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APRF-17

Human Approval

Require human gates for high-impact or irreversible actions.

Purpose

Insert human approval and oversight where AI-proposed actions have high impact, irreversibility, or regulatory sensitivity.

Engineering philosophy

Human-in-the-loop is not a product apology—it is a control. The goal is calibrated oversight: humans approve what machines should not decide alone.

Why it matters

Autonomous execution of irreversible actions (money movement, data deletion, external communications, code deploy) without approval creates unacceptable blast radius.

Common failures

  • Rubber-stamp UIs that hide risk details
  • Approval only in UI while API/agent path bypasses it
  • No dual control for mission-critical actions
  • Approvals without audit trail

Mandatory checks

Gate controls. Each check is pass/fail via artifact + pass condition. Expected from the annotated capability level when the system meets the minimum criticality tier.

  • HUM-M1L3 · DefinedTier 2 · Productionhybrid

    High-impact action classes shall be inventoried and gated by human approval in production

    Artifact
    High-impact action inventory + gate wiring evidence
    Pass condition
    100% of inventoried high-impact action classes have an approval gate in production; ungated execution tests fail at 100%
  • HUM-M2L3 · DefinedTier 2 · Productionhybrid

    Approval decisions shall be logged with actor, context, and outcome

    Artifact
    Approval audit log schema + sample records
    Pass condition
    100% of sampled approvals in last 30 days include actor ID, action context, and approve/deny outcome; schema validation test passes
  • HUM-M3L3 · DefinedTier 2 · Productionautomated

    Approval shall not be bypassable via alternate agent or API paths

    Artifact
    Bypass-path threat tests across UI, API, and agent entry points
    Pass condition
    Automated or reviewed tests attempt bypass via alternate paths; 0 successful ungated high-impact executions
  • HUM-M4L5 · OptimizingTier 3 · Mission Criticalhybrid

    Dual control shall be required for Level 5 irreversible actions

    Artifact
    Dual-control workflow config + sample approval records for irreversible actions
    Pass condition
    PASS if Level 5 irreversible actions are inventoried and 100% of sampled executions show dual approval; 0 single-approver completes in the sample

Evidence required

  • High-impact action inventory
  • Sample approval audit logs
  • Architecture proof that bypass paths are closed

Severity & risk

Severity
critical
Impact if violated
Risk level
high
Typical residual risk (impact × likelihood)

Engineering best practices

  • Classify actions by impact tier with default gates
  • Allow break-glass with heightened logging for emergencies
  • Never ask the model to 'pretend' approval was granted
  • Design approvals for voice and async channels, not only web UI

Automatic validations

  • Tests that gated tools fail without approval tokens
  • Monitoring of approval bypass attempts
  • Alerts on abnormal approval velocity

Manual validations

  • Process review of approval fatigue risk
  • Sample audits of approved vs executed actions

Examples

  • A coding agent opens a PR but cannot merge to main without human review
  • A finance agent queues wire transfers for dual approval above a threshold

References

Crosswalks

  • GOVERN Govern

    NIST AI Risk Management Framework · supports

  • Safe Safe

    NIST AI Risk Management Framework · aligns-with

  • Accountable Accountable and Transparent

    NIST AI Risk Management Framework · supports

  • §5 Leadership

    ISO/IEC 42001 · supports

  • Annex A AI system controls (selected themes)

    ISO/IEC 42001 · partial

  • LLM06 Excessive Agency

    OWASP Top 10 for Large Language Model Applications · supports

  • CC5 Control Activities

    SOC 2 Trust Services Criteria · evidence-for

  • Generative AI Lens Generative AI Lens (themes)

    AWS Well-Architected Framework · aligns-with

Future evolution

Standard approval protocols for cross-system agents with portable audit receipts.