Compliance-by-Construction Argument Graphs: Using Generative AI to Produce Evidence-Linked Formal Arguments for Certification-Grade Accountability

Generative AI can produce engineering artefacts, but generation alone does not determine whether or how those artefacts should enter safety-critical workflows. This paper develops a formal framework for assigning AI participation and assurance at the level of individual workflow units. Each unit has a participation and assurance record covering its engineering requirement, an approved operational formalization where applicable, the applicable mechanism, fallback where applicable, evidence obligations and the applicable guarantee, plus a deployment-readiness status. The framework distinguishes deterministic verification, statistically calibrated admission, authorized human judgement supported by AI advice, authorized human adjudication of AI-produced artefacts, retained deterministic tool paths and explicit non-participation; these arrangements carry different kinds of guarantee rather than levels on a common scale. The framework also separates formalization fidelity from verifier soundness, provides a staged classification and readiness procedure, and derives conditions for comparing a gated AI-assisted unit with an incumbent process under recurring-population assumptions. We instantiate and apply the framework in an executed 17-unit wing-spar structural-analysis workflow combining deterministically gated AI-generated CAD, retained deterministic computation and human judgement. The AI-generated CAD program passed all 23 deterministic checks and was admitted at the first attempt. Favourable stress magnitudes did not suffice to pass the stress criteria where the predeclared mesh-convergence evidence was insufficient; those criteria were instead referred to engineering judgement. The case demonstrates selective AI participation and explicit evidence handling at unit level; no claim is made of workflow-level dependability, certification, structural safety or productivity.

The EU AI Act (Regulation 2024/1689) imposes technical obligations on high-risk AI providers, yet Articles 8-15 were drafted for predictive AI and leave seven technical gaps when applied to generative systems, spanning non-deterministic data governance, training-data provenance, continuous conformity, human oversight, open-ended robustness, emergent risk, and generative fairness. We deliver Governance-as-Code (GaC), a framework of 43 machine-checkable acceptance criteria across six compliance modules that run in a CI/CD pipeline and emit Article-indexed audit evidence, and we show the actual Rego policy code rather than merely describing it. Our central commitment is that the Act's open-textured standards ("appropriate levels," "possible biases") become declared, auditable numbers: robustness thresholds are derived from the provider's documented baseline and a state-of-the-art floor, and framing bias is collapsed into eight measurable proxies tested by counterfactual demographic probing. We also correct who owes what, since under Article 25 and Chapter V a downstream deployer relies on the upstream provider's Article 53 training-data summary and documents only the layers it controls, so GaC verifies that summary rather than demanding per-sample documentation the deployer never had. We validate on two enterprise deployments, a high-risk advisory chatbot and a limited-risk content generator, benchmarking against a manual expert audit rather than documentation artifacts that were never designed to enforce compliance. GaC reproduces all of the manual audit's findings, including three penalty-triggering violations, while cutting audit labor by roughly 75%.

Audits of generative AI (GenAI) systems often summarize behavior as a reported rate: how often the audited system complies with policy. Researchers and stakeholders use that rate to compare systems, track regressions, and gate deployment. A reported rate reflects both the system under audit and the measurement choices behind it, so a change in the rate can leave it unclear whether the system or those choices moved. We introduce ASSERT, a specification-driven measurement pipeline for GenAI audits that ties each reported rate to a written specification of the measurement choices used to produce it. ASSERT helps draft a behavioral rubric and test cases, then runs the audit against a GenAI system and returns a reported rate. In a case study on conversational deception, we observe that the reported rate moves substantially with the dialogue setup, the simulated user, the judge, and the evidence bar for non-compliance. These measurement choices substantially change the reported rate and can reorder GenAI system rankings. Because each reported rate is tied to an explicit specification, differences across audits are easier to attribute and interpret.