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NIST AI RMF and OSFI E-23

What evidence Oloproof records toward the NIST AI RMF's Measure function and OSFI's Guideline E-23, item by item, and what it does not record. The editions are the NIST AI Risk Management Framework 1.0 (NIST AI 100-1, January 2023) and Guideline E-23, Model Risk Management (final 11 September 2025, in effect from 1 May 2027 for federally regulated financial institutions in Canada).

This is not certification, not an assessment of your compliance and not legal advice. A framework asks for practices across an organisation; Oloproof produces evidence about AI systems, which is one part of those practices. NIST has said the AI RMF 1.0 is being updated, so check the edition you are held to.

How to read the tables

  • Recorded: Oloproof records evidence for the item as written, in every run or record it names.
  • Partly: Oloproof records part of what the item asks; the rest is said beside it.
  • Not covered: the item asks for something Oloproof does not do.

The items are paraphrased. Read the framework's own text before relying on a row.

NIST AI RMF 1.0: Measure

ItemWhat it asks, in shortWhat Oloproof recordsStatus
MEASURE 1.1Metrics chosen for the risks the Map function foundEach run's metric specifications, rules and release policy, by digest. Choosing them is yoursPartly
MEASURE 1.2Metrics and controls reassessed over timeTrend marks where the judge or the cases changed; a decision says when its evidence is stale (Gating)Partly
MEASURE 1.3Assessment by people who did not build the systemA workspace that decides on its own evidence, labellers counted by account, and a decision record a second party checks offline. Who those people are is yours to arrangePartly
MEASURE 2.1Test sets, metrics and tools documentedEvery run names its suite, system and evaluator versions, metrics and methods by content address, and the analysis versionRecorded
MEASURE 2.2Human subject protectionsNothingNot covered
MEASURE 2.3Performance measured and demonstratedEvery rule decided on an interval: PASS, FAIL, INSUFFICIENT_EVIDENCE or MANUAL_REVIEW. Whether the suite resembles deployment is yoursPartly
MEASURE 2.4Behaviour monitored in productionPeople review a sample the workspace draws from real traffic (Evaluating production)Partly
MEASURE 2.5Validity and reliability demonstratedIntervals with their denominators, and judges measured against people before they may decide (Judges)Partly
MEASURE 2.6Safety risks evaluated regularlyCeilings on what goes wrong, decided on your cases, and a red-team tool's grades read when you have them (Risk ceilings). Oloproof writes no attacksPartly
MEASURE 2.7Security and resilience evaluatedOnly through ceilings on cases you write or importPartly
MEASURE 2.8Transparency and accountability examinedSign-offs and approvals by two named people, kept in a chain and carried in the decision recordPartly
MEASURE 2.9The model explained and its output interpretedDiagnoses by intervention name the part implicated in failures; they explain no modelPartly
MEASURE 2.10Privacy risk examinedThe egress policy keeps content on your side; no privacy risk is assessedNot covered
MEASURE 2.11Fairness and bias evaluatedDeclared slices measured with multiplicity control; what makes a slice fair is yoursPartly
MEASURE 2.12Environmental impact assessedCost is recorded; energy is notNot covered
MEASURE 2.13The measurement itself evaluatedJudges validated against people's labels, and each statistical method admitted by a note, a coverage grid and an auditPartly
MEASURE 3.1Risks tracked over timeTrend, freshness and production reviewPartly
MEASURE 3.2Risks that are hard to measureA rule the evidence cannot decide says so (INSUFFICIENT_EVIDENCE, MANUAL_REVIEW), and an undecided interval says how many more cases would decide itPartly
MEASURE 3.3Feedback from end usersNothingNot covered
MEASURE 4.1Measurement tied to the deployment contextLabels from your own reviewers; the context is yoursPartly
MEASURE 4.2Results informed by domain expertsReviewers' labels decide what a judge is worthPartly
MEASURE 4.3Improvements and declines documentedComparisons of a change against what is live, paired, with intervals (Compare)Recorded

OSFI Guideline E-23 (2027)

PrincipleWhat it asks, in shortWhat Oloproof recordsStatus
1.1 to 1.3Reporting lines, a model risk framework, models fit for their purposeEvidence of fitness for one purpose: a release policy's rules decided on intervals. The framework and its governance are yoursPartly
2.1An inventory of models in useEach project's system versions, as the runs that evaluated them recorded them. Not an enterprise inventoryPartly
2.2A model risk ratingNothingNot covered
2.3Effort in proportion to riskA policy per project: its bars, its confidence level, whether a passing release needs two people's approvalPartly
3.1Lifecycle policies, documentedThe release policy is a file, recorded by digest with every gate decided under itPartly
3.2Data suitable for its useSuites versioned by content; whether they suit the use is yoursPartly
3.3Development standards for performance and documentationRules with thresholds, and every run's recordPartly
3.4Independent review of soundness and performanceA workspace gate that decides on evidence it verified itself, runs signed by a runner your platform team registers, and a decision record a reviewer checks offline. The review function is yoursPartly
3.5Deployment with quality and change controlNothing: a signed run attests what a runner executed, not what serves productionNot covered
3.6Monitoring and decommissionProduction review and freshness for monitoring; decommission is not coveredPartly
ApprovalApproval before use, with residual risk affirmedA passing release can wait for two named people's approval, recorded and chained (Gating)Partly

Where to go next

  • Gating: the release policy, approvals and the decision record.
  • Risk ceilings: what a ceiling decides and does not say.
  • What works today: everything that is built, and what is not.