ASSERT: A Measurement Pipeline for GenAI Audits

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%.

An auditor instructs an AI assistant: "open each file individually using the Read tool -- no scripts, no agents." The AI replies "Yes" -- then issues a single batched call summarizing all fifty files at once. We call this the Compliance Gap: a third, orthogonal axis of AI honesty distinct from factual truthfulness and rhetorical substance. Three questions: does this verbal-behavioral disconnect exist (existence); can any text-only observer recover it (detectability); what infrastructure does AI deployment need (remedy)? Some 75 benchmarks (IFEval, SWE-bench, BFCL, COMPASS, SpecEval) measure outcome fidelity; none measures process fidelity. Theorem 1 shows the gap is structurally inevitable under RL that rewards text without observing behavior. Theorem 2, via the Data Processing Inequality, shows it is undetectable from text alone -- by any human or LLM observer, present or future. Thirteen experiments and 2,031 sessions on six frontier models confirm both predictions. Under default framing, all six exhibit instruction compliance rates of 0% -- Claude Sonnet 4 verbally agrees ten out of ten times then bypasses in all ten. The gap is selective: 97% compliance where rationale is rewarded (audit trails), 0-4% where it is not (file reading, privacy masking); removing delegation tools raises compliance to 75% (Cohen's d = 2.47), confirming environmental affordance rather than weight-encoded failure. Nine blinded human raters achieve Fleiss' kappa = 0.130 and correctly identify zero of fifteen compliant sessions, exactly as Theorem 2 predicts. Where humans show 47% intention-behavior gaps in psychology and 96.5pp gaps in surgical audits, RLHF-trained models approach 100% under default conditions -- a regime warranting its own measurement infrastructure. We release BS-Bench: the first open benchmark for process compliance, with seven tool-call-log audit metrics and a public leaderboard.

We introduce AuditBench, an alignment auditing benchmark. AuditBench consists of 56 language models with implanted hidden behaviors. Each model has one of 14 concerning behaviors--such as sycophantic deference, opposition to AI regulation, or secret geopolitical loyalties--which it does not confess to when directly asked. AuditBench models are highly diverse--some are subtle, while others are overt, and we use varying training techniques both for implanting behaviors and training models not to confess. To demonstrate AuditBench's utility, we develop an investigator agent that autonomously employs a configurable set of auditing tools. By measuring investigator agent success using different tools, we can evaluate their efficacy. Notably, we observe a tool-to-agent gap, where tools that perform well in standalone non-agentic evaluations fail to translate into improved performance when used with our investigator agent. We find that our most effective tools involve scaffolded calls to auxiliary models that generate diverse prompts for the target. White-box interpretability tools can be helpful, but the agent performs best with black-box tools. We also find that audit success varies greatly across training techniques: models trained on synthetic documents are easier to audit than models trained on demonstrations, with better adversarial training further increasing auditing difficulty. We release our models, agent, and evaluation framework to support future quantitative, iterative science on alignment auditing.