when architecture becomes the audit evidence

Mohamad Amin Hasbini
Zenodo (CERN European Organization for Nuclear Research)
Ethics and Social Impacts of AI
preprint

Auditing Agents Under NIS2, DORA, and the EU AI Act: Compliance by construction, when architecture becomes the audit evidence

Mohamad Amin Hasbini
preprint en

Abstract

Regulators no longer ask whether an agent action happened. They ask the deploying organization to reconstruct who or what authorized it, scoped to what, valid until when, and how the boundary was held across the delegation chain. Application logs answer the first question. Only architecture-produced evidence answers the second.NIS2 Article 21, DORA Articles 6 / 8 / 17-19, and EU AI Act Annex IV name different obligations under different enforcement regimes but demand the same artifact: a cryptographically chained receipt of authority that survives partial-chain compromise. The capability-token + ZKP + attenuation-discipline architecture from Papers #1-4 of the Non-Human Identity Series produces that artifact by construction.Paper #5 of the Non-Human Identity Series. Series I closure. Bridges to Series II (PQC for AI Agent Systems), opening late June 2026.

Zenodo (CERN European Organization for Nuclear Research)
Sustainable cities and communities
Ethics and Social Impacts of AI
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