H33-74 for Government

What gets attested in government

Each of the following operational events emits an H33-74 proof at the moment it occurs. The collection composes into the operational history that audit, compliance, and regulatory teams reconstruct from.

• Benefit determinations: eligibility, denial, appeal, redetermination.
• Licensing actions: grant, renewal, suspension, revocation.
• Procurement awards including evaluation scores and contract clauses.
• Regulatory enforcement: investigations opened, findings, penalties, settlements.
• Identity issuances and revocations including credential lifecycle events.
• Inter-agency disclosures and data sharing authorizations.
• Policy interpretation decisions and administrative rulings.

Regulatory pressure that already justifies this

Government is regulated under frameworks whose audit horizons now extend past the lifetime of the systems and vendors holding the evidence. H33-74 produces evidence that survives that horizon:

• FedRAMP. Cloud environments handling federal information. See: FedRAMP crosswalk
• FISMA. Information security for federal information systems.
• Privacy Act / FOIA accounting. Accounting of disclosures and records preservation.
• EU AI Act. High-risk AI in public administration in EU. See: EU AI Act crosswalk
• NIS2. EU public administration cyber resilience. See: NIS2 crosswalk

Scenarios this changes

Inspector General investigation seven years after a benefit decision

The original PQ-signed proof of the determination is produced. The case officer, the eligibility criteria applied, the evidence reviewed, and the disposition are all in the proof.

FOIA request for disclosure accounting

Every accounting-of-disclosure entry produces an independently verifiable proof. The requester can verify directly without trusting the agency's log integrity.

Cross-administration transition

Operational decisions from the prior administration remain independently verifiable. New administration inherits the verifiable historical record without inheriting the technical infrastructure that produced it.

What survives versus what gets replaced

How to start

Three integration patterns, ordered by how invasive each is.

Pattern 1 — Receipt at the policy engine

The decision system (policy engine, approval workflow, AI scorer) emits an H33-74 proof for every decision at the moment it is made. No change to upstream systems. Auditors verify proofs directly.

Pattern 2 — Receipt at the system of record

Each system of record (treasury, claims, records, EHR) is wrapped so that committed transactions emit H33-74 proofs in addition to the existing audit log. Existing systems remain unchanged. Proofs become a parallel canonical record.

Pattern 3 — Receipt at the integration bus

Service mesh or integration bus intercepts cross-system events and emits H33-74 proofs. Highest reach, requires bus integration. Useful where systems-of-record cannot be modified.

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