The gaps that appear when policy stays a PDF

A written policy feels like coverage. In an agent system, it is not. The document describes what should happen; the runtime has no way to enforce it. The failures that follow are predictable, and none of them look like a "hack."

Gap 1: silent overrides

An agent is told to "process the refund" and does — including the one above the manager-approval threshold. Nothing blocked it, because the threshold existed only in prose. The override was silent; the customer got the money back; the audit trail shows a normal transaction.

Gap 2: no evidence trail

EU AI Act Art. 12 requires logging of high-risk system activity. A PDF policy produces no logs. When a regulator or your own DPO asks "did the agent ever violate the data-residency rule?", a document cannot answer. Only an enforced, logged rule can.

Gap 3: drift after a prompt change

Someone edits the agent prompt to "be more helpful with refunds." The policy did not change — but the agent's behavior did. Without a rules file the agent evaluates on every run, the policy and the behavior quietly diverge, and nobody notices until an incident.

Closing the gaps

Encode each policy as a condition + action rule, wire high-risk rules to human approval or a block, and log every decision. Re-run the checklist after any prompt or tool change. The rules are a view of your obligations, not a guarantee — but they turn an invisible policy into an enforceable, auditable control.

Authoritative references

  • EU AI Act (Reg. 2024/1689), Art. 12 (logging): https://eur-lex.europa.eu/eli/reg/2024/1689/oj
  • AI Act explorer: https://artificialintelligenceact.eu/
  • European Commission AI policy: https://digital-strategy.ec.europa.eu/en/policies/regulatory-framework-ai