The Compliance Gap

Each regulatory requirement, met or unmet at the agent level.

4
Regulatory regimes mapped to substrate-level evidence
7
Discrete supervisory requirements decomposed
46%
Mean unobservability across DORA articles

DORA, the EU AI Act, MiFID II, and GDPR each impose a discrete supervisory requirement on the AI agent estate of regulated financial institutions. The substrate decomposes each requirement into the specific evidence that an external supervisor would need to verify compliance. Where the evidence is structurally unobservable from public sources, the institution is non-compliant under a verifiability standard regardless of any internal documentation it may hold. The two largest gaps are DORA Article 28 (third-party identifiability) at 53.3 percent and DORA Article 11 (ICT business continuity, halt mechanism) at 46.2 percent. MiFID II RTS 6 algorithmic trading control documentation tracks the same evidence as Article 11 and carries the same gap. The narrower gaps under EU AI Act Articles 11 and 14 reflect the regulation's more granular disclosure requirements; the architecture of the AI Act builds external observability into compliance from inception.

Figure 1 · Compliance Gap Matrix on v13.1.0 Substrate
REGULATION · REQUIRED CAPABILITY · SHARE UNOBSERVABLE ON v13.1.0 DORA Art 28 Third-party ICT vendor identifiability 53.3% DORA Art 11 ICT business continuity (halt mechanism) 46.2% MiFID II RTS 6 Algorithmic trading control documentation 46.2% EU AI Act Art 14 Human oversight classification 9.1% EU AI Act Art 11 Technical documentation (high-risk class) 4.9% DORA Art 5 ICT-relevance designation 1.5% GDPR Art 22/35 Automated-decision data sensitivity 0.0% Each row is a supervisory requirement met or unmet at the agent level. MAR®500.com

Each row decomposes a discrete regulatory requirement into the agent-level evidence required to verify compliance externally. The bar measures the share of 95,876 agents in the v13.1.0 sealed substrate at which the named evidence is unobservable from public sources. Severity coding reflects the supervisory weight typically assigned to each requirement: DORA Article 28 and Article 11 are coded as high-severity gaps, EU AI Act Articles 11 and 14 as moderate, DORA Article 5 as low, and GDPR Articles 22 and 35 as minimal because data sensitivity is near-universally observable. The matrix is computed on v13.1.0 evidence only; institutional self-reporting may close some gaps inside the institution.

Source · Meridian substrate v13.1.0, May 2026 · Per-regulation requirement decomposition; substrate-level evidence rates Methodology · Stationary Sea Part 1 (Zenodo)
543 institutions · 12 sectors · 95,876 agents · 636,854 governance edges · substrate v13.1.0
Methodology grounded in The Stationary Sea (Part 1) on Zenodo. The compliance gap framework draws on Cascade Without Containment (working paper).