Compliance

Built for the human-oversight era.

Regulators now expect a human in the loop before automated systems act — and evidence that oversight happened. Proof Holdings is designed to support both: approvals on channels people actually answer, recorded as signed, offline-verifiable tokens.

Proof Holdingsproof.holdings · oversight record
Oversight RecordNº 2026-0014
subjectAdverse credit decision · applicant #4471
systemcredit-model v3 — solely automated
controlhuman review required before the decision takes effect
approver · on the record+370 691 •• •99 · via WhatsApp · 14:02:07 UTC
tokendecision + time + request hash · ES256
authorityEU AI Act Art. 14 · GDPR Art. 22
verdictOversight recordedthe review itself is signed — not a screenshot
Minted
action · ES256 ✓

The regulatory docket

The dates your roadmap already lives under

34+ jurisdictions, one direction: people must be told, and be able to reach a human, when an automated decision affects them — and some now require a record that it happened.

  1. In force
    EU
    GDPR · Art. 22

    A person may not be subject to a solely automated decision with legal or similarly significant effect — where the decision rests on a contract or consent, human intervention must be available on request.

    Source: Regulation (EU) 2016/679, EUR-Lex

  2. In force
    UK
    UK GDPR · Arts. 22A–22D

    The Data (Use and Access) Act replaced Article 22 on 5 February 2026: significant automated decisions are permitted, but safeguards are mandatory — people must be able to obtain human intervention, make representations, contest the decision, and get information about it.

    Source: Data (Use and Access) Act 2025, s. 80, legislation.gov.uk

  3. In force
    US
    NYC Local Law 144

    Automated employment decision tools require an independent bias audit and advance notice to candidates — an automated decision alone is not enough.

    Source: Automated Employment Decision Tools, NYC Department of Consumer and Worker Protection

  4. In force
    CH
    Swiss FADP · Art. 21

    Switzerland’s revised data protection law: automated individual decisions must be disclosed, and the person can ask for the decision to be reviewed by a human.

    Source: Federal Act on Data Protection (SR 235.1), Fedlex

  5. In force
    KR
    Korea PIPA · Art. 37-2

    South Korea’s privacy law grants the right to refuse, or demand a human explanation of, fully automated decisions that significantly affect a person.

    Source: Personal Information Protection Act, Korea Law Information Center

  6. In force
    US
    Utah AI Policy Act

    Consumers must be told they are interacting with generative AI when they ask; in regulated occupations, upfront only for high-risk interactions.

    Source: Utah Code § 13-77-103, Utah Legislature

  7. In force
    JP
    Japan AI Promotion Act

    Japan’s first AI law sets a light-touch national governance baseline — a duty for businesses to cooperate with national measures, and transparency expectations, with no penalties.

    Source: Act No. 53 of 2025, Japanese Law Translation (Ministry of Justice)

  8. Guidance
    SG
    Singapore Model AI Framework

    Singapore’s PDPC framework recommends choosing how far a human stays involved (in, over or out of the loop) by the likelihood and severity of harm. Not binding — but the governance reference point for the region.

    Source: Model AI Governance Framework, 2nd ed., PDPC

  9. In force
    KR
    Korea AI Basic Act

    Korea’s AI Basic Act (in force 22 January 2026) imposes duties on high-impact AI — employment, loans, healthcare and more — including risk management, explainability, and human-oversight mechanisms.

    Source: Framework Act on Artificial Intelligence (Act No. 20676), Korea Law Information Center

  10. In force
    EU
    EU AI Act · Art. 50

    Transparency obligations apply: people must be told when they interact with an AI system, and AI-generated content must be disclosed (systems already on the market before 2 August 2026 have until 2 December 2026 for the marking).

    Source: Regulation (EU) 2026/1744 amending Regulation (EU) 2024/1689, EUR-Lex

  11. Dec 2026
    AU
    Australia Privacy Amendment

    Australia’s Privacy Act amendments require privacy policies to disclose automated decisions that significantly affect individuals — transparency first, with broader reform still moving.

    Source: APP 1.7–1.9 transparency obligation fact sheet, OAIC

  12. Jan 2027
    US
    Colorado AI Act · revised

    Colorado repealed and replaced its 2024 act (SB 26-189, May 2026): deployers of automated decision-making technology must give clear notice, explain adverse outcomes, and offer meaningful human reconsideration of consequential decisions.

    Source: SB26-189, Colorado General Assembly

  13. Dec 2027
    EU
    EU AI Act · Art. 14

    Human oversight becomes mandatory for high-risk AI systems: humans must be able to understand, intervene in, and override the system (Annex III systems; Annex I systems from 2 August 2028 — deferred from 2026 by the Digital Omnibus, Regulation (EU) 2026/1744).

    Source: Regulation (EU) 2026/1744 (Digital Omnibus on AI), EUR-Lex

Sources, checked 25 October 2026: the law text or the regulator’s or legislature’s own page for each row.

Why this matters now

The strictest texts ask for two things

Requirement 01

A human able to intervene before the system acts.

Proof of Action delivers the approval on the channels people already answer — Telegram or WhatsApp — so the checkpoint happens in seconds, not in the next sprint. A queue nobody opens is oversight on paper only.

Requirement 02

Evidence that the oversight actually happened.

Every decision mints a signed ES256 token: approve or deny, and when, bound to the encrypted request. Who answered is kept on the record beside it. An auditor verifies the token offline against our published JWKS: no Proof Holdings account, no API key, no trust in screenshots.

How Proof Holdings maps to the obligations

Every obligation, an instrument you can hand an auditor

No vendor hands you compliance. What we issue is the oversight mechanic and the signed evidence trail the rules keep asking for.

Human oversight & intervention

EU AI Act Art. 14 · GDPR Art. 22 · Colorado

Human-in-the-loop approval gates before irreversible actions, on channels people answer.

action · ES256 ✓
Proof of Action

Supply-chain & agent authority

NIS2 Art. 21(2)(d) supply chain · agent authority

Signed, scoped, revocable statements of which agents, packages and endpoints a domain you control authorized.

delegation · ES256 ✓
Proof of Delegation

Demonstrable audit trail

EU AI Act Art. 12 record-keeping · accountability

Signed ES256 tokens for every decision — verifiable offline via the public JWKS, holdable for years.

action · ES256 ✓
Proof of Action

Put a human in the loop this week

Your first approval gate is one API call — and every decision after it leaves a signed token you can show an auditor.

Product positioning, not legal advice. Consult your counsel on how these rules apply to you.