The United States has AI standards, auditor accreditation, and management-system certificates. It does not have conformance testing of deployed systems. The fix is a scheme inside the existing architecture, not a rival institution.
John Francis · Stout Street Capital · July 2026 · PDF · 19 pages · 8,033 words · 204 KB
Auditor accreditation is not missing: ANAB accredits ISO/IEC 42001 certification bodies, and Schellman, SGS, DEKRA, DQS and BSI hold that accreditation. What is missing is conformance testing of system behavior, a defined certification unit that survives model updates, and a public registry. Drawing on Underwriters Laboratories, FedRAMP and the NTSB, the paper specifies what gets certified and for how long, who pays and why publishing test methods defeats issuer-pays capture, why parametric insurance makes AI harm priceable, why state procurement is the one demand lever federal preemption explicitly does not reach · and the seven ways the institution fails.
[ figures ]
The evidence, drawn.
fig. 01 · the gap, dated
Both columns are true at once. Regulation retreated; standards, accreditation, and insurance kept arriving. The missing piece is the conformance layer that binds the right-hand column into one mark. Dates as cited in the paper.
fig. 02 · the stack, audited
What this edition corrects: the bottom three layers are built and operating · ANAB has accredited Schellman, SGS, DEKRA, DQS and BSI. The paper's claim is only the dashed top three, run as a scheme inside the existing architecture.
fig. 03 · what moves the certificate
UL certifies a toaster; the toaster is the same toaster next year. An AI system is not · so the unit and its lifecycle are defined before anything else. Systems that update continuously in production have no certifiable artifact, and the paper says so.
[ contents ]
Inside the paper.
Executive summary
The assurance gap
The 2026 landscape
Precedents: UL, FedRAMP, NTSB
What exactly gets certified, and for how long
Who pays, and why that does not corrupt the mark
The incumbent path · a scheme, not a rival
Blueprint principles
A state-scale design study, and why its foundation failed
The economics: assurance as adoption infrastructure