Pillar 14: AI Assurance & Testing

Control question: Do the controls actually hold? Surface: proves the boundedness of See, Decide, and Do.


Purpose

A control that has never been tested is a claim, not a control. This pillar makes control strength provable: it requires that a use case's controls be tested proportionate to its tier, that high-impact and autonomous use cases face adversarial testing, and that results are retained as evidence and re-run when the use case changes. It is how a boundary moves from declared or evidenced to verified.


Why it matters

AI controls fail quietly. A data boundary looks configured but leaks under a certain query; an injection filter blocks the obvious cases and misses the crafted one; an action allow-list is bypassed through an unexpected tool path. None of this shows up until someone looks, deliberately, adversarially, before an incident does the looking for you. Assurance is the pillar that turns "we have controls" into "we have tested controls," and it is the difference between a architecture that documents intentions and one that can survive its own show-me.


Control objectives

  • Test controls before go-live: proportionate to tier.
  • Subject high-impact and autonomous use cases to adversarial testing of input, output, and action controls.
  • Retain results as evidence and re-run on material change.

Requirements

From the Requirements Catalogue:

ID Requirement From Boundary
ACA-14-01 Controls are tested before go-live, proportionate to tier. T3 Verified
ACA-14-02 High-impact and autonomous use cases undergo adversarial testing of input, output, and action controls. T5 Verified
ACA-14-03 Test results are retained as evidence and re-run on material change. T3 Verified

Key controls

  • Control test plan: for each in-scope control, a defined way to test that it holds, and the expected result (see the AI Assurance Test Plan template).
  • Pre-go-live gate: controls are tested before a decision-supporting or higher use case is allowed live; failures block or tier-down.
  • Adversarial / red-team testing: for high-impact and autonomous use cases, actively try to break input, output, and action controls (prompt injection, boundary escape, unauthorized action) rather than only confirming happy paths.
  • Regression on change: model updates, new tools, new data sources, or scope changes re-trigger the relevant tests; a control verified last quarter is not assumed to hold today.
  • Evidence capture: results are recorded as the verified boundary evidence the other pillars point to.

The how-to for running assurance and audit lives in the operating guide (Assurance & Audit Guide); this pillar defines what assurance is required.


Tier guidance

  T1 T2 T3 T4 T5
Pre-go-live control test - Recommended Required Required Required
Adversarial testing - - - Recommended Required
Retain results as evidence - - Required Required Required
Re-test on material change - - Required Required Required

Evidence

The AI Assurance & Testing template and AI Assurance Test Plan template capture the test plan, execution, and results. This pillar is what produces the Verified boundary source that pillars 08–12 rely on, assurance is how their controls earn that grade.


Standards crosswalk

Maps to NIST AI RMF Measure, ISO/IEC 42001 (verification, validation, performance evaluation), EU AI Act (testing, accuracy, robustness, Arts. 9, 15), and SR 11-7 (model validation and effective challenge). See mappings/.


Failure modes

  • Controls documented but never tested, claims dressed as controls.
  • Happy-path testing only; no adversarial attempt to break them.
  • A model or tool change that silently invalidates a previously verified control.
  • Test results that exist but were never captured as evidence.

Next: 15 · Monitoring, Logging & Evidence

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