Built by the person who filed the NPRM comments.

The market is starting to map the stack around AI governance into distinct layers. Some companies are building intelligence generation, some orchestration, some policy definition, some runtime authority that decides at the moment of execution whether an action is allowed to become real. The picture is broadly correct as a category map.

Where I disagree is on what one of those layers actually does. The attestation, witness, continuity slot is often described as informational. As a layer that records what happened so other layers can decide.

That description undersells the layer. When an examiner asks six months later whether a control held on a given date, the answer is not informational. It determines admissibility before a regulator or a court. The runtime authority layer matters at execution time. The witness layer matters at examination time. Both are decisional. They decide at different time scales.

For the examination-time decision to hold, the record has to be externally verifiable without trusting the runtime that produced it. Tamper-evident, with an independent signing key held outside the producing runtime. Reconstructable by a third party from primitives that survive the system. That property is not produced by hardware-rooted trust alone, nor by retrospective audit. It sits across the witness layer and the cryptographic enforcement layer as a unified property.

That is the slot Notary Cloud holds.