# ACT-09 Dry-run / shadow mode

Domain: ACT Action & Tool Use Controls · HI-AAF v1.3 · Public review · https://humanintel.net/standard/act/act-09

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.

## Maturity

- L1 Ad hoc: Controls exist informally; documentation is incomplete; no consistent review.
- L2 Documented: Controls are written down; ownership is assigned; review cadence is defined.
- L3 Operated: Controls are followed in practice; evidence is collected; deviations are tracked. Published criterion for ACT-09: 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.
- L4 Measured: Control effectiveness is measured against documented thresholds; trends are reported.
- L5 Continuously Improved: Controls evolve based on incident learning; maturity gains are evidenced over time.

## Evidence an assessor asks for

- 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.

## Framework mappings

- NIST AI RMF: MANAGE 4.3
- ISO/IEC 42001: A.8.6
- SOC 2 (TSC): CC7.4, A1.3
- EU AI Act: Art. 15(1)
- Singapore: MAIGF Operations Management

Mappings are directional: meeting this control evidences but does not by itself satisfy the external requirement.

## 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