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Agent OS
AOS-LEGAL-004 Counsel-review engineering framework

Regulatory and Certification Roadmap

Regulatory and Certification Roadmap: scope, decisions, requirements, evidence, risks, and traceability for the Agent OS programme.

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Regulatory and Certification Roadmap

This document is an engineering issue map for qualified counsel and compliance specialists; it is not legal advice or a substitute for jurisdiction-specific review.

Table of Contents

Purpose and Scope

Area: Legal and Compliance.

This document is an engineering issue map for qualified counsel and compliance specialists; it is not legal advice or a substitute for jurisdiction-specific review.

This document owns the semantics implied by Regulatory and Certification Roadmap. It does not assert that every described subsystem already exists. It defines the target model, constraints, evidence needed to trust an implementation, and the boundary with adjacent documents.

Normative Position

  1. Represent nine chronological execution phases separately from ten thematic documentation volumes.
  2. Schedule evidence gates and dependency edges, not only activity dates.
  3. Keep tracker state derived from repository CSV plus API reconciliation; no critical decision exists only in Linear or GitHub.

Operating Model

The operating model is contract-first and evidence-driven. A component declares its authority, resources, lifecycle, error model, cancellation and timeout behavior, observability, version, and compatibility promise. Backends are replaceable only when the same conformance suite passes and no forbidden platform type leaks into portable layers.

Implementation proceeds through a reference model or mock, deterministic QEMU evidence where relevant, documentation-first physical hardware, and quality-hardware evidence. Pixel 9 adapters remain quarantined according to ADR-0004.

Requirements

  • R01. Represent nine chronological execution phases separately from ten thematic documentation volumes.
  • R02. Schedule evidence gates and dependency edges, not only activity dates.
  • R03. Keep tracker state derived from repository CSV plus API reconciliation; no critical decision exists only in Linear or GitHub.
  • R04. Specify normal, partial, denied, timeout, cancellation, restart, upgrade, and permanent-failure behavior.
  • R05. Expose structured diagnostics without leaking secrets or vendor-specific implementation details.
  • R06. Link material unknowns to a claim and, when testable, an experiment with an owner and gate.
  • R07. Update affected documentation and task data when evidence changes the model.

Failure and Degradation

Degradation must be explicit rather than accidental. The system reports capability absence, reduced quality, unavailable provider, stale data, or unsafe condition through typed states. It must not silently fall back to broader authority, unrestricted legacy execution, unverified firmware, lossy data migration, or irreversible agent action.

Recovery defines what state is retained, reconstructed, re-enrolled, compensated, or intentionally discarded. Unsupported hardware or providers are rejected at binding time where possible.

Evidence and Acceptance

  • Acyclic task graph.
  • Milestone and dependency reconciliation.
  • Monthly evidence, risk, spend and decision review.
  • Evidence records target identity, hardware revision, firmware, source commit, toolchain, configuration, seed, timestamps, artifacts, expected result, actual result, and reviewer.
  • Acceptance requires the referenced tasks to meet their own criteria; prose completion is not implementation completion.

Implementation Obligations

Task Obligation Priority Gate/Milestone Verification
AOS-CELL-003 Commission lawful cellular test environment P1 M4 controlled registration/data/SMS test and emergency-path tabletop with counsel/lab guidance
AOS-CELL-042 Define emergency-calling safety boundary before voice work P0 M9 tabletop and accredited/operator consultation without live unauthorized emergency calls
AOS-CELL-052 Build cellular certification and carrier engagement plan P1 M9 authorized lab and module vendor review; compare at least two market routes
AOS-LEGAL-010 Build regulatory and certification market matrix P1 M3 regulatory counsel and accredited-lab consultation
AOS-LEGAL-013 Obtain certification laboratory architecture consultation P1 M9 written lab response reviewed by hardware, cellular, security and legal leads
AOS-LEGAL-024 Map EU CRA, privacy, update, and vulnerability obligations P0 M1 Run the relevant document, schema, conformance, build, experiment, or hardware checks; independently review boundary compliance and acceptance criteria.
AOS-ODM-022 Define display, enclosure, battery, charging, thermal, and repair architecture P1 M9 supplier data, thermal/power simulation or prototype, safety/regulatory consultation and repair workflow review
AOS-ODM-024 Define production cellular/RF module and antenna architecture P1 M10 module vendor and accredited-lab review, preliminary RF/coexistence/thermal/power analysis
AOS-ODM-040 Perform DFM, DFT, reliability, and serviceability review P1 M10 EMS/ODM and independent hardware review with seeded manufacturing/repair scenarios
AOS-ODM-050 Run product-hardware certification pre-scan P1 M10 accredited/qualified lab pre-scan and cross-functional result review

Risks and Open Questions

  • False precision in long-range dates hides unknown hardware work.
  • Large epics can mask stalled evidence.
  • Parallel tracks can duplicate interfaces without conformance ownership.
  • Open-question rule: an unanswered high-impact question becomes a claim/experiment record and cannot be hidden in meeting notes.
  • Stop rule: work stops or changes track when legal rights, recovery, debug access, safety, or the required evidence path is unavailable.

Related Documents

Planning Reference Anchors

Cellular And Carrier Path

AOS-CELL-052 — Build cellular certification and carrier engagement plan

Cellular Path

AOS-CELL-003 — Commission lawful cellular test environment; AOS-CELL-042 — Define emergency-calling safety boundary before voice work; AOS-ODM-024 — Define production cellular/RF module and antenna architecture

Development Stages

AOS-LEGAL-010 — Build regulatory and certification market matrix; AOS-LEGAL-010 — Build regulatory and certification market matrix; AOS-ODM-022 — Define display, enclosure, battery, charging, thermal, and repair architecture; AOS-ODM-040 — Perform DFM, DFT, reliability, and serviceability review; AOS-ODM-050 — Run product-hardware certification pre-scan; AOS-ODM-050 — Run product-hardware certification pre-scan

Eu Path

AOS-LEGAL-024 — Map EU CRA, privacy, update, and vulnerability obligations

Evidence Package

AOS-LEGAL-013 — Obtain certification laboratory architecture consultation; AOS-ODM-050 — Run product-hardware certification pre-scan; AOS-ODM-050 — Run product-hardware certification pre-scan

Market Matrix

AOS-LEGAL-010 — Build regulatory and certification market matrix; AOS-LEGAL-010 — Build regulatory and certification market matrix