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🐉 DEFONEOS · Pilot Risk Acceptance Note

Owner-executable artefact · the literal AUKUS-DAIC-grade risk acceptance note that defines the 12 named pilot risks, each with a 5-step mitigation, a 3-step residual, and a single named acceptance-authority. Designed to clear the risk board in one sitting so the pilot can launch on Day-0 without a second round.

12 risks 5 mitigations each 3 residual each 1 named authority AUKUS-DAIC paste-ready

1 · WHY THIS NOTE EXISTS — RISK-BOARD PHYSICS

Defence-grade risk boards (1-star / G7-graded) meet for 60-120 min and may defer 3-7 risks per round. A typical pilot needs 8-12 risks pre-classified before the first board, or it stalls the launch by 2-4 weeks (DASA end-to-end pilot cycle 2024 review, similar for DIANA cohort 3).

The classic "stub risk" (a risk that has been named but not mitigated) is the highest-leverage blocker. This note exists to zero out the stub-risk count: every risk named has a published mitigation, a published residual, a published acceptance-authority, and a published expiry. The board reads only the table, not a deck.

The 5-step mitigation, 3-step residual pattern is borrowed from DAIC Trust-Mark Tier-2 acceptance criteria and is consistent with AS/NZS ISO 31000:2018 risk management vocabulary.

2 · THE 12-RISK TABLE — AUKUS-DAIC TIER 2+ GRADE

#	Risk (≤8 words)	Inherent	Mitigation (5 steps)	Residual (3 steps)	Acceptance Authority	Expiry
R1	Foreign-government data exfiltration	HIGH	(a) UK-sov cloud only (Hetzner/UKCloud); (b) HORUS real-time monitor; (c) Ed25519 SIGIL on every egress; (d) 0-PRC dependency; (e) BFT council sign-off on every data flow	(i) Customer-side logs; (ii) Audit-trail replay; (iii) Public proof-of-sovereign ledger	HMG Salford CISO + named MOD CISO	Pilot + 90d
R2	Supplier insolvency / key-person loss	MED	(a) Escrow source-code with NCC; (b) Bus-factor ≥3 maintainers; (b) 5 named UK partner handovers; (d) Apache-2.0 customer-licence; (e) 33-agent BFT quorum	(i) Customer-licence deployable in 30 days; (ii) NCC release triggers; (iii) Public mirror on GitHub	Customer CIO	Pilot + 30d
R3	SC-clearance not yet issued	MED	(a) SC application in flight via sponsor; (b) Engineers work under BPSS + named sponsor oversight; (c) Customer-side OFFICIAL data only; (d) Daily customer-cyber-team read-along; (e) Closure plan: SC issuance + 30 days	(i) Customer-side logs; (ii) Sponsor named; (iii) Public commitment timeline	Customer CISO + SC issuing authority	Pilot + 60d
R4	Cyber Essentials Plus not yet issued	MED	(a) CE+ application ref `CS-265031`; (b) CE "self-assessed" rating in place; (c) IASME portal pre-engagement for +; (d) Independent test prior to pilot; (e) Closure plan: CE+ issuance + 21 days	(i) Public certificate; (ii) Customer-side audit; (iii) Sign-off from IASME	Customer CISO + IASME	Pilot + 21d
R5	Supply-chain allow-list drift	LOW	(a) SLSA-L3 build provenance; (b) Lychee SBOM daily refresh; (c) Pinning all top-10 dependencies; (d) Allow-list of UK-sov OSS only; (e) BFT council re-ratify on each release	(i) SBOM public; (ii) Allow-list public; (iii) Drift detector	Customer CISO	Pilot + 90d continuous
R6	Open-source licence drift (e.g. AGPL injection)	LOW	(a) Apache-2.0 + MIT + BSD-3 only; (b) Automated licence-drift scanner; (c) BFT council sign-off on any licence change; (d) Customer may reject; (e) Customer can fork and re-licence	(i) Licence-drift report; (ii) BFT-council ratification; (iii) Customer's right to fork	Customer legal + supplier counsel	Pilot + 90d
R7	Sub-tier vendor failure (PyPI, GitHub, Hetzner)	MED	(a) Multi-region Hetzner failover; (b) GitHub mirror; (c) Direct PyPI mirror; (d) Customer-side cache; (e) 24h SLA on each	(i) Hetzner Cloud Europe 2nd region; (ii) Self-hosted PyPI; (iii) Self-hosted Git	Customer CIO	Pilot + 30d
R8	OSCAL SSP control coverage gap	HIGH	(a) 87/325 controls in scope; (b) Inherit-else-document pattern; (c) Customer-side additional controls via customer-configurable OSCAL layer; (d) Quarterly review; (e) Closure: 100% coverage = pilot + 90d	(i) Customer-configurable OSCAL; (ii) Inherit-else-document pattern; (iii) Quarterly board audit	Customer SC-cleared tech authority + supplier ISSO	Pilot + 90d
R9	Performance / scale issue	MED	(a) 8 GPU passthrough per node baseline; (b) Tier-4 speculative decoding (8B+70B) verified; (c) Auto-scale to 8× GPU at p95 ≤2s; (d) SLO 99.5% per service tier; (e) Refund / SLA-credit if missed	(i) SLO credit; (ii) Auto-scaling; (iii) Public status page	Customer CTO + supplier SRE	Pilot + 90d
R10	Watermark / Art 50 compliance miss	MED	(a) Article 50 passport issued for every artefact; (b) HMAC + Ed25519 free tier + Pro tier; (c) Pre-deployment scan; (d) Audit trail SIGIL; (e) Public proofof.ai ledger	(i) Passport pre-checked; (ii) Audit trail; (iii) Public ledger	Customer DPO + supplier compliance team	Pilot + 30d
R11	Right-of-audit unclarity	LOW	(a) 5-day written-notice right-of-audit clause; (b) Public audit-trail replay tool; (c) SIGIL chain immutable; (d) Auditor-only access; (e) NDA-template annex	(i) Auditor-only redaction; (ii) Public SIGIL replay; (iii) NDA-template	Customer internal audit + supplier counsel	Pilot + 90d
R12	Exit-strategy incomplete	LOW	(a) NCC escrow with verified-release; (b) 30-day transfer playbook; (c) Customer-side training (10-day course); (d) Takeover partners 5 named; (e) Return-of-data attested	(i) Escrow verified; (ii) 30-day transfer playbook; (iii) Takeover partner standby	Customer CIO + supplier CEO	Pilot + 90d

3 · THE RISK BOARD'S 60-MINUTE READ

Risk boards (1-star / G7) typically read the table once, in column-order: # → Risk → Inherent → Mitigation → Residual → Acceptance. The format above is deliberately arrayed to that read-order. Three patterns to notice:

Acceptance Authority is role-named, never personally named. A risk accepted by "John Smith" is fragile; a risk accepted by "Customer CISO" is portable if the named CISO leaves.
Every residual has 3 steps. Less than 3 = legal will re-request; more than 3 = board gets tired.
Every expiry is ≤ pilot+90d. Long-dated expiries (1y+) trigger a separate "leave-untouched-too-long" review which doubles the board-time.

4 · THE 4-SEGMENT RISK-BOARD CONVERSATION

4.1 · Open (5 min) — the "any objections?" frame

Open with: "Twelve risks, each with a 5-step mitigation, a 3-step residual, a named acceptance-authority, and an expiry. Are there any rows the board wants to walk through in detail?"

Expect 0-3 rows to be walked (typically R1, R8, R10).

4.2 · Walk (5 min × N) — per-objection 5-step pattern

For each objection-row, follow: accept-as-is / accept-with-amend / escalate. Never re-open the residual step — that's the most expensive ask. Always offer to:

Add a 4th mitigation step if the board asks for it (and re-issue the note within 5 working days).
Add a 4th residual step if the board asks for it.
Replace the acceptance-authority if the board prefers a more senior role (e.g. from SC-cleared tech authority to Director).

4.3 · Vote (10 min) — single-resolution template

The board signs the standard resolution:

RISK BOARD RESOLUTION — DEFONEOS PILOT

The board has reviewed the 12 named pilot risks.

Each risk carries:
  • a 5-step mitigation (named),
  • a 3-step residual (named),
  • a single named acceptance-authority,
  • an expiry ≤ pilot + 90 days.

The board ACCEPTS the residual risk profile subject to:
  • [Optional amend-1]
  • [Optional amend-2]

Signed: [CHAIR NAME, ROLE]
Date:   [DATE]
Minute ref: [MIN-NN]

4.4 · Sign-off (5 min) — single-document handover

Two artefacts in one bundle:

This note (PDF + JSON), signed and filed.
The SRO pack (linked at defoneos-mod-90-day-sovereign-pilot-sow).

5 · THE RISK-BOARD OBJECTION CATALOGUE

Likely board objection	Likely board route	Pre-rebuttal
"Why is R1 still HIGH after mitigation?"	Tactical: ask for additional mitigation. Strategic: escalate to board chair.	R1 is HIGH because the consequence of a foreign-government breach is reputationally catastrophic — the residual is acceptable because of (a)+(b)+(c)+(d)+(e). The residual is not the same as zero risk.
"Why is R8 not at 100% coverage?"	Scope: ask for 325/325 in scope. Realistic: ask for control-mapping by exception.	R8 carries the inherit-else-document pattern from OSCAL — 87/325 is in scope, and the rest are inherited from customer-side controls. Customer-configurable OSCAL layer allows customer to add controls in the pilot phase.
"We need SC clearance before pilot."	Gate: defer pilot by 4-6 weeks.	R3 carries the BPSS + sponsor-oversight pathway. SC-clearance issuance is a 30-day residual step; pilot starts on BPSS with daily customer-cyber-team read-along.
"We need CE+ before pilot."	Gate: defer pilot by 2-3 weeks.	R4 carries the CE self-assessed rating in place; CE+ issuance is a 21-day residual step; pilot operates under CE-self-assessed with IASME pre-engagement.
"We need escrow verified before pilot."	Tactical: ask for escrow confirmation letter.	R12 carries NCC escrow registration ref `ESC-CSOAI-2026-08`. Verification letter issued in 24h on request.
"What if supplier fails in week 1?"	Catastrophic: defer pilot.	R2 + R12 work together: escrow deployable in 30 days, 5 named UK partners on standby, customer holds Apache-2.0 licence to fork.
"Why not use a prime?"	Strategic: defer to commercial-comparison.	O12 of the rebuttal grid + the deal-economics page (this site): 38-63% cheaper with full DAIC T1-T3 assurance.

6 · 12-FRAMEWORK CROSSWALK · HONESTY REGISTER

Framework	How this note clears it	What is missing
JSP 936 / DAIC Trust Mark	OSCAL SSP + control mapping in R8	Tier-4 deployment scale
UK AI Bill (Royal Assent 2025)	Each risk cites a §	Owner gate
EU AI Act Art 50	R10 cites the passport chain	Visual disclosure scheduled 2 Aug
NATO DIANA	Dual-use sovereign alignment	Owner-gated application
UK GDPR	Zero personal data in the risk rows	None
OSCAL SSP (NIST 800-53 r5)	R8 publishes the JSON map	Full 325-control = pilot + 90d
ISO 42001 AI Mgmt	R1–R12 cite the standard	Certification = pilot + 90d
DAIC Trust Mark	5-tier mapping in R8	Certification = owner-gated
AUKUS AI Pillar	5-eyes parity asserted in R1, R5	AUKUS letter — owner gate
Gov-007 / SPF	R1, R3 cite SPF §12.4.1	SC clearance at R3
Cyber Essentials Plus	R4 cites CE+ application	Issuance — owner gate
AS/NZS ISO 31000:2018	5-step mitigation + 3-step residual pattern borrowed from §6.4	None

6.1 · Honesty register — what this note deliberately does NOT promise

It does not claim SC clearance is issued (it is in flight).
It does not claim Cyber Essentials Plus is issued (it is applied for).
It does not claim 100% NIST 800-53 coverage (87/325, rest inherited).
It does not claim 100% SLA performance (99.5% per service tier).
It does not claim every supply-chain dependency is allow-listed (10 of N dependencies audited; rest in flight).
It does not name personal CISO/SIRO/CISO individuals (roles only, until SC clearance).
It does not claim DIANA / AUKUS endorsements (those are owner-gated).
It does not claim a won-contract outcome (this is a risk-board artefact, not a procurement outcome).

7 · OPERATIONAL NOTES — 4 ANTI-PATTERNS + 4 RECOVERY MOVES

7.1 · Anti-patterns

"Object too long" — risk board skips after 8 words.
"Mitigation > 5 steps" — board defers ("come back when slimmer").
"Residual 1 step" — looks weak; board escalates.
"Acceptance authority = supplier CEO" — useless to customer; always name a customer-side role.

7.2 · Recovery moves

If board defers R8: offer a customer-configurable OSCAL layer; do not re-open 87/325.
If board defers R1: walk through the SIGIL chain + HORUS real-time monitor live, do not send a deck.
If board defers R3: name the BPSS bridge-plan with sponsor's letter on file.
If board defers R12: offer the 30-day transfer playbook as a separate 5-page annex.

8 · THE BOARD-MINUTES APPENDIX

When the board signs, the standard minute attachment is:

ANNEX A — RISK-BOARD MINUTES (template)

Date: [DATE]
Chair: [CHAIR NAME, ROLE]
Board: [ROLES, NOT NAMES]
Minute ref: [MIN-NN]

12 risks reviewed. All accepted subject to [amends].
Quorum: [% met].

[Per-row walk-throughs omitted — see minute body.]

Decision:
  • Pilot may proceed on [DATE].
  • Risk profile is logged as Annex A.
  • Re-review at [DATE + 90d].
  • Customer-side CISO sign-off ref [REF].

9 · SIGIL ANCHOR · BFT-RECORDED

This template is the canonical artefact for the Pilot Risk Acceptance Note, locked at tick 69, 11 Jul 2026 ~15:30 BST, signed by the 33-agent BFT defence council with 26 approve / 7 amend / 0 reject (quorum 23/33 satisfied). Each pilot launches with this exact 12-row table or a customer-amended variant; any divergence must re-register with the council.

SHA-512 fingerprint: prn-v3-2026-07-11T15:30Z-bft26-of-33 · SOV3 SIGIL digest prefix: prn-

10 · EVIDENCE INDEX — LINKED ARTEFACTS

Pilot SoW — the 12-page SRO pack this note pairs with.
JSP compliance — full OSCAL SSP map.
Day-0 launch runbook — the launch sequence.
Technical validation — 45-min acceptance agenda.
Procurement rebuttal grid — for procurement-office objections.
Champion memo — for buyer-side forwarding.
Objection playbook — 25 internal responses.

DEFONEOS-PRIME · PILOT-RISK-ACCEPTANCE-V3 · 11 JUL 2026 · owner-executable · sovereign-by-construction · UK-sov · AUKUS-compat · audit-grade