Regulator-mapped compliance packs¶

The EU AI Act Article 12 bundle (bernstein compliance pack article-12) covers record-keeping. Operators with obligations beyond record-keeping needed three more evidence shapes, and used to assemble them by hand from raw exports. The bernstein compliance pack group now ships them as one-command packs, each a deterministic projection of the audit chain and each offline-verifiable with the standalone verifier.

Pack	Command	Maps to	Proves
Retention	`pack retention --since --until`	Article 12(3)	logs existed over the window and were not truncated or rewritten
Incident	`pack incident --run <id>`	Article 73	the incident timeline joined with its audit slice, evidence bundles, and receipts
Oversight	`pack oversight --since --until`	Article 14	who approved what, and that the displayed action equalled the executed action

Every pack is sealed with the same operator-key signing, signed SLSA-style provenance manifest, and canonical-bytes rule (PACK_FORMAT_VERSION 2) as the Article 12 bundle. Two builds over the same chain window yield byte-identical member content hashes; build timestamps live only in the manifest, isolated from the member hashes so the comparison is mechanical.

Retention pack¶

bernstein compliance pack retention \
  --since 2026-01-01 --until 2026-12-31 \
  --org "Acme GmbH" --output acme-retention-2026.zip

Contents:

retention-evidence.json records the boundary head hashes at the window edges, the entry count, detected coverage gaps, and the retention parameters in force.
lineage-log.jsonl embeds the signed entries in canonical bytes, with their per-entry Ed25519 signatures under signatures/ and Agent Cards under agent-cards/.
retention-evidence.pdf and .csv are the human- and machine-readable views.

The verifier recomputes the boundary head hashes and entry count from the actual signed entries, so the continuity claim is checked against the chain, not trusted from the report.

Incident pack¶

bernstein compliance pack incident --run run-42 \
  --org "Acme GmbH" --output acme-incident-run-42.zip

Reads .sdd/incidents/<run>/timeline.json (with optional evidence_bundle_refs and receipt_refs) and .sdd/incidents/<run>/audit-slice.jsonl, then joins:

incident-timeline.json and a fixed regulator-readable incident-report.pdf / .csv.
audit-slice.jsonl, the prev_hmac-chained audit events in canonical bytes.
evidence-bundles/ and receipts/, the referenced artefacts present in the store.
gaps.json, an explicit entry for every referenced artefact missing from the store.

The pack never fabricates completeness: a missing bundle or receipt is recorded as a gap, and verification reports the gap list rather than passing silently.

Oversight pack¶

bernstein compliance pack oversight \
  --since 2026-01-01 --until 2026-12-31 \
  --org "Acme GmbH" --output acme-oversight-2026.zip

Reads resolved approvals from .sdd/approvals/resolved.jsonl (or --approvals). Each in-window approval becomes a canonical receipt under receipts/ carrying the attested displayed-versus-executed binding (displayed_hash, executed_hash), the approving principal, and the decision outcome, summarised in oversight-evidence.json and rendered in oversight-report.pdf / .csv. The verifier recomputes each binding from the receipt payloads, so an auditor confirms displayed equalled executed decision by decision.

Verifying a pack offline¶

All three kinds verify on a machine with no Bernstein install:

pip install bernstein-verify
python -m bernstein_verify pack ./acme-retention-2026.zip

Exit 0 with a one-line PASS summary means every member's sha256 matches the signed manifest input_hashes, the manifest self-anchors (output_hash), and the chained substrate re-verifies for the pack kind. Flipping a single byte in any member, including a rendered PDF, fails verification and names the member. Existing Article 12 packs (format v1 and v2) verify unchanged.