Standards Crosswalk

Practice identifiers in the SSDF column follow Secure Software Development Framework version 1.1, which remains the operative final version; a draft revision was released for comment in December 2025 and had not been finalized as of August 2026.⁹⁷ Note that the generative AI community profile reintroduces practice PW.3 with an entirely new meaning—confirming the integrity of training, testing, fine-tuning, and aligning data—where SSDF 1.1 has no PW.3 at all.¹⁰ Citing PW.3 without naming the document is a common and avoidable error.

22.1 Regulatory Notes #

Four points where a framework drafted earlier in 2026 would now be wrong, and one where the underlying assumption is worth stating.

The EU AI Act’s high-risk obligations have been deferred. Regulation (EU) 2026/1744, the Digital Omnibus on AI, was adopted on July 8, 2026 and entered into force on July 27, 2026.⁹⁴ It moved the Chapter III high-risk obligations for Annex III stand-alone systems from August 2, 2026 to December 2, 2027, and for Annex I product-embedded systems from August 2, 2027 to August 2, 2028, citing delayed availability of harmonised standards and delayed designation of national competent authorities. As of August 2026 the binding obligations are the prohibited practices and AI literacy requirements in force since February 2025, the general-purpose AI obligations in force since August 2025, and the Article 50 transparency obligations in force since August 2, 2026. Any framework asserting that Articles 9 through 15 currently bind Annex III providers is wrong by roughly sixteen months. Plan against the deferred dates; do not claim they are current.

The US federal software attestation mandate was rescinded. OMB Memorandum M-26-05, issued January 23, 2026, rescinded the memoranda that created the government-wide secure software self-attestation requirement.⁹⁵ The attestation form and the SSDF remain available and are now optional, with agencies setting tailored risk-based requirements. The SSDF survives as guidance rather than as a procurement condition. This is a material change for anyone whose control rationale rested on a federal mandate.

The Cyber Resilience Act’s reporting obligations begin imminently. Reporting for actively exploited vulnerabilities and severe incidents applies from September 11, 2026, with full application on December 11, 2027.⁴⁶ Manufacturers must maintain an SBOM covering at least top-level dependencies, publish a coordinated vulnerability disclosure policy, and define a support period. It is the first regime to make secure development practice a market access condition.

Sector regimes were drafted without agents in contemplation, and the regulator’s position will be that existing obligations apply unchanged. The DORA regulatory technical standards require testing and approval of all systems before production use, source code review covering both static and dynamic testing, non-production environments containing only anonymised or pseudonymised production data, and independence between the approving and implementing functions.⁴ PCI DSS requires pre-release review of bespoke and custom code, and where that review is manual, a reviewer other than the originating author; automated review is permitted as an alternative.² The FDA’s predetermined change control plan is the only instrument among these that pre-authorizes a bounded envelope of future autonomous change, and it is worth studying as the closest available regulatory precedent for governing systems that modify themselves after release.⁹⁶

The underlying assumption. Where an agent acts on regulated data or systems, document the mapping explicitly rather than waiting for guidance. Regulators are unlikely to accept that an obligation lapsed because the party performing the work was not a person.