What federal policy already asks for, in its own words.
The government already asks to monitor, review and keep what its AI systems do. Today it does that through the operator's own records.
NIST is already asking it.
NIST's National Cybersecurity Center of Excellence asks in a February 2026 draft: “How can we ensure that agents log their actions and intent in a tamper-proof and verifiable manner?”1
For what an agent did, the record is one answer. It is written as the agent acts, committed where no one can change it, PacSpace included, and checkable by anyone given the link.
Monitoring, accountability and traceability.
“Agencies must ensure human oversight, intervention, and accountability suitable for high-impact use cases.”
Where each action and each approval is written as it happens, whether an approval was recorded before the system acted is on the record for oversight to check.
“Contractual terms must provide the contracting agency the ability to regularly monitor and evaluate” an AI system's performance, risks and effectiveness.
The agency monitors from a record it can check itself: what the system did, unchanged since it was committed, opened from a link the contract can require, with no data call each time.
“transparent and auditable methodologies, data sources, and design procedure and documentation”
Each output can carry the model version and settings the operator recorded, so the version recorded in the field can be checked against the version recorded at test.
Scope: OMB's two memos do not cover AI used as a component of a National Security System, and M-25-21's minimum practices do not apply to the intelligence community. What this page doesn't claim
Audit information anyone can check for changes.
“Protect audit information and audit logging tools from unauthorized access, modification, and deletion”
A committed record can't be modified by anyone, PacSpace included, and a modified copy fails the check. Access to your logs, and their deletion, stay with your system's own controls.
“Use multiple independent monitoring systems that cross-validate agent reports and system logs.”
A cross-check needs one account the agent can't reach: what was committed as it acted. Your monitoring raises the alarm. The record gives it a signal the machine can't erase. The change shows.
Records that last past the work.
Contractors must make records, including computer data, available for audit for “3 years after final payment”.
Any copy kept for audit still checks against what was committed, after final payment and after the contract changes hands.
Federal records include “Audit trails an agency captures and uses to conduct official business, such as investigations.”
The agency keeps its own copy of a record and can check it against what was committed for as long as its schedule keeps it.
The record answers part of each rule, never the whole of it.
PacSpace is not a compliance product and doesn't make a system compliant or authorized. What a record satisfies on a given system is for the program, its assessor and its counsel.
OMB's two memos do not cover AI used as a component of a National Security System, and M-25-21's minimum practices do not apply to the intelligence community. The controls, the records rules and the guidance on AI agents each say where they apply.
The operator still chooses what to write, the same limit every log has. What it gives up is changing the record afterward. If writing stops, the gap shows: the records on either side put a start and an end on it.
Sources
- NIST NCCoE, “Accelerating the Adoption of Software and AI Agent Identity and Authorization”, draft concept paper, Feb 2026.
- OMB, M-25-21, “Accelerating Federal Use of AI through Innovation, Governance, and Public Trust”, Apr 3, 2025.
- OMB, M-25-22, “Driving Efficient Acquisition of Artificial Intelligence in Government”, Apr 3, 2025.
- Department of Defense, AI Ethical Principles, adopted Feb 2020.
- NIST, SP 800-53 Rev. 5, AU-9, Protection of Audit Information.
- NIST, SP 800-171 Rev. 2, 3.3.8.
- 32 CFR 170.14, CMMC Level 2.
- ASD's ACSC, CISA, NSA and partners, “Careful adoption of agentic AI services”, May 2026.
- FAR 4.703, as revised in the FAR overhaul.
- NARA, AC 11.2026, “Guidance on Applying the Federal Records Act to Artificial Intelligence Materials”, Aug 21, 2026.
Bring the case you think breaks it.
We would rather be evaluated by use than by description. Talk to us and we'll put you in a live environment: commit a record, do your best to change it, then check it yourself, with us out of the loop. The change shows.
The record must exist.