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§ I · Domain ACT · Control 9 of 9
Control
ACT-09
Edition
v.1.3
Status
Public review

ACT · Action & Tool Use Controls

ACT-09Dry-run / shadow mode

A dry-run or shadow mode is available for newly introduced tools, allowing observation of intended behavior without live effect.

For newly introduced tools or tool-configuration changes, a dry-run or shadow mode allows the agent's intended behavior to be observed without live effect. This control provides a safe path for introducing new capabilities into production without risking unintended consequences, and generates evidence that the tool behaves as expected before live activation.

Table ACT-09.1 · Maturity criteria · v.1.3

L1 to L5 · the lowest level in scope caps the agent
L1Ad hoc

Controls exist informally; documentation is incomplete; no consistent review.

L2Documented

Controls are written down; ownership is assigned; review cadence is defined.

L3Operated

Controls are followed in practice; evidence is collected; deviations are tracked.

Dry-run or shadow mode is available and has been used for at least one tool introduction or configuration change; observation results are retained; the mode is documented in the deployment process.

L4Measured

Control effectiveness is measured against documented thresholds; trends are reported.

L5Continuously Improved

Controls evolve based on incident learning; maturity gains are evidenced over time.

The v1.3 edition publishes a control-specific criterion at L3 (Operated). The other levels apply the general ladder to this control; see the maturity ladder.

Evidence an assessor asks for

  1. E.1

    Dry-run or shadow mode is available and has been used for at least one tool introduction or configuration change.

  2. E.2

    Observation results are retained.

  3. E.3

    The mode is documented in the deployment process.

Table ACT-09.2 · Framework mappings

5 of 7 frameworks carry a control-level reference
NIST AI RMFMANAGE 4.3NIST AI Risk Management Framework 1.0
ISO/IEC 42001A.8.6ISO/IEC 42001:2023 · Artificial intelligence management system
OWASP LLM Top 10·OWASP Top 10 for Large Language Model Applications
SOC 2 (TSC)CC7.4, A1.3AICPA Trust Services Criteria for SOC 2 Type II
EU AI ActArt. 15(1)EU AI Act · Regulation (EU) 2024/1689
MITRE ATLAS·MITRE ATLAS · Adversarial Threat Landscape for AI Systems
SingaporeMAIGF Operations ManagementSingapore Model AI Governance Framework / AI Verify / PDPA

Mappings are directional: meeting this control evidences but does not by itself satisfy the external requirement. A middle dot means no control-level reference is published at this edition; see the crosswalk.

Cite this control

Human Intelligence. HI-AAF v1.3, ACT-09 Dry-run / shadow mode. Public review edition, July 2026. https://humanintel.net/standard/act/act-09

Edition v.1.3 · July 2026 · Public review · Markdown · PDF

https://humanintel.net/standard/act/act-09

Notice

HI-AAF v1.3 is an independent framework published by Human Intelligence. It is not affiliated with NIST, ISO, AICPA, or any government or accreditation body. The framework is offered openly for review during the current draft cycle.