For Supervisors

Governance that cannot be verified is the supervisory perimeter.

53.3%
Agents where DORA Art 28 third-party identity is unobservable
46.2%
Agents where DORA Art 11 halt mechanism is unobservable
9.1%
Agents where EU AI Act Art 14 oversight class is unobservable

DORA Article 28 and EU AI Act Article 14 establish parallel demands. Both require institutions to verify the governance posture of the AI systems they deploy or depend on. Both are necessary for a supervisory standard that does not collapse into trust. The Meridian substrate measures, across 95,876 AI agents at 543 regulated financial institutions, the share of governance evidence that is externally unobservable for each regulatory dimension. The pattern is sharp. Third-party ICT risk under DORA Article 28 cannot be externally verified for 53.3 percent of agents because the vendor relationship is not disclosed. ICT business continuity under DORA Article 11 is unobservable on halt mechanisms for 46.2 percent. Human oversight under EU AI Act Article 14 is unobservable for 9.1 percent. The substrate distinguishes "not detected" from "not present" through the four-state evidence taxonomy. Supervisors require both distinctions; neither is currently produced by self-reporting alone.

Figure 1 · External Unobservability by Regulatory Dimension
SHARE OF 95,876 AGENTS WHERE THE NAMED EVIDENCE IS UNOBSERVABLE 0% 10% 20% 30% 40% 50% 60% DORA Art 28 third-party ICT risk 53.3% unobservable DORA Art 11 ICT business continuity 46.2% unobservable EU AI Act Art 14 human oversight 9.1% unobservable EU AI Act Art 11 technical documentation 4.9% unobservable DORA Art 5 ICT-relevance designation 1.5% unobservable GDPR Art 22/35 automated decision data 0.0% unobservable What cannot be verified externally is the supervisory perimeter. MAR®500.com

Each bar measures the share of 95,876 agents in the v13.1.0 sealed substrate where the named regulatory evidence is unobservable from public sources. Unobservability includes both the absence of evidence and the absence of state-knowledge under the four-state taxonomy. The two states are operationally distinct: the substrate distinguishes between "the institution discloses no halt mechanism" and "we cannot verify whether the institution has a halt mechanism." For supervisory purposes both states are non-compliant under a verifiability standard, but only the second is correctable through institutional disclosure. The narrowest dimensions, GDPR Article 22 data sensitivity and DORA Article 5 ICT-relevance designation, are below 5 percent unobservable across the population.

Source · Meridian substrate v13.1.0, May 2026 · Per-dimension unobservability rates from agent-level evidence states 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. Findings cross-reference Coase Inversion (SSRN 6470098), Credit Ratings (SSRN 6524438), Cascade Without Containment (working paper), and Systemic Governance Risk (SSRN 6535599).