Synthetic agents in government
Disclosure and accountability formats, and what governments are doing.
Disclosure formats for AI in government exist at five grains, and none records, for one output, who or what produced each part and what the human did with it. Tool registers (UK ATRS, 153 records on 14 October 2026; a registry of AI agents under construction in Singapore; an accountable owner for each agent asked for in New South Wales and by the Australian DTA) give an owner and describe human involvement in words. Assessments (Canada's AIA, the AI Act's fundamental-rights assessment) scale duties to risk. Decision notices (France since 2017, Italian case law) say an algorithm contributed and how much. A document rule (AI Act Art. 50(4)) exempts AI-generated public-interest text only if a human holds editorial responsibility. PROV-DM models agents and delegation. The human response is the weak point. Dutch experiments find no general automation bias but selective use of advice that fits a prior view (govai-03, govai-11); oversight policies assume a capacity people may lack (govai-04); the reviewer can become the crumple zone (govai-05). Deployments are real but reported in aggregates: UK Consult (F1 0.76) and Extract (two-thirds of cases needed minor edits), Singapore, Estonia, the UAE's Regulatory Intelligence Office and Davos whitepaper, Dubai's 22 Chief AI Officers. For Mandates the test is whether the named human could decide, in time and with authority, and whether anyone able to change the decision hears back.
Sources
- UK Government Digital Service (GDS), with the ATRS team in the Department for Science, Innovation and Technology (DSIT) (2021 (published 29 November 2021); template v4 and guidance updated 8 May 2025). Algorithmic Transparency Recording Standard: template (Tier 1 and Tier 2), guidance and the published records. GOV.UKcheckedmust readopen accessdated Mandatory across central government from 2024 (GDS blog, 8 May 2025); 153 records on 14 Oct 2026 (records index); BenchNotes record published 9 Sep 2026
The closest working government format to a hands card, at the level of a tool. Tier 2 asks who owns the tool (a role title), how humans are involved, how far the process is automated and what appeal or review route exists; version 4 suits pre-trained models such as language models. The first index page includes an Ofsted AI writing assistant for social care, HMCTS BenchNotes and a Standards and Testing Agency language-model writing-sample generator. The BenchNotes record says the output is always reviewed and validated by the judge and that the tool does not make decisions, and also that the senior responsible owner for the final component is still to be agreed: a gap in the mandate, visible in a public document. What the format does not do is say, for one output, what the reviewer changed or how long they had; the human-involvement field is a statement, not a measurement. Scope rules mean absence from the register is not evidence that no tool is used. Pi, Li and Singh (arXiv:2606.00035, FAccT 2026, abstract only) compare the ATRS with China's Beian system and argue a register can work as pre-approval and regulatory infrastructure, not only transparency.
Read first: The template page for the Tier 1 and Tier 2 split; then the BenchNotes record, sections on owner and responsibility and deployment context.
- European Parliament and Council of the European Union (Regulation); Johann Laux and Hannah Ruschemeier (commentary) (2024; amended 2026; commentary 2025). Regulation (EU) 2024/1689 (AI Act), Articles 14, 26, 27 and 50, as amended in 2026; read with Laux and Ruschemeier on automation bias in the AI Act. Official Journal of the EU; European Journal of Risk Regulation (Laux and Ruschemeier, online 28 July 2025; arXiv:2502.10036)checkedmust readopen accessdated Provisional agreement 7 May 2026; in force 27 July 2026 (secondary sources); high-risk duties from 2 Dec 2027 (Annex III) and 2 Aug 2028 (Annex I); Article 50 from 2 Aug 2026, with a grace period to 2 Dec 2026 for Article 50(2) marking by systems already on the market (secondary sources)
The most detailed legal vocabulary for human oversight and disclosure, and the only instrument among the formats here that names automation bias. Article 14(4): people assigned to oversight must be enabled to understand the system, stay aware of automation bias, interpret outputs, decide not to use the system or to override or reverse it, and stop it. Article 26(2): deployers give oversight to people with competence, training, authority and support; authority is the mandate question in one word. Article 27 asks public bodies to assess fundamental-rights impact, including how oversight will work and what complaint routes exist. Article 50(4) requires disclosure of AI-generated text published to inform the public on matters of public interest, unless it has had human review or editorial control and someone holds editorial responsibility: a legal hook for a hands card, since the exemption turns on a named human taking responsibility. After the 2026 amendment the high-risk duties apply from December 2027 (Annex III), so they do not yet bind. Laux and Ruschemeier argue the awareness duty is hard to enforce because the unbiased outcome is often unknowable, that it splits responsibility unevenly between providers and deployers, and that standards should draw on research on human-AI interaction. For Holagram this favours a log of observable acts (overrides, edits) over a claim of awareness.
Read first: Articles 14(4), 26(2) and 50(4).
- Saar Alon-Barkat, Madalina Busuioc (2023 (online February 2022)). Human-AI Interactions in Public Sector Decision Making: 'Automation Bias' and 'Selective Adherence' to Algorithmic Advice. Journal of Public Administration Research and Theory 33(1): 153-169; DOI 10.1093/jopart/muac007checkedmust readopen access
The central empirical source for the thread's second question, and it complicates the usual story. Three survey experiments in the Netherlands (605 citizens, 904 citizens, 1,345 civil servants) put participants on a school board choosing which of three teachers should lose a contract, with a performance score labelled algorithmic or from a human expert beside a contradicting HR evaluation. In none did people follow the algorithmic score more than the same human-expert score: no general automation bias. In the second study (citizens), people acted on a low score more readily for a teacher with a Moroccan-Dutch name, whether the advice came from an algorithm or a human: selective adherence. Civil servants in the third study, surveyed after the childcare benefits scandal, followed the algorithm less and did not replicate that effect. For Holagram the risk to design against is selective use, not deference: a reader takes output that fits a reading already held, the self-confirming loop of Applied Ballardianism in small. It supports writing the human Reading before the synthetic one is seen, and logging the human response whether or not it changes. It also cuts against any claim that synthetic agents distort specially. Vignette experiments, not field data.
Read first: The abstract, then the descriptions of Study 2 and Study 3, which contrast.
- Ben Green (2022). The flaws of policies requiring human oversight of government algorithms. Computer Law & Security Review 45, article 105681; DOI 10.1016/j.clsr.2022.105681; arXiv:2109.05067checkedmust readopen access
The strongest critique of the idea that a human reviewer fixes a government algorithm. Green reviews 41 policies requiring human oversight and finds two flaws: people often cannot do the oversight assigned to them, and the policies let agencies adopt flawed tools without fixing them, giving a false sense of security that lets vendors and agencies avoid accountability. For Holagram this threatens any hands card that treats 'a human reviewed it' as a safeguard, and supplies a move: the card should carry evidence that the oversight is feasible. For Mandates, institutional oversight is a mandate-level test: who approved the justification, at which level, on what evidence.
Read first: The abstract: the two flaws and the proposed institutional oversight.
- Madeleine Clare Elish (2019). Moral Crumple Zones: Cautionary Tales in Human-Robot Interaction. Engaging Science, Technology, and Society 5: 40-60; DOI 10.17351/ests2019.260checkedmust readopen access
Names the failure a hands card must not create. A moral crumple zone is a human operator who absorbs blame for an automated system's failure while having little real control over it, so the human protects the technology, and those who own it, at their own expense. The paper works through accidents in complex automated systems and the coverage of them. For Holagram: if the human-response register records a name and a sign-off, it can be used to assign blame. The card should record the reviewer's authority, information and time next to the name (compare govai-02, Article 26(2)), and the failure log needs a category for blame landing on a person without control. For Mandates the question is: when an audit finds an error, who is named, and could they have changed the outcome?
Read first: The abstract.
- French Republic (Law No. 2016-1321, art. L311-3-1 of the CRPA; Decree No. 2017-330); Italian Consiglio di Stato (judgments 2270/2019 and 8472/2019); Italian Republic (D.Lgs. 36/2023, art. 30) (2016 (law); 2017 (decree); 2019 (judgments); 2023 (Italian Code)). Decision-level notice and non-exclusive human contribution in French and Italian administrative law. Code des relations entre le public et l'administration; Consiglio di Stato; Codice dei contratti pubblicicheckedopen accessdated Decree in effect 1 September 2017; Consiglio di Stato 2270/2019 dated 8 April 2019; D.Lgs. 36/2023 art. 30 in force with the 2023 Code
The nearest thing in force to a hands note on a single decision. French administrations must tell a person that an individual decision rests on algorithmic processing and, on request, explain how much and in what way the processing contributed, the data and parameters used and the operations performed. Degree of contribution is a notion Holagram's hands notes need and the ATRS does not give per output. Italian case law adds a functional definition of the human part: non-exclusivity means a human contribution able to check, validate or overturn the automated result, alongside knowability and algorithmic non-discrimination (per search-result summaries). For Mandates these are act-level norms a court can enforce, unlike tool registers. Limits: they cover administrative decisions about individuals, not documents or plans, and a parliamentary question reported in search results says the French notice was missing from tax notices years after the law.
Read first: The decree summary: the information to be given on request about the degree and mode of contribution.
- Treasury Board of Canada Secretariat (Government of Canada) (2019 (in force 1 April 2019; amended 25 April 2023; page dated 24 June 2025)). Directive on Automated Decision-Making and the Algorithmic Impact Assessment tool. Government of Canada policy suite; canada.cacheckedopen accessdated In force 1 April 2019; amended 25 April 2023; version dated 24 June 2025 (search excerpt); AIA page dated 15 September 2026
The most mature mandatory regime for automated administrative decisions, and the only one here that scales duties to impact: a questionnaire gives one of four levels (mitigations scoring 80 per cent or more cut the raw score by 15 per cent), and the level sets the safeguards, which Agora lists as peer review, notice, human intervention and explanation. It names the post accountable for the assessment, so it is also a mandate document. For Holagram the AIA is a Reading by the institution about itself, with published results as Traces anyone can open and peer review as an outside Test before launch. Limits: it covers systems used to make or assist administrative decisions about clients, in production, so it does not reach a ministry drafting legislation with a language model; per-level human-intervention rules are unverified here.
Read first: The AIA page: the four impact levels and how the score is built.
- Luc Moreau, Paolo Missier (editors); W3C Provenance Working Group (2013). PROV-DM: The PROV Data Model. W3C Recommendation, 30 April 2013checkedopen access
The one existing standard whose vocabulary matches a hands note. An Agent bears responsibility for an activity, for a thing's existence or for another agent's activity, and may be a person, running software or an organisation. actedOnBehalfOf models delegation and leaves some responsibility with the delegator, which a Mandates Entry needs. Using it would let Holagram publish its log of linked entries in a form other tools read, and keep apart the producing agent, the delegator and the plan followed. It is a data model, not a disclosure policy: it says nothing about what the human did in review unless that is modelled as an activity, and it will not stop a vague agent field. Pair it with the French degree of contribution (govai-06).
Read first: The definitions of Agent, SoftwareAgent and actedOnBehalfOf.
- Shidong Pan, Haochen Gong, Boming Xia, Xiaoyu Sun, Xiwei Xu, Liming Zhu (2026). The Creation and Analysis of Government AI Transparency Statements in Australia. arXiv:2604.26075 (v1 28 April 2026; v2 8 July 2026)checkedopen access
A rare empirical look at how a government disclosure format behaves once agencies write to it. The authors built a dataset (AITS-101) of AI transparency statements that Australian government bodies must publish under a national standard, analysed it with stylometric, quantitative and qualitative methods, and report wide variation in how much agencies disclose and gaps between the policy's intent and what agencies write. For Holagram it supports a card with few fixed fields, since free text drifts, and offers a corpus of invisible literature at the unit level: public, agency-written and checkable against what the agency does. Read with the Robodebt report (govai-17), the same country's earlier failure.
Read first: The abstract.
- Government Technology Agency of Singapore (GovTech), reported by The Straits Times; Digital NSW Office for AI; Australian Digital Transformation Agency (DTA) (2025-2026). Registers and named owners for government AI agents: Singapore's planned registry (2 June 2026), NSW guidance on AI agent deployment (14 November 2025), Australia's Agentic AI addendum (May to June 2026). News report and government guidancecheckedopen accessdated 2 June 2026 (Singapore); 14 November 2025 (NSW); May to June 2026 (DTA)
Governments are converging on a small format for agents: a named owner and an activity record. GovTech Singapore is building a registry for its 150,000 public officers that tracks who owns each AI agent and what it does, as part of a tool suite due for wider rollout later in 2026; the story notes agents can act with minimal or no human intervention. NSW advises a designated business owner for each agent, central visibility of agent ownership, and a first deployment in a low-risk internal setting. The DTA addendum, per the excerpt, asks that a human be assigned accountability for agent decisions (AGT.1.1) and that oversight be human-in-the-loop or on-the-loop (AGT.1.2). This is hands at the level of the agent: who owns the synthetic hand and what it may do. For Holagram it models the registry of synthetic agents in a study (Alter, Adversary): owner, role, permitted actions, log. It does not give hands per output, and the Singapore registry is announced, not evidenced.
Read first: The Straits Times story (via BritCham) and the NSW guidance on owner and visibility.
- Friso Selten, Marcel Robeer, Stephan Grimmelikhuijsen (2023). 'Just like I thought': Street-level bureaucrats trust AI recommendations if they confirm their professional judgment. Public Administration Review 83(2): 263-278; DOI 10.1111/puar.13602checkedopen access
A 2x2 factorial experiment with Dutch police officers and a mock predictive-policing system. Officers trusted and followed recommendations that matched their intuitive professional judgement, and explanations had no measurable effect on trust. The authors read this as officers not trusting AI blindly, so discretion can catch faulty recommendations, while fair AI may not correct human bias. For Holagram it is direct evidence for the rule that no reading judges itself: an Adversary that disagrees with the researcher will be discounted just when most useful, and one that agrees will be trusted. The log should record the Reading before the Adversary's Test is shown, and whether the Reading changed. It also warns against treating explanations attached to the Adversary's output as a cure. One experiment, one profession, one country.
Read first: The abstract.
- OECD (2025). Governing with Artificial Intelligence: The State of Play and Way Forward in Core Government Functions. OECD Publishing, 18 September 2025; DOI 10.1787/795de142-encheckeddated 18 September 2025
The reference survey of what governments are doing: 200 use cases across 11 core functions, which the OECD.AI page illustrates with service delivery, justice, anti-corruption, public finance and civil service reform. Per Global Government Forum it names over-reliance and weak transparency as risks and finds most governments lack holistic measurement of results. For Holagram, benefit claims are mostly projections or self-reports, so a Trace of the form 'the government says X' should record whether X was measured. Practitioners are likely to know the document, and it can anchor which functions a Mandates study covers. Not a source on oversight mechanics.
Read first: The OECD.AI summary page.
- UK Department for Science, Innovation and Technology (DSIT) and Incubator for AI (i.AI); Ministry of Housing, Communities and Local Government (MHCLG) Digital Planning; Department for Transport with the Alan Turing Institute (2025-2026). Government-built language-model tools with officer review: Consult (DSIT, 14 May 2025), the Consultation Analysis Tool evaluation (DfT and Alan Turing Institute, 23 December 2025) and Extract (MHCLG, 17 June 2026). GOV.UK press release and publication; MHCLG Digital blogcheckedopen accessdated 14 May 2025; 23 December 2025; 17 June 2026
Three government deployments in which a language model reads public documents and officers review. Consult sorted responses to a Scottish Government consultation (over 2,000 responses, six questions) into themes; experts reviewed every response in this first live use; multi-label F1 was 0.76 and median review time 23 seconds per response; DSIT's estimate of 75,000 days a year across about 500 consultations is a projection, and the tool was still in trial. The DfT and Turing evaluation compared theme generation with human-analysed data, ran a live pilot in which reviewers could amend output and checked accuracy across protected characteristics; the page gives no figures. Extract converts scanned planning documents (conservation areas, Article 4 directions, tree preservation orders) into structured data; officers review and correct all outputs; about two-thirds of cases needed only minor edits; every English planning authority has had access since June 2026. These give aggregate measures of the human response (edits, agreement, review time) but not per-output records, and the Extract blog has no ATRS record or statement on responsibility for errors. Extract is an LLM reading the invisible literature of planning: a cross-lead for Cities.
Read first: The DSIT press release; the MHCLG blog section on review and edits.
- UAE Cabinet and its General Secretariat; Dubai Media Office; General Secretariat of the Cabinet with Presight and PwC (whitepaper); Pinsent Masons Out-Law (commentary) (2025-2026). Regulatory Intelligence Office and AI-based legislative system (Cabinet decision, 14 April 2025) and the whitepaper 'The UAE: Shaping the Future of Regulatory Intelligence' (World Economic Forum, Davos, 22 January 2026). Government announcement and whitepaper, seen through reportscheckedopen accessdated 14 April 2025; 22 January 2026; 30 January 2026
The most developed announced programme of AI in lawmaking, and the one closest to the Mandates audience. On 14 April 2025 the Cabinet approved a Regulatory Intelligence Office under its General Secretariat to lead an AI-based legislative system: federal and local laws linked to court rulings, procedures and public services, daily tracking of the impact of laws, suggested updates, and an official projection of up to 70 per cent faster legislation. The release says the approach combines human insight with AI efficiency but not how human review works. On 22 January 2026 a whitepaper presented at Davos (General Secretariat with Presight and PwC) proposed a Unified Regulatory Digital Twin, which Out-Law says covers onshore and offshore jurisdictions such as DIFC and ADGM, and a Sovereign Governance-in-the-Loop framework: AI assists, humans remain decision-makers at critical stages. Out-Law calls it a vision, not enacted law. A UAE minister's article (30 January 2026) stresses human-in-the-loop models, clear accountability and explainable algorithms. For Mandates, layered jurisdictions are the test bed: a unified twin is a Reading at the polity level, not an aggregate of emirate and free-zone texts, and 'critical stages' is the term a hands card would make checkable. Use the announcements as dated Traces; do not infer practice.
Read first: The Dubai Media Office report of 14 April 2025; the Out-Law summary of the whitepaper's human oversight framework.
- Government of Dubai (Executive Council; Dubai Center for Artificial Intelligence); Smart Dubai Office (its site now redirects to digitaldubai.ae); UAE Cabinet (Charter) (2019-2024). Dubai Universal Blueprint for AI (29 April 2024) and the appointment of 22 Chief AI Officers (9 June 2024), with the Smart Dubai Ethical AI Toolkit (8 January 2019). Gulf News reports; Smart Dubai newsroom; u.aecheckedopen accessdated 29 April 2024 (blueprint); 9 June 2024 (22 Chief AI Officers); 8 January 2019 and 2 February 2020 (toolkit); 10 June 2024 (Charter)
Dubai's accountability apparatus, as announced, is posts and principles more than disclosure formats. The blueprint, an annual plan whose first phase puts a Chief AI Officer in every government entity (candidates assessed by the Dubai Center for AI), was followed on 9 June 2024 by 22 appointments, including Dubai Municipality, the Roads and Transport Authority, Dubai Police and the Public Prosecution. The 2019 toolkit includes a self-assessment tool that scores a system against the city's ethical principles; by February 2020 it had been used on 18 use cases and the Roads and Transport Authority had made it mandatory for its own AI systems. The federal Charter lists human oversight, transparency, and governance and accountability among 12 principles. As read, none defines a per-decision or per-document disclosure, or says who answers for a Chief AI Officer's decisions; that is where a hands card would add something. Mandates hook: a Chief AI Officer is a created mandate across 22 bodies of different kinds, whose ability to act is not described in the sources seen.
Read first: Gulf News, 9 June 2024: the list of 22 entities.
- Estonian Information System Authority (RIA) and Ministry of Economic Affairs and Communications; e-Estonia; European Commission (Recovery and Resilience Facility page); Apolitical (2022-2026). Bürokratt: Estonia's network of public-service AI assistants (e-Estonia, 26 January 2022; European Commission project page; Apolitical case study, 6 July 2026). e-Estonia; European Commission; Apoliticalcheckedopen accessdated 26 January 2022; October 2025 (18 organisations, as reported on 6 July 2026)
Estonia built an interoperable network of agency assistants, each answering from sources its institution defines, with handover to a human customer agent when it cannot help, moving from a trained chatbot to language models. The Apolitical case study says its material does not state who is liable for answers, what is logged or how users are told they are talking to an AI, and the 2022 e-Estonia article does not say how users are told either. For Mandates, an institution defining the sources its assistant may use is a delegation of voice: the assistant speaks for the agency, so a hands note for an answer must say whose source and whose rule. For the unconventional shelf: the name comes from the kratt of Estonian folklore, a creature that serves its master and must always be given work or it may turn against the master (per e-Estonia), a usable image for the care rule that every synthetic agent has a stated job.
Read first: The e-Estonia article for the kratt image; the Apolitical page for its governance section.
- Royal Commission into the Robodebt Scheme (Commonwealth of Australia) (2023). Report of the Royal Commission into the Robodebt Scheme. Tabled 7 July 2023; corrected edition 11 July 2023checkedopen accessdated Report tabled 7 July 2023; government response November 2023
The reference case of automation without a lawful basis, seen at the level of an institution's mandate. Per the summaries, the scheme matched tax-office income data with welfare payments, averaged annual income into fortnightly figures and issued debt notices; the Commission found it neither fair nor legal, earlier tribunal decisions against averaging had been ignored, legal barriers were left out of the Cabinet proposal, and officers impeded the Ombudsman. Recommendations 17.1 and 17.2 are the nearest thing to a disclosure format prescribed by an inquiry: a consistent legal framework for automation, a clear review path, departmental websites saying automated decision-making is used and explaining it in plain language, business rules and algorithms open to independent expert scrutiny, and a body to monitor and audit. The government said in November 2023 it accepted all recommendations in full or in principle. For Holagram it shows no level sums up another: an act-level debt notice traces to polity-level documents (a policy proposal, legal advice, department structure), each of which could look in order alone. It is also a case of 'the next step': the department could take it without legal authority.
Read first: Recommendations 17.1 and 17.2 on automated decision-making (seen only through two legal summaries, not in the report).
- Lighthouse Reports, with WIRED (partners included Follow the Money and Vers Beton) (2023). Suspicion Machines (investigation) and its methodology page, 'How we evaluated bias in Rotterdam's suspicion machine'. Lighthouse Reports, March 2023 (methodology dated 2 March 2023, investigation 6 March 2023)checkedopen accessdated March 2023
A worked example of a Test at another level, run by an outsider. After freedom-of-information requests across Europe, Rotterdam released the trained model, code, variable list, internal evaluations and a data-scientist handbook, but not the training data. The team varied one characteristic at a time and compared scores, checked on a synthetic dataset and built hypothetical profiles; it reports the model penalised younger people, parents, women, people with financial problems and weaker Dutch, and that the city said it had reached similar conclusions and suspended the system in 2021. It lists what could not be done: no outcome labels, so error rates by group could not be compared, and training data unrepresentative of the population. For Holagram: (1) a Test with a held, broke or unchecked structure; (2) the unchecked list is part of the result; (3) a care rule, since the release contained real records by accident, which the team kept under access controls and planned to delete. Governance-innovation readers are likely to know this investigation. Not a scholarly source.
Read first: The methodology page, including the section on what could not be obtained.
- Bruce Schneier, Nathan E. Sanders (2025). AI-Generated Law Isn't Necessarily a Terrible Idea. Foreign Policy, 14 May 2025 (also on Schneier on Security, 15 May 2025)checkeddated 14 May 2025 (essay on the UAE announcement of April 2025; a Brazilian ordinance of 2023; an Ohio code review of 2020)
A short essay, readable well within an hour, that gives Holagram three things. First, a dated disclosure failure: a Brazilian city ordinance drafted with ChatGPT help passed unanimously in 2023, and the authors argue the AI involvement should have been disclosed before the vote, not after. Second, a concept, microlegislation: AI-produced loopholes that may stay imperceptible on the page until their effects are felt. Third, an argument that drafting speed is rarely the bottleneck in lawmaking, so 'up to 70 per cent faster' measures the wrong variable. For Mandates it pins 'disclose before adoption' on a legislative text.
Read first: The Porto Alegre passage and the microlegislation passage.
- mandy brown (essay); Dan Davies (book) (2024). Accountability sinks (essay, A Working Library, 16 October 2024), on Dan Davies, The Unaccountability Machine: Why Big Systems Make Terrible Decisions (Profile Books and University of Chicago Press, 2024). A Working Library; Profile Books / University of Chicago Presscorrectedopen accessdated 16 October 2024 (essay)
Names the structure a hands card must avoid becoming: an accountability sink, a structure that breaks the link between the person affected by a decision and the people able to change it, so consequences are absorbed and no one is held responsible. The essay pairs Davies's point that accountability follows the power to change a decision with the view that an account is a story of how something happened, and notes algorithms are convenient sinks but organisations already make them, so existing accountability efforts may not work well against AI. For Holagram: (1) a test for any Mandates Entry: can the affected person's feedback reach someone with power to change the decision? That differs from asking whether a human was in the loop. (2) A written account of how something happened is close to the Entry's chain from Trace to Test, making the account itself an accountability device. (3) It gives practitioners a term they may already use. Practitioner writing, not a study.
Read first: The essay.
Audit: Full book subtitle per Open Library is 'Why Big Systems Make Terrible Decisions - and How the World Lost Its Mind'; the scout's title string stops after 'Decisions'.
What it implies for the proposals
- Levels. Place each existing format at the level where it speaks and do not let one stand for another. Act: decision notices and the degree-and-mode-of-contribution information in French law (govai-06), the review of one output (govai-13). Unit: the team using the tool, as in the ATRS deployment-context sheet and the officers reviewing Extract outputs (govai-01, govai-13). Authority: the owner or senior responsible owner, the designated business owner of an agent, the Chief AI Officer (govai-01, govai-10, govai-15). Jurisdiction: federal, emirate and free-zone layers, which the UAE whitepaper's regulatory digital twin is said to span (govai-14). Polity: Cabinet decisions, inquiries and surveys (govai-14, govai-17, govai-12). An ATRS record is a Reading at the authority level; it does not certify what a reviewer did on one act.
- Documents to read, and the ground to check them against. The invisible literature for Mandates with synthetic agents is public and dated: ATRS records (153 on 14 Oct 2026), Canadian AIA results published before launch, Australian AI transparency statements (the AITS-101 corpus), Cabinet decisions and whitepapers, lists of appointed Chief AI Officers, evaluation reports (Consult, CAT) and inquiry reports (govai-01, 07, 09, 13, 14, 15, 17). The ground is not a place but the next step: can the unit take it. Check each document against a public document at another level: an ATRS statement that output is always reviewed against the evaluation's reported edit rate; a press release's savings against the evaluation; a role announcement against the delegation or terms of reference that would give the role authority.
- Hands note fields. Build the card from what exists and add what is missing. Existing: producer type and delegation (PROV: person, software agent, organisation, acted on behalf of; govai-08), owner and role title (ATRS sheet 2.1; govai-01), degree and mode of contribution (French decree; govai-06), how oversight will be implemented and the complaint route (AI Act Art. 27; govai-02). Missing everywhere: what the reviewer changed, the time available, and the reviewer's authority to override or stop. The AI Act names the duty in Art. 14(4) and 26(2) but no format records it (govai-02, govai-13).
- A test of the human response. Replace 'human in the loop: yes' with observed behaviour: override rate, edit rate, time per item, and whether the reviewer wrote a view before seeing the machine's. Aggregates exist: about two-thirds of Extract cases needed only minor edits, and Consult experts reviewed every response in the first live use at F1 0.76 (govai-13). Because the literature finds selective use rather than deference (govai-03, govai-11) and the AI Act's awareness duty is hard to prove (govai-02), a human response that never differs from the machine's is a finding to test, not a pass. Result 'unchecked' when the institution publishes no figures, which is the usual case.
- Failure modes specific to Mandates. Put them in the failure log from the start: reviewer as crumple zone (govai-05); accountability sink, where delegation cascades until the origin is lost and the affected person cannot reach anyone able to change the decision (govai-20); mandate drift, where a text authorises assistance and practice delegates the decision, or the legal basis does not support the step (the Robodebt findings, govai-17); oversight as decoration (govai-04); disclosure after adoption (govai-19); a role created without authority to act (govai-15, and govai-02 Art. 26(2)).
- Tests at another level. Three working patterns. An outsider reconstructs from released artefacts, varies one factor and lists what could not be obtained (govai-18). An inquiry tests act-level documents against polity-level law (govai-17). Peer review or an impact assessment tests an authority's self-description before launch, as the Canadian Directive requires for peer review (govai-07). In a Mandates Entry, a Reading at the authority level ('the unit reviews all outputs') is tested at the act level (a sample of outputs) or by another agent (an outside reader), never by the authority's own report.
- Layered jurisdictions. For federation, emirate, authority and free-zone settings, treat a 'unified' view as a Reading at the polity level, not an aggregate of lower levels. The UAE whitepaper is described as proposing a regulatory digital twin spanning onshore and offshore jurisdictions and a principle that humans remain decision-makers at critical stages (govai-14). A neutral first Test: ask each level, from its own documents, to name the critical stages and the person with authority at each, and record where the answers differ. The difference is the finding. Use only the government's own words, and treat the whitepaper text as unseen until it is found.
- Benefit and speed claims as Traces with a status. 'Up to 70 per cent faster' legislation is a projection (govai-14); 75,000 days a year across consultations is an estimate (govai-13); the OECD finds most governments lack processes to measure results (govai-12); drafting speed may not be the bottleneck (govai-19). Log each as claim, source, date and status: projection, self-report, measured, or independently evaluated. KPI sheets that reward throughput are a Mandates document worth reading for how they treat review time.
- First study for Mandates (public material only, three weeks). Option B for Dubai readers: the three public statements on the Regulatory Intelligence Office (14 April 2025, 22 January 2026, 30 January 2026), read for how each level defines critical stages (govai-14). Option A needs no one's consent; Option B needs an outside reader from inside government who can call a stop.
- Care rules for Mandates. Use role titles, as the ATRS does, never named officials; do not read a projection as practice; keep the Fiction register off real institutions' decisions, or label it so plainly that it cannot be quoted as a finding; carry no personal data from released artefacts (the Rotterdam release contained real records by accident; govai-18); and ask a reader from the institution studied to act as the outside reader who can call a stop (govai-01 for role titles).
Ideas to take
A hands card shaped like a provenance record, with a human-response block.
Changes: The GRAM page can specify a card for each register of an Entry and for any document built from the log: the part produced, the agent type (person, software agent, organisation), who it acted on behalf of, its role (Alter, Adversary or none), degree and mode of contribution in the French wording, then a human-response block: who reviewed, with what authority and time, and what changed. The log can be exported in a form other tools read.
Risk: Free-text disclosure drifts (govai-09 reports wide variation in Australian statements) and a rich model invites completeness theatre. Keep fields few and fixed; a card nobody fills in is worse than a short one.
Authority and capacity in place of 'human in the loop'.
Changes: Every human response records whether the person could override, stop or escalate, and had the information and time to do so (Art. 14(4), 26(2)). The failure log gets a category, crumple zone: blame landing on a person without control. Mandates gets a standard question for any claim that a human decides.
Risk: Authority is partly self-reported and partly a legal question that a literary reading will not settle. Naming roles can expose individuals; use role titles and ask an outside reader.
Measure the human response and treat absence as 'unchecked'.
Changes: Any Trace saying officers review everything gets three follow-up Traces: edit rate, override rate, time per item. If none is published the Test result is unchecked, logged as a finding about the institution and not as a gap in the study.
Risk: A low edit rate is ambiguous: a good tool or a rubber stamp. The method must keep the ambiguity and not turn a rate into a verdict; metrics can also be gamed once published.
Reading before reply, as a small embedded design.
Changes: The protocol fixes the order: the human writes the Reading, then sees the Adversary's Test, and the log records whether the Reading changed and whether the Adversary agreed or disagreed. Over a few dozen Entries this gives a rough, honest measure of selective use inside the research team.
Risk: Too few Entries for inference, and the researcher is both subject and author; present it as a log, not a result. The Dutch findings come from vignette and simulation studies and may not transfer.
Outside-in reconstruction as the standard Test for institutional claims.
Changes: The Test register gets a template: artefacts obtained, one factor varied, result, and a list of what could not be obtained. For Mandates the artefacts are public records (ATRS, AIA results, published evaluations); a polity-level inquiry such as the Robodebt Commission is the pattern for testing act-level documents.
Risk: The first study is public material only, so the artefacts will rarely allow a model to be re-run and the method may shrink to document comparison. Released data can carry personal information.
Make a stated principle checkable: humans decide at critical stages.
Changes: Gives Mandates a distinct study for layered jurisdictions: ask each level to list the critical stages in its own documents and name the person with authority at each; the disagreement between levels is the finding. For governance-innovation practitioners it reads as an offer to operationalise a named principle, not a critique.
Risk: Political sensitivity, and the whitepaper text has not been found; a government reader may take any gap as an accusation. Work from the government's own words and agree an outside reader from inside government before starting.
A registry for the synthetic agents used in a study.
Changes: The protocol adds a short registry before any synthetic agent is used: owner, role (Alter or Adversary), permitted actions, log location. The Estonian image of the kratt, an agent that must always be given work, can name the care rule that every agent has a stated job and anything outside it goes to the failure log.
Risk: Formalism for a three-week study; the folklore framing may read as frivolous to some audiences; agent registries are announced, not evaluated.
Disclose before adoption: a hands map travels with any drafted text.
Changes: Any text an institution could adopt (draft clauses, plan text, terms of reference) circulates with a map of which parts a synthetic agent produced and who reviewed them, from first circulation. Fiction stays labelled and outside the text. This gives governance labs a practical product and ties to Art. 50(4).
Risk: Provenance of iterative drafting is hard to keep at clause level and false precision is likely. Drafters may stop using the tool openly to avoid the map.
Counter-arguments
- Registers and assessments already do this, so what does GRAM add? Practitioners know the ATRS, the AIA and the AI Act's fundamental-rights assessment. If the hands card is a re-skinned Tier 2 sheet they will say use the ATRS. The answer has to be what those instruments lack: a record of the human response, and a cross-level Test with a failure log (govai-01, govai-07, govai-09).
- Disclosure and oversight formats may not change behaviour. Green finds that 41 oversight policies rest on a capacity people often lack and give a false sense of security; Laux and Ruschemeier find the AI Act's awareness duty hard to enforce. A hands card could join that list as one more safeguard that does little (govai-04, govai-02).
- A hands card can create crumple zones. Recording a reviewer's name against a machine's output makes it easier to blame them, and government staff will resist anything that names reviewers. The card has to record authority, information and time with the name, and use role titles (govai-05, govai-20).
- The evidence for automation bias in public administration is mixed. Three Dutch experiments found no general deference to algorithmic advice, so a method built around the fear of deference may be overbuilt. What the studies do support is selective use of advice that confirms a prior view, and that is already the failure Holagram's rules address. Do not claim synthetic agents are uniquely risky: human advice was used selectively too (govai-03, govai-11).
- In government the binding question is legal authority, not reading. A mandate is a legal category (power, delegation, jurisdiction), and Robodebt failed on legality. Lawyers will say a literary-style reading of mandate documents is no substitute for legal review, and may call it an amateur ultra vires analysis. The method needs a legal outside reader (govai-17, govai-06).
- Public documents about government AI are mostly announcements and projections ('up to 70 per cent', '75,000 days', '100 per cent accurate' on a small sample). A Trace taken from them is a claim, not a fact, and the method risks laundering press material into evidence unless each claim is graded (govai-14, govai-13, govai-12).
- Strong or paranoid readings of a government's AI programme are costly for practitioners who work inside that government. The UAE whitepaper's own principle is that humans stay in command at critical stages, so a Reading that the machine decides would be an over-reading unless tested; a government colleague may take Fiction about their mandate as insinuation (govai-14, govai-19).
- Practice is moving from texts to agents that act. Singapore's report says agents can act with minimal or no human intervention, and registries for them are only being built. A document-first method may study yesterday's practice, and the hands that matter are in logs the public cannot see (govai-10).
Gaps
- Per-output hands records in government: none found. The ATRS is tool-level, France's notice is decision-level but a notice only, the AI Act's Art. 50(4) is document-level, PROV is a data model.
- What reviewers actually do with language-model output in government: only aggregates (Extract: two-thirds minor edits; Consult: F1 0.76, every response reviewed in the first live use). The full evaluation reports were not read. No field study of automation bias with language models in public administration found; the experiments are Dutch vignettes and one police simulation.
- UAE: the whitepaper text was not found; no published review procedure for AI-assisted drafting; no law known to have been drafted through the system; no description of a Chief AI Officer's duties. The Cabinet's own page returned 403.
- Left out of the sources as unverified.
- Canada: the Directive text and Appendix C could not be fetched, so the human-intervention requirements by impact level are unverified, and whether the 2025 revision changed them is unknown.
- Estonian-language sources not searched. The status of the 2019 'kratt law' discussion is unconfirmed.
- Singapore: the agent registry is known only from news reports; its fields and whether it is public are unknown. GovTech and Open Government Products pages on Pair were minimal.
- Effect of the standard on practice: only an abstract-level FAccT 2026 paper (arXiv:2606.00035).
- AI Act: read on an unofficial text site; the consolidated official text, the Commission's template for the fundamental-rights assessment and any guidance on Art. 14 were not seen. Dates after the 2026 amendment come from secondary summaries.
- Finnish and Estonian public-law routes: Finnish rules on automated decisions and the Helsinki city AI register of 2020 were not searched or verified in this run. Koulu's 'Human control over automation: EU policy and AI ethics' (European Journal of Legal Studies, 1/2020, pp. 9-46; University of Helsinki) was seen in a catalogue record but not listed; see cross-leads.
- Beyond the UAE, Singapore, the UK, Estonia, Australia, Canada and the EU: China's Beian system appears only in the abstract of the Pi, Li and Singh paper. No other jurisdictions searched.