Standard operating procedure · LG5C · Legal
Regulatory Stance Position
Judgment procedure owned by Regulatory Affairs in Legal. 6 numbered steps, 1 of them a person deciding and 5 of them agent work … more
Procedure code
LG5C
Judgment
Rule versions in force
v2.1 · v5.0 · v3.0 · v4.8
4 governing rules stacked over it
In force since
2025-05-28
Earliest effective date across those rules
Last reviewed
2026-08-11
Latest review date across those rules
Rules approved by
1
VP Regulatory Affairs
Rule health
4/4
0 under review · 0 superseded
There is no document register behind this header. The version, the dates and the approver names are read off the governing rules this procedure runs inside, which is the closest thing the estate holds to a document control record. Nobody wrote these procedures. There is no document library behind this page and no Word file anywhere in the estate. Every procedure below is generated from rows this platform already holds: the line and its ordered stations, the owning team and the person accountable for it, the policy items bound to that team, and the governance gates seeded against the function. The steps, the owners, the gates, the approvers, the dwell times and the volumes are read straight off those rows. The sentences that join them together are generated. Read a procedure as the estate describing itself, not as a document somebody signed.
Purpose and scope
What this procedure is for and where it stops
To run regulatory stance position to one repeatable standard inside Regulatory Affairs, part of Legal. more
Entry condition
Runs judgment. Starts when the annual doctrine review opens.
Exit condition
The unit clears gc ratify, released by VP Regulatory Affairs. more
In scope
- Every unit of regulatory stance position raised inside Regulatory Affairs, from the trigger below through to the final step.
- 5 of the 6 steps, which run without a person present.
- 1 decision that stops the line until a named person releases it.
Out of scope
- Anything outside the envelope set by the owning team. It leaves the line at a gate and becomes the named approver's decision.
- Work that belongs to another function. This line records no handoff, so nothing leaves it mid-flow.
- Shared-spine work. This line has none; every step is done inside the function.
Who owns it
Runs the line
Regulatory Affairs Orchestrator
Accountable person
VP Regulatory Affairs
The end of the escalation path. Above them sits Legal Chief of Staff for the function.
That team’s remit
Owns regulatory item work end to end inside Legal. more
That remit describes the whole team, not this one procedure, so its counts are larger than the ones on this page.
Autonomy
64% now · ceiling 68%
Horizon scanning and impact mapping are continuous and agentic. more
The procedure, step by step
6 numbered steps · 1 of them stop for a person
A step is one station on the line. more
| No. | Step | Who does it | What happens | System of record | Time on the step | In flight |
|---|---|---|---|---|---|---|
| 01 | Frame Agentstrategy | Horizon Scanning Agent | Horizon Scanning Agent performs this step unattended at the strategy layer, inside the envelope its owning team has set, and writes an evidence record naming the actor, the authority it acted under and the digests of what it read and wrote. | Contract Lifecycle Management | 32.4 hrsstandard 47.9 hrs | 37 |
| 02 | Gather precedent Agentstrategy | Impact Assessment Agent | Impact Assessment Agent performs this step unattended at the strategy layer, inside the envelope its owning team has set, and writes an evidence record naming the actor, the authority it acted under and the digests of what it read and wrote. | Contract Lifecycle Management | 2.9 daysstandard 4.3 days | 15 |
| 03 | Model options Agentstrategy | Submission Drafting Agent | Submission Drafting Agent performs this step unattended at the strategy layer, inside the envelope its owning team has set, and writes an evidence record naming the actor, the authority it acted under and the digests of what it read and wrote. | Contract Lifecycle Management | 2.1 daysstandard 4.7 days | 42 |
| 04 | Draft position Agentstrategy | Regulator Correspondence Agent | Regulator Correspondence Agent performs this step unattended at the strategy layer, inside the envelope its owning team has set, and writes an evidence record naming the actor, the authority it acted under and the digests of what it read and wrote. | Contract Lifecycle Management | 31.5 hrsstandard 2.8 days | 6 |
| 05 | Challenge Agentstrategy | Change Implementation Agent | Change Implementation Agent performs this step unattended at the strategy layer, inside the envelope its owning team has set, and writes an evidence record naming the actor, the authority it acted under and the digests of what it read and wrote. | Contract Lifecycle Management | 2.7 daysstandard 5.5 days | 29 |
| 06 | GC ratify HumanpolicyDecision | VP Regulatory Affairs Releases: VP Regulatory Affairs | Work stops. VP Regulatory Affairs reviews what the line has produced and either releases the unit or sends it back. Nothing downstream of this step runs until that decision is made.Holds until: Held for a named human when the unit exceeds the regulatory item decision envelope, when confidence falls below the floor, or when a policy clause is engaged. | Contract Lifecycle Management | 5.4 daysstandard 10.5 days | 4 |
The swimlane
The same steps, laid out by who is holding the work
Three lanes: a person deciding, an agent working, and the shared services spine. more
Run the procedure
One unit walked along that swimlane on the happy viable agentified path
Press run and a single unit enters at station 01. Each station takes exactly the dwell this platform records for it and is held by whoever the estate says holds it. more
Nothing has happened yet. more
- The lanes are the recorded lanes. 1 of the 6 stations stop for a person and every one of them still does on this run.
- Every one of the 1 decision is still taken by the person who holds it. The happy path is that each one is released first time, not that it is skipped.
- The owning team is held to a 68% autonomy ceiling and this run sits at 66% unattended, inside it.
- 1 system is attributed across the stations, and 0 of them are connected. Nothing in this run has been watched executing against a real system of record.
One decision, held by VP Regulatory Affairs. more
- 06 GC ratify — The last decision on the line. Something on every procedure ends with a person, so this one is never offered.
This is a run, not a forecast. more
Happy means nothing goes wrong: no station raises an exception, no gate sends the unit back, no rework loop fires and nothing sits in a queue between stations. more
The second clock is the allowance. more
A decision may be handed to the agent lane only if two things hold … more
The run reads the station rows only. more
What this run does not model: arrival patterns, contention between procedures for the same person, shift patterns, weekends, learning curves, and the cost of anything. more
Run it again, going wrong
The same unit, the same stations, broken the way the estate already records breaking
This is the same unit on the same stations, breaking. more
No break below was chosen. more
One play head, two tracks, the same scale. The clean run stops when it runs out of stations; the other one keeps going.
As written
6 stations, nothing waiting, nothing sent back
0 min of 15.6 days
now Frame · Horizon Scanning Agent · 32 hrs
As the ledger has it
the same stations, plus 3 categories the estate already counts
0 min of 15.8 days
now Frame · Horizon Scanning Agent · 32 hrs
What breaks, and where it is counted
No break below was chosen. more
What the two runs say together
3 counted categories land on this procedure. more
What this run cannot claim
These breaks are shown together on one unit so the shape of a bad day fits on one screen. more
Two clocks run. Worked time is the sum of the time the work is actually being done … more
Roles and responsibilities
7 named parties
The responsibility grid is assigned by a rule, not lifted from a chart. more
| Party | RACI | Steps | Duty | Escalates to |
|---|---|---|---|---|
Regulatory Affairs Orchestrator orchestrator | Runs the line | 0 | Sequences this line, holds its timetable and decides what has to surface to a person. more | Raises to VP Regulatory Affairs when a unit falls outside the envelope or confidence drops below the floor. |
Horizon Scanning Agent agent A2% autonomy · ceiling A2% 97% clean · 6% overridden | Responsible | 1 | Executes the regulatory affairs step it owns, posts its evidence, and hands the unit to the next stage. | Escalates to VP Regulatory Affairs when the unit falls outside the decision envelope or confidence drops below the floor. |
Impact Assessment Agent agent A2% autonomy · ceiling A2% 93% clean · 7% overridden | Responsible | 1 | Executes the privacy & data protection step it owns, posts its evidence, and hands the unit to the next stage. | Escalates to Data Protection Officer when the unit falls outside the decision envelope or confidence drops below the floor. |
Submission Drafting Agent agent A2% autonomy · ceiling A2% 90% clean · 4% overridden | Responsible | 1 | Executes the regulatory science step it owns, posts its evidence, and hands the unit to the next stage. | Escalates to VP Regulatory Science when the unit falls outside the decision envelope or confidence drops below the floor. |
Regulator Correspondence Agent agent A2% autonomy · ceiling A2% 95% clean · 5% overridden | Responsible | 1 | Executes the regulatory affairs step it owns, posts its evidence, and hands the unit to the next stage. | Escalates to VP Regulatory Affairs when the unit falls outside the decision envelope or confidence drops below the floor. |
Change Implementation Agent agent A2% autonomy · ceiling A2% 89% clean · 2% overridden | Responsible | 1 | Executes the regulatory affairs step it owns, posts its evidence, and hands the unit to the next stage. | Escalates to VP Regulatory Affairs when the unit falls outside the decision envelope or confidence drops below the floor. |
VP Regulatory Affairs person | Accountable and responsible | 1 | Holds 1 decision on this line. more | Accountable to VP Regulatory Affairs for the decisions held here. |
Decision points and escalation
1 places this procedure stops
06 · GC ratify
5.4 daysHeld for a named human when the unit exceeds the regulatory item decision envelope, when confidence falls below the floor, or when a policy clause is engaged.
VP Regulatory Affairs
Handoffs out of this procedure
Nothing leaves this procedure for another function. It completes inside Regulatory Affairs.
The rules this procedure runs inside
4 governing rules
Regulatory Affairs Decision Envelope
activeLG5-POL-200 · envelope · vv2.1
Agents in this lane may act without a human when the regulatory item sits inside the stated value, risk and confidence envelope. more
Approved by VP Regulatory Affairs · in force 2025-12-18 · reviewed 2026-07-05
Binds Horizon Scanning Agent, Impact Assessment Agent, Submission Drafting Agent, Regulator Correspondence Agent, Change Implementation Agent
EU · UK
Regulatory Affairs Evidence Standard
activeLG5-POL-201 · evidence · vv5.0
Every autonomous decision writes inputs, the rule version applied, the model and prompt version, the output and a reversal path. more
Approved by VP Regulatory Affairs · in force 2025-07-04 · reviewed 2026-08-11
Binds Horizon Scanning Agent, Impact Assessment Agent, Submission Drafting Agent, Regulator Correspondence Agent, Change Implementation Agent
Global
Regulatory Affairs Escalation Rule
activeLG5-POL-202 · escalation · vv3.0
Escalation is mandatory when confidence falls below the floor, when two options sit inside the confidence band, or when a break condition on a ratified position fires. more
Approved by VP Regulatory Affairs · in force 2026-04-03 · reviewed 2026-07-19
Binds Horizon Scanning Agent, Impact Assessment Agent, Submission Drafting Agent, Regulator Correspondence Agent, Change Implementation Agent
LATAM · US
Regulatory Affairs Autonomy Ceiling
activeLG5-POL-203 · ceiling · vv4.8
The ceiling for this lane is 68 on the platform scale. more
Approved by VP Regulatory Affairs · in force 2025-05-28 · reviewed 2026-05-16
Binds Horizon Scanning Agent, Impact Assessment Agent, Submission Drafting Agent, Regulator Correspondence Agent, Change Implementation Agent
Global
Systems this procedure touches
1 named · 0 connected
System attribution is a rule, not a reading. more
| System | Vendor | Domain | Criticality | Steps | Connection |
|---|---|---|---|---|---|
| Contract Lifecycle Management | Icertis | legal | high | 6 | modeled |
0 of the 1 systems on this procedure is connected to the platform, and none of the twenty-six in the estate register is. 1 of them are marked as taking a write back, which is a property of the system, not a live path from here.
How it performs
End to end
15.6 days
Summed from the time each step sits, standard 29.8 days — running at 52% of the standard.
Touchless
35%
Agent share
83%
A week
1
In flight
133
Effort a week
7,723 human minutes · 14,752 agent minutes
Volume multiplied by the time on each step. more
Assurance over this procedure
4 governance gates sit above it
The twenty-four controls and eighteen exception classes in this platform are held at estate level … more
| Gate | What trips it | Who releases it | Clock | Waivable |
|---|---|---|---|---|
Any external legal communication approval | Every communication leaving the enterprise on a legal matter | Named lawyer | Same day | No |
Contract above $250,000 approval | Contract value above $250,000 or nonstandard indemnity, unlimited liability or IP transfer | General Counsel delegate | 2 business days | No |
Settlement or regulator filing approval | Any settlement, filing or regulator submission | General Counsel | Case dependent | No |
Citation and provenance audit oversight | Every agent-produced document with external authority citations | Citation Verifier plus lawyer sign-off | Pre-release | No |
Next to it on the same team
Regulatory Affairs
What this document is and is not
These procedures describe the modeled estate. more
Actions
What is waiting on a person
What one procedure document gives you, and what to check before you treat it as the standard.
named approvers appear across the library
Every decision point on every procedure carries a job title, not a queue. more
steps in the library hand their unit to another function
A handoff is where a procedure stops being one team’s problem. more
controls exist in the estate, and they belong to no procedure in particular
Controls and exception classes are held estate-wide. more
Operations
What this desk is allowed to start
A surface that only reports is not operable. more
Trigger and bound
A procedure document prints purpose, scope, entry and exit, the numbered steps with the actor on each, the roles and their RACI position, the swimlane, the decision points and escalation, the handoffs, the governing rules with version and approver, the systems by rule and the timings. more
Live observability
What the record shows right now
The whole library, by lane, so a single document can be read against the estate it came from. more
Current distribution
2,748 steps
Is policy and strategy coming to fruition
Whether the written intent is holding here
Half. The document is complete and every actor on it is measured more
Not holding on the record
A procedure here carries a version, an approver, an in-force date and a last-review date. more