⚠️ PAP Status: PARTIAL DRAFT Track B (Investigative-Decision Vocabulary) exists as a v0.2.0 draft; Track A (Administrative-Decision) is scoped but not drafted. No consolidated PAP specification exists. Contributions and feedback are welcome.
VAP Profile PAP

PAP - Public Administration Profile

Democratic Accountability for Government AI

"No Decision Without Justification" — A decision without explanation is an enemy of democracy.

Your loan application was denied. Why?

Your welfare benefits were terminated. Why?

Your parole was rejected. Why?

"Because the AI decided so" is not an answer democracy can accept.

Every citizen has the right to know the reasons behind decisions that affect them.
Every decision must be subject to appeal and judicial review.

PAP is designed to cryptographically record every AI decision in public administration — documenting when, what data was used, which rules were applied, and why that conclusion was reached — in a tamper-evident format.

🏛️
Profile ID
PAP
📋
Status
Partial Draft
🔗
Parent Framework
VAP
⚖️
Risk Category
Democratic Integrity

Why PAP is Necessary

Current challenges in public AI systems and how PAP addresses them

Lack of Accountability

AI declares "ineligible" without explaining why. Citizens cannot even begin to appeal without understanding the basis for the decision.

Algorithmic Bias Entrenchment

AI trained on historically discriminatory data perpetuates and reproduces unfair decisions systematically.

Loss of Democratic Control

Unelected algorithms make decisions that affect citizens' fundamental rights, without democratic oversight or accountability.

Illustrative Problem Scenarios (Generalized)

Case 1: Welfare Benefits AI Black Box

Benefits eligibility determination

[Applicant] → [AI Decision: "Ineligible"] → [Appeal] → [Request for Decision Rationale]

↓

"The AI's reasoning is proprietary information."

"Details of the scoring model cannot be disclosed."

↓

The citizen loses all means to contest the decision.

Case 2: Recidivism Risk AI Racial Bias

Criminal justice risk assessment

[Defendant] → [AI Risk Score: "High Risk"] → [Bail Denied / Harsher Sentence]

↓

Post-hoc analysis revealed:

"ZIP code" and "arrest history" were primary factors

→ Effectively using proxies for race and socioeconomic status

↓

No mechanism existed to verify this at the time of the decision.

Case 3: Immigration AI Arbitrary Decisions

Visa application processing

[Visa Applicant] → [AI Review: "Denied"] → [Reason: "Comprehensive Assessment"]

↓

"Which factors were problematic?" Unknown

"What should be improved?" Not indicated

"Will reapplication yield the same result?" Unpredictable

PAP Application Scope

Target systems and recorded events

Target Systems

💳
Credit Scoring
Loan, Credit Card Review
Required
🏛️
Welfare Benefits
Social Security, Unemployment, Disability
Required
🛂
Immigration Control
Visa, Refugee Status, Border Control
Required
⚖️
Judicial AI
Recidivism Risk, Sentencing, Bail
Required
👔
Employment & HR
Hiring AI, Promotion, Termination Risk
Required
🏫
Education & Admissions
Admission Review, Scholarships
Recommended
🏥
Medical Resource Allocation
Organ Transplant Priority, Triage
Recommended

Recorded Event Chain (Causal Chain)

1. Application Receipt
2. Data Collection
3. AI Evaluation
4. Decision Generation
5. Notification
6. Appeal

PAP Architecture

Data flow and system structure

┌─────────────────────────────────────────────────────────────┐
│                  Public Administration System                │
│  ┌──────────┐   ┌──────────┐   ┌──────────┐                │
│  │ Citizen  │──▶│ AI/ML    │──▶│ Decision │                │
│  │ Data     │   │ Scoring  │   │ Output   │                │
│  └──────────┘   └────┬─────┘   └──────────┘                │
│                      │                                       │
│              ┌───────▼───────┐                              │
│              │  PAP Logger   │ ← Records all decision events│
│              │  (Sidecar)    │                              │
│              └───────┬───────┘                              │
│                      │                                       │
└──────────────────────┼───────────────────────────────────────┘
                       │
               ┌───────▼───────┐
               │  Hash Chain   │ ← Cryptographically chained
               │  + Signature  │ ← Digitally signed
               │  + Factor Log │ ← Complete decision factor record
               └───────┬───────┘
                       │
               ┌───────▼───────┐
               │ Audit Archive │ ← Long-term storage
               │ (GDPR-aware)    │ ← Access control
               └───────┬───────┘
                       │
               ┌───────▼───────┐
               │Citizen Portal │ ← Self-information disclosure
               │(Accountability)│ ← Appeal support
               └───────────────┘

Illustrative Event (concept for Track A, which is not drafted)

{
  "event_id": "019234ab-7c8d-7def-8123-456789abcdef",
  "timestamp_ns": 1734567890123456789,
  "event_type": "ELIGIBILITY_DECISION",
  "agency_id": "AGENCY_XXXXX",
  "provenance": {
    "actor": {
      "type": "AI_MODEL",
      "identifier": "benefit_eligibility_v2.3.1",
      "model_hash": "sha256:abc123...",
      "training_date": "2024-03-15",
      "bias_audit_date": "2024-06-01",
      "bias_audit_result": "PASSED"
    },
    "input": {
      "applicant_id_hash": "sha256:applicant_pseudonymized...",
      "data_sources": [
        {"source": "TAX_AUTHORITY", "freshness_days": 30},
        {"source": "EMPLOYMENT_REGISTRY", "freshness_days": 7},
        {"source": "RESIDENCE_REGISTRY", "freshness_days": 1}
      ],
      "input_hash": "sha256:def456...",
      "missing_fields": ["PRIOR_BENEFIT_HISTORY"],
      "imputation_method": "CONSERVATIVE_DEFAULT"
    },
    "context": {
      "applicable_law": "SOCIAL_WELFARE_ACT_2023_SEC_12",
      "policy_version": "2024-Q2",
      "budget_constraint_active": false,
      "human_override_available": true
    },
    "action": {
      "decision": "ELIGIBLE",
      "confidence": 0.89,
      "eligibility_score": 72.5,
      "threshold_applied": 65.0,
      "explainability": {
        "method": "SHAP",
        "top_contributing_factors": [
          {"factor": "income_below_threshold", "contribution": 0.35, "direction": "positive"},
          {"factor": "dependent_children", "contribution": 0.25, "direction": "positive"},
          {"factor": "employment_status", "contribution": 0.20, "direction": "positive"},
          {"factor": "asset_level", "contribution": -0.10, "direction": "negative"}
        ],
        "counterfactual": {
          "if_income_increased_by": 15000,
          "then_decision_would_be": "INELIGIBLE"
        }
      },
      "appeal_rights": {
        "deadline_days": 30,
        "appeal_authority": "ADMINISTRATIVE_TRIBUNAL",
        "required_documentation": ["INCOME_PROOF", "EXPENSE_RECORDS"]
      }
    }
  },
  "prev_hash": "sha256:789xyz...",
  "signature": "ed25519:...",
  "citizen_disclosure": {
    "simplified_explanation": "Your application has been approved. Main reason: You meet income criteria.",
    "full_explanation_available": true,
    "explanation_request_url": "/citizen/explanation/019234ab..."
  }
}

Regulatory Mapping

PAP design targets against selected regulations (draft)

Regulation Jurisdiction Requirement PAP Support
EU AI Act Article 6(2) EU AI systems in the Annex III use cases are high-risk (subject to the Art. 6(3) exceptions) Design target (draft)
EU AI Act Article 13 EU Transparency and provision of information to deployers (the right to an explanation of individual decisions is Art. 86) Design target (draft)
EU AI Act Article 14 EU Human oversight obligation Design target (draft)
GDPR Article 22 EU Right to contest automated decision-making Design target (draft)
GDPR Article 15 EU Right of access (self-information disclosure) Design target (draft)
NYC Local Law 144 NYC Audit obligation for hiring AI Design target (draft)
Illinois BIPA Illinois Biometric information use restrictions Design target (draft)
Administrative Procedure Act Japan Obligation to provide reasons for administrative decisions Planned

GDPR Automated Decision-Making Mapping (Arts. 13–15 and 22; Recital 71)

GDPR Requirement
Notification of automated decision-making existence
PAP design target (illustrative field)
Explicitly stated via event_type
GDPR Requirement
Meaningful information about the logic involved
PAP design target (illustrative field)
explainability.top_contributing_factors
GDPR Requirement
Significance of processing and envisaged consequences
PAP design target (illustrative field)
action.decision + appeal_rights
GDPR Requirement
Right to obtain human intervention
PAP design target (illustrative field)
context.human_override_available
GDPR Requirement
Right to express point of view
PAP design target (illustrative field)
action.appeal_rights
GDPR Requirement
Right to obtain explanation of decision
PAP design target (illustrative field)
citizen_disclosure

EU AI Act Annex III (High-Risk AI) Mapping

Annex III Category Examples PAP Support
Employment and Worker Management Hiring AI, Termination Risk Assessment In planned scope (draft)
Access to Essential Public Services Welfare Benefits, Public Housing In planned scope (draft)
Creditworthiness Assessment Loan Review, Credit Score In planned scope (draft)
Emergency Services Dispatch Ambulance/Fire Priority In planned scope (draft)
Migration, Asylum, Border Control Visa Review, Refugee Status In planned scope (draft)
Justice and Democratic Processes Sentencing support (re-offending risk assessment falls under law enforcement, point 6(d)) In planned scope (draft)

Hiring AI: High-Risk Classification

EU AI Act explicitly classifies resume screening AI as high-risk

🔬

Research Phase

We are currently researching the generalization of verifiable decision audit trails—specified for financial markets (VCP)—to hiring AI domains. No implementation or certification is currently provided for this domain. Across VSO specifications there are zero external implementations and zero Evidence Packs accepted in any proceeding. Commercial disclosure update (24 October 2026): the earlier contract figure is withdrawn pending primary-record verification; this does not establish zero contracts. Details

Legal Basis: EU AI Act Annex III, Point 4(a)

"AI systems intended to be used for the recruitment or selection of natural persons, in particular to place targeted job advertisements, to analyse and filter job applications, and to evaluate candidates"

— EU AI Act (Regulation 2024/1689), Annex III, Point 4(a)

Applicable Requirements for Hiring AI

Article Requirement Hiring AI Application
Article 12 Automatic Logging Automatic recording of events (logs) over the system's lifetime; recording feature weights or rejection reasons is a PAP design target, not an Art. 12 requirement
Article 14 Human Oversight Human reviewers can override AI decisions
Article 19 / 26(6) Log Retention Minimum 6 months retention period
Article 26(7), 26(11) Worker and Candidate Notification Inform workers and their representatives before workplace use (26(7)); inform natural persons that they are subject to the use of a system that makes or assists in decisions about them, such as candidates (26(11))
Article 86 Right to Explanation Candidates can request explanation of AI decisions

Enforcement Timeline

📅
2 December 2027
High-Risk AI Requirements Apply (Annex III)
Hiring AI systems within Annex III must meet the EU AI Act high-risk requirements from this date (deferred from 2 August 2026 by Regulation (EU) 2026/1744)
⚠️
Penalties
Up to €15M or 3% of global turnover
Art. 99(4): non-compliance with operator obligations (e.g. Arts. 16 and 26). The €35M / 7% tier of Art. 99(3) applies only to prohibited practices under Art. 5, not to high-risk obligations

Technical Design Principles

Temporal Fixation (Tiered)

High Assurance
IEEE 1588 PTP + microsecond timestamps
Practical Baseline
NTP/secure time source + millisecond + external timestamping

External Anchoring

Third-party verifiable integrity proofs

Examples: RFC 3161 TSA, public timestamping services, transparency-log style anchoring

Current System Deficiencies

No Decision Rationale Logs

Feature weights and scoring logic are not recorded for individual decisions

Mutable Timestamps

System clock dependent, no external anchoring or cryptographic proof

No Third-Party Verification

Cannot prove non-tampering to external auditors or courts

Algorithmic Bias Countermeasures

Making bias detectable and recording it

Sources of Algorithmic Bias

[Training Data]
Historical discriminatory decisions are included in the data
[Feature Selection]
Proxy variables for protected attributes (ZIP code → race, name → gender)
[Model Training]
Optimized for majority groups, disadvantaging minorities
[Threshold Setting]
Uniform thresholds disproportionately impact certain groups
[Deployment]
Performance degradation on new populations (drift)

Bias-Related Records (design targets; not drafted)

bias_audit_date / bias_audit_result recording
Decision distribution tracking by protected attribute
Monitoring proxy variable contributions
Counterfactual analysis recording
Temporal performance monitoring

Fairness Metrics Recording

Demographic Parity
Same approval rate across groups
Illustrative field (not in any PAP draft): group_approval_rates
Equalized Odds
Equal TPR/FPR across groups
Illustrative field (not in any PAP draft): group_tpr_fpr
Calibration
Predicted probability matches actual outcome
Illustrative field (not in any PAP draft): calibration_by_group
Individual Fairness
Similar individuals receive similar decisions
Illustrative field (not in any PAP draft): similarity_scores

Citizen Accountability

Transparency portal and multi-layered explanation model

🏛️ Citizen Transparency Portal (illustrative concept — not defined in any PAP draft)

🔍 Self-Information Disclosure
  • • What data was used about me?
  • • From which sources was it obtained?
  • • How current was the data (freshness)?
📊 Decision Explanation
  • • Why was this decision made? (Top factors)
  • • Which factors were positive/negative?
  • • How does my score compare to the threshold?
🔄 Counterfactual Simulation
  • • "If my income was ¥X more, would the result change?"
  • • "What conditions would I need to meet for approval?"
⚖️ Appeal Support
  • • Appeal deadline and procedures
  • • Required documentation
  • • Statistics on similar past cases

Multi-Layered Explanation Model

Layer Target Audience Explanation Detail
Citizen General applicants Plain language summary (simplified_explanation)
Representative Lawyers, advocates Detailed decision factors and contributions
Auditor Regulators, audit firms Model specs, training data, bias audit results
Technical AI developers, researchers Complete logs, model hashes, reproduction steps

Use Cases

Practical scenarios for PAP application

🏛️ Scenario: Welfare Benefits Appeal

Phase Without PAP With PAP
Denial Notice "Ineligible based on comprehensive assessment" "Income criteria met, but assets exceeded threshold"
Reason Inquiry "Details cannot be disclosed" All decision factors viewable via citizen portal
Appeal Preparation Unclear what to contest Can specifically point out "asset valuation error"
Administrative Review Dismissed due to insufficient evidence PAP evidence makes the asset valuation logic issue verifiable
Outcome Resignation Appeal decided on verifiable records (PAP does not determine the outcome)

👔 Scenario: Hiring AI Audit (NYC Local Law 144)

[Company] → [Annual hiring AI audit obligation]

↓

PAP Evidence-Based Audit
  • • Selection pass rates by gender and race
  • • Contribution analysis of each decision factor
  • • Proxy variable impact assessment
  • • Counterfactual analysis for fairness verification

↓

[Publication of audit report] → [Audit evidence retained]

⚖️ Scenario: Judicial AI (Recidivism Risk) Post-Verification

[Defendant] → [AI Risk Score: "High Risk"] → [Harsher sentence]

↓

[5-year follow-up study]

↓

PAP Evidence Verification
  • • Complete reconstruction of decision factors at the time
  • • Compare predicted vs actual recidivism rates
  • • Analyze prediction accuracy by group
  • • Statistical verification of bias existence

↓

[System improvement / Basis for reviewing past judgments]

Privacy Protection & Data Minimization

Balancing transparency and privacy

The Dilemma

"We want to record everything for accountability"

↕

"We want to minimize data for GDPR/privacy"

PAP's Solutions

1 Data Minimization
  • • Collect and record only minimum data needed for decisions
  • • Protected attributes not directly recorded; only aggregated for fairness monitoring
2 Pseudonymization
  • • Personal identifiers recorded as hashes
  • • Reverse lookup only under strict access control
3 Crypto-Shredding
  • • When right to erasure is exercised: destroy encryption key
  • • Hash chain maintained (audit integrity preserved)
  • • Personal data becomes unreadable
4 Differential Privacy
  • • Add noise to aggregate statistics
  • • Enable bias monitoring without identifying individuals

Technical Specification Summary

Key technical parameters

Item PAP design target (not drafted)
Timestamp Precision Seconds to milliseconds (depending on use case)
Event Recording Frequency Per decision event
Hash Algorithm SHA-256
Signature Algorithm Ed25519 (Dilithium support planned)
Personal Data Protection AES-256-GCM encryption + Crypto-Shredding
Retention Period Per legal requirements (typically 5-10 years, longer for judicial)
Citizen Access Self-information disclosure via portal
Bias Audit Periodic fairness metric calculation and recording

Roadmap

PAP development timeline — no dates set for the remaining steps; PAP is currently a Partial Draft (Track B v0.2.0 only; no consolidated specification), and the later milestones have not been reached

Partly done
Track B (Investigative-Decision Vocabulary) drafted at v0.2.0; consolidated PAP draft specification not yet written
Planned — no date set
Technical Validation with Government Agencies and Municipalities
Planned — no date set
Information Briefing to EU AI Office and National Data Protection Authorities
Planned — no date set
PAP v1.0 Official Release
Planned — no date set
NYC Local Law 144 and EU AI Act Compliance Guidance Published
Planned — no date set
Collaboration with OECD, United Nations, and International Organizations

Relationship with VAP/VSO

Framework hierarchy and profile positioning

┌────────────────────────────────────────┐
│  VAP (Verifiable AI Provenance)        │
│  Cross-domain parent framework         │
└──────────────────┬─────────────────────┘
                   │
┌──────────────────▼─────────────────────┐
│  VSO (VeritasChain Standards Org)      │
│  Standards organization                │
└──────────────────┬─────────────────────┘
                   │
     ┌──────┬──────┼──────┬──────┐
     ▼      ▼      ▼      ▼      ▼
  [VCP]   [DVP]  [MAP]  [EIP]  [PAP]
  Finance Auto   Medical Energy Public
    ↓                            ↓
  v1.2                     Partial Draft
Released

Differences from Other VAP Profiles

Characteristic VCP (Finance) MAP (Medical) DVP (Automotive) EIP (Energy) PAP (Public)
Impact Speed Milliseconds Minutes-Hours Seconds Minutes-Days Months-Years
Reversibility Partial Irreversible Irreversible Slow Recovery Difficult
Primary Victim Investors Patients Occupants/Pedestrians Citizens Individual Rights
Regulatory Focus Market Integrity Patient Safety Physical Safety Continuity Democracy
Appeal Rights Limited Limited Limited Limited Required

Get Involved

PAP is currently a Partial Draft (Track B v0.2.0 only; no consolidated specification). We welcome participation from government agencies, municipalities, human rights organizations, and AI ethics researchers.

"Power without explanation is the enemy of democracy. AI is no exception."

— VeritasChain Standards Organization

"The right to an explanation is the foundation of due process in the algorithmic age."

This specification is licensed under CC BY 4.0 International

Provider: VeritasChain Standards Organization (VSO) | https://veritaschain.org