Regulatory Submission Integrity

Cryptographic evidence that regulatory submissions are what they say they are — and remain so for decades.

Federal and state regulatory submissions — FDA drug applications, SEC filings, banking call reports, EPA permit applications, FAA airworthiness directives — require integrity that survives the retention window, vendor changes, and cryptographic primitive transitions. H33 produces submission evidence that satisfies the integrity requirement without depending on the submitter's continued existence.

The submission integrity problem

A regulatory submission is a structured document submitted by a regulated entity to a regulator. The submission asserts facts the regulator relies on for licensing, approval, oversight, or enforcement decisions. The submission is retained for a long window. FDA submissions are retained indefinitely. SEC filings are retained for decades. During the retention window, multiple integrity concerns arise: Did the submission arrive at the regulator unmodified? Has the submission been modified after acceptance? Does the submission match what the entity claimed to submit? Is the submission's signature still valid? Can the submission be verified by parties who do not trust the regulator's systems?

How H33 handles submissions

Each regulatory submission becomes an H33 evidence bundle (or a chain of bundles for multi-document submissions). The bundle contains the submission content (or commitments to it, with content held separately for confidentiality); documents the submitter's authority via AuthorityBind; documents the policy or regulation via PolicyBind; documents the model(s) and analyses that produced the submission via ModelFingerprint and PipelineDag; documents the data underlying the submission via CorpusBind and EvidenceAttestation; includes citation binding for cited evidence via ResultCitationBind. The bundle is signed with three independent post-quantum algorithm families. The bundle's 32-byte canonical commitment can be anchored to a public blockchain at submission time.

What the chain anchor provides

For high-stakes submissions, chain anchoring provides time-binding that does not depend on either party's internal records. When the submission is prepared, the bundle's commitment is computed. The commitment is published as a transaction on a public blockchain (Avalanche today). The blockchain confirms the transaction in a block. The block's timestamp provides a cryptographic time witness. Years later, the verifier queries the blockchain for the transaction. The transaction's continued presence proves the submission's commitment was published at the anchor time. The bundle's commitment is recomputed; the recomputed commitment must match the on-chain calldata. If it matches, the bundle has not been modified since the anchor.

Use cases

FDA submission integrity. A pharmaceutical company submits an NDA. The submission includes thousands of pages of clinical data, analyses, and documentation. The submission is anchored at filing time. Years later, in a post-market surveillance review or litigation discovery, the original submission's integrity is verifiable against the anchor. SEC filing integrity. A public company files a 10-K, 10-Q, or 8-K. The filing is anchored. Subsequent enforcement or shareholder litigation can verify the filing's integrity. Banking call report integrity. A bank files quarterly call reports. Each call report is anchored. The bank's records and the regulator's records are both verifiable against the anchor. FAA airworthiness submissions. Aircraft manufacturers submit airworthiness data. The submissions are anchored. Decades later, accident investigations verify integrity against the original anchor. International regulatory submissions. A US-based company submits to EMA, PMDA, or NMPA. The bundle provides verifiable evidence interpretable across regulator boundaries.

Common questions

Does this require regulator adoption?
No. The submitter can produce H33 bundles unilaterally. The regulator's acceptance is a process matter, but the technical artifact is verifiable regardless.

Can the regulator verify the bundle without trusting the submitter?
Yes. The bundle is self-contained. The open-source verifier runs offline.

What about confidential or proprietary content?
The bundle structure supports selective disclosure. Confidential portions can be referenced by digest with the underlying content kept under submitter control.

Can the submitter prove a submission was filed at a specific time?
Yes, via chain anchoring. The anchor's block timestamp is cryptographic proof of submission time.

What if the submission needs amendment?
Amendments produce additional bundles in a chain. The original bundle remains anchored and unmodified.

Get Started

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