Draft for public comment · v0.1 · May 2026

The open standard for AI agent auditability

AAS-1 defines an evidentiary record format and a set of standard assertions that allow an independent reviewer — human or agent — to form assurance opinions about the activity of autonomous AI agents.

The AAS-1 Audit Manual provides the engagement procedures practitioners follow when applying the standard — from pre-engagement scoping through to issuing the Class D Determination.

CC0 — no rights reserved
JCS · RFC 3339 · AIS-1
Continuous attestation supported
Open for comment until 31 July 2026

What is AAS-1?

AAS-1 is an open standard for producing audit-grade evidence about agent activity. It defines a record format, five record classes, and twelve standard assertions that allow auditors to evaluate agent actions against the same rigor applied to human-controlled processes.

The standard addresses what we call the Unauditable Agent Problem: autonomous agents are now executing transactions, making decisions and producing outputs at scale, yet the records they leave behind are platform-specific, unstructured and not designed for assurance. AAS-1 defines a portable evidentiary format, anchored to AIS-1 identities, that any auditor can evaluate.

At its core AAS-1 is a relationship between two parties — the agent emits a Class A record per action; the auditor emits a Class D opinion in response. Class B and Class C aggregate Class A for sampling; Class E wraps the engagement. The diagram shows the actor-output pair at the heart of the standard.

Class A — Action Record

Agent Action

  • Event ID (ULID)
  • Agent ref (AIS-1 DID)
  • Principal ref
  • Action type & hashes
  • Tools & model
  • Policy refs & result
  • Timestamp service
  • Signature
Evidence · Attestation
Class D — Determination

Auditor Finding

  • Auditor ref (AIS-1 DID)
  • Engagement ref
  • Subject records
  • Per-assertion result
  • Finding type
  • Materiality basis
  • Timestamp service
  • Signature
Canonicalisation: RFC 8785 (JCS) Hashing: SHA-256 default Identity binding: AIS-1

Without AAS-1

  • Agent actions are unauditable — no standard evidence format
  • Each platform invents its own logging; no portability between auditors
  • Auditors lack tools to verify the actor or the authority for the action
  • Continuous assurance is impossible at agent speeds
  • Regulators cannot map agent activity onto existing audit frameworks

With AAS-1

  • Every agent action emits a portable, attestable evidentiary record
  • Twelve standard assertions auditors evaluate against in any engagement
  • AIS-1 binding gives cryptographic verification of the actor and authority
  • Class C streaming enables continuous and real-time assurance
  • Records map cleanly onto ISA, ISAE 3000-series and SOC frameworks

The AAS-1 Audit Manual has been prepared to assist practitioners in applying the standard — see the Audit Manual section below for details.

Five record classes. One spine.

A complete audit trail typically comprises many Class A records, organised by Class B or Class C aggregations, evaluated against a Class E engagement, and concluded with Class D determinations. Each class shares the core identity, evidence and signature primitives.

Class A

Action

A single agent action with evidence. The atomic unit. Captures actor, principal, action type, hashed inputs and outputs, tools, model and signature.

Issuer: agent / operator
Class B

Batch

Aggregation of Class A records over a defined period. Carries a Merkle root over the canonicalised members and the standard identity and signature primitives.

Issuer: operator
Class C

Continuous

A single entry within a continuously attested stream. Bound to a separate stream-anchor record. Designed for high-frequency or always-on agents.

Issuer: operator · v0.2
Class D

Determination

An auditor's finding, opinion or exception over a set of subject records. Records per-assertion results and an overall finding type.

Issuer: auditor
Class E

Engagement

Audit engagement metadata: scope, period, applicable framework, materiality threshold, the agent population in scope and engagement letter hash.

Issuer: auditor

Twelve assertions. One evaluation pass.

AAS-1 records support seven assertions adapted from established audit frameworks (ISA 315/330, AICPA AU-C, ISAE 3000), plus five assertions specific to autonomous agents. An auditor — human or agent — evaluates every assertion in a single pass before issuing a Class D determination.

// Auditor verification flow — evaluating an AAS-1 Class A record

const record   = await aas1.fetch(eventId);
const identity = await ais1.resolve(record.agentRef);

const findings = await auditor.evaluate(record, {
  identity,
  assertions: AAS1.ALL_ASSERTIONS,
  policies:   record.policyRefs
});

// Returns per-assertion findings:
//   existence       'satisfied' | 'modified' | 'exception'
//   completeness    ...
//   accuracy        ...
//   identity        ...   (AIS-1 binding)
//   provenance      ...   (model, tools, prompt context)
//   reproducibility ...

if (findings.allSatisfied) {
  await auditor.issueClassD({ finding: 'unmodified', ... });
} else {
  await auditor.issueClassD({ finding: 'modified', exceptions: ... });
}
01 · CLASSICAL
Existence
The recorded action actually took place.
02 · CLASSICAL
Completeness
All relevant actions in scope are recorded.
03 · CLASSICAL
Accuracy
Inputs and outputs are faithfully captured.
04 · CLASSICAL
Authorisation
The agent acted within delegated authority.
05 · CLASSICAL
Cutoff
Recorded in the correct period.
06 · CLASSICAL
Classification
Correctly categorised by action type.
07 · CLASSICAL
Presentation
Records are presented and described accurately.
08 · AGENT-SPECIFIC
Identity
The recorded actor is the agent of record (AIS-1 binding).
09 · AGENT-SPECIFIC
Provenance
Model, tools, prompt context and data sources captured.
10 · AGENT-SPECIFIC
Reproducibility
Sufficient state to permit re-derivation.
11 · AGENT-SPECIFIC
Policy Compliance
Applicable policies and compliance result recorded.
12 · AGENT-SPECIFIC
Independence
Agent action separated from operator override.

What is the Audit Manual?

The Audit Manual is the operational companion to the specification. Where the spec defines what AAS-1 records are, the manual sets out how an auditor receives them, evaluates them, and issues an opinion. It is the practitioner's playbook for conducting an AAS-1 Class D Determination.

A specification on its own would leave every auditor inventing their own procedures from the spec text. The manual closes that gap. It walks through pre-engagement scoping, receiving and validating the record population, the per-record verification flow, detailed procedures for each of the twelve assertions, sampling methodology for large populations, and the form of the Class D Determination itself. A worked example over the PayAgent USDC transfer shows the procedures applied end-to-end.

This makes AAS-1 immediately deployable rather than aspirational. An auditor can pick up the manual, follow the procedures, and conduct an engagement without further interpretation. The first AAS-1 engagement — over PayAgent's Q2 2026 records — is being conducted to this manual; subsequent engagements use it as the standard reference.

Section 2

Pre-engagement

Define the Class E engagement: scope, period, applicable framework, materiality threshold, agent population. The on-record equivalent of an engagement letter, signed by both parties.

Class E setup
Section 3

Population validation

Receive the records (pull from registry, batch push, or continuous stream). Walk the prevHash chain, recompute Merkle roots, reconcile counts against external statements.

Receipt + verify
Section 4

Verification flow

Per-record technical checks: resolve the AIS-1 identity, validate the signature, verify the independent timestamp, recompute hashes against source data where accessible.

4 phases
Section 5

Twelve assertions

Detailed auditor procedures for each of the seven classical and five agent-specific assertions. Definitions, fields supporting evaluation, step-by-step procedures, common exceptions.

12 procedures
Sections 6–8

Sampling & determination

Sampling methodology for batch and continuous populations. Findings catalogue mapping common issues to finding types. Issuing the Class D — fields, signature, publication.

Class D output
§9 + Apps A–C

Worked example + templates

Full evaluation walkthrough on the PayAgent USDC transfer. Class D determination template, engagement letter template, working-paper checklist for the auditor.

PayAgent + forms
Read the audit manual →

From draft to deployed standard.

MAY 2026

AAS-1 v0.1 published

Specification, audit manual, JSON Schema for Class A and worked PayAgent example published under CC0. Open for public comment until 31 July 2026.

Live
Q3 2026

v0.2 — Schemas for B, C, D, E

Class B/D/E schemas finalised. Class C continuous-stream semantics defined. Materiality methodology annex. Mapping table to ISA 315/330. First DABA Class M and SOC 2 profiles drafted.

Q3 2026
Q4 2026

First production audit using AAS-1

PayAgent emits Class A records over a 90-day period. An independent reviewer issues a Class D determination. The full evidentiary chain — including the AIS-1 identity binding — is published as a reference engagement.

Q4 2026
2027

Standardisation track

Submission to IFAC and ISO/IEC JTC 1. Conformance test suite. Reference adapters for major audit-tooling platforms. Integration with continuous-assurance pipelines and agent-commerce settlement (Clavus, x402).

2027

Specification and supporting materials.

AAS-1 v0.1 is a draft for comment.

Feedback is invited from auditors, agent developers, blockchain engineers, legal and regulatory professionals, enterprise AI deployers, standards organisations and government bodies. The comment period closes 31 July 2026. A revised v0.2 will incorporate substantive feedback.

We are looking for:

Review of the assertion catalogue from practising auditors · feedback on the Class A schema and evidence types · proposed regulatory profile mappings (DABA, SOC 2, ISAE 3402, statutory audit) · input on Class C continuous-streaming semantics · proposals for authorised reference implementations · real-world engagement use cases.