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What we claim (and don't)

Lex Custis is a compliance engine, not a compliance blanket. This page states exactly what OSS v0.1 covers, what it doesn't, and where the honest gaps lie so you can plan the rest of your compliance programme.

Claims we stand behind

  1. Tamper-evident event logs under Art. 12. The HMAC hash chain with a per-organisation HKDF subkey, held outside Postgres, provides cryptographic integrity beyond what the regulation minimally requires. A regulator's technical team can verify this offline.

  2. Append-only at the DB role level. REVOKE UPDATE/DELETE/TRUNCATE ON audit_logs FROM lexcustis. No bypassable PostgreSQL RULE. The oversight table is separate.

  3. A regulator-ready Annex IV dossier in one click. Bundles Art. 11 + 12 + 15 + 53 + 73 evidence with a per-file SHA-256 manifest.

  4. An Art. 73 serious-incident workflow with correct Art. 3(49) classification, per-category SLA windows (10 / 2 / 15 / 72 h), status machine, and regulator-ready JSON export.

  5. Tenant isolation. Every query is scoped by organization_id; cross-tenant leaks are enforced by integration tests in CI.

  6. Art. 14 human-oversight records. Accept / modify / reject per inference, separated from the append-only chain.

  7. Art. 50 AI-generated markers. Every AI response carries a visible marker in the UI and in exports.

  8. Multi-LLM + EU-sovereign default. Ships Mistral and Ollama in OSS. Ships a provider ABC so any OpenAI-compatible endpoint works.

  9. Rate-limited and cost-capped. slowapi + per-org daily chat cap prevent cost-DoS.

  10. Open source. Every line of the compliance-claim-critical code is AGPL-3.0 in the public repo. No hidden back-channels.

What we do not yet cover (v0.1 OSS)

  • Art. 9 risk-management system with a lifecycle UI. The dossier contains a boilerplate risk-assessment section only. Commercial edition adds a real risk register. If you need it today, handle the register outside the product and attach to the dossier.

  • Art. 10 data-governance registry. The provider manifest captures the inference data path, but we don't (yet) track training-data source, lineage, representativeness statement. Commercial edition adds this.

  • Art. 13 versioned IFU generator. The dossier includes intended purpose + limitations at a high level. A per-deployer, per-release IFU generator is commercial edition.

  • Art. 14 pause-system toggle. The regulation expects an operator to be able to stop the system. OSS v0.1 records oversight actions but does not implement an org-level "pause AI" kill switch. Commercial edition adds it. (If you need this tomorrow, put a feature flag in front of your chat endpoint and flip it manually.)

  • Art. 15 drift detection. OSS ships aggregate metrics. Rolling KS/PSI drift tests with alerting are commercial edition.

  • Art. 17 QMS documentation set. Lex Custis ships a QMS posture (CI, SECURITY.md, release discipline); you still need to stand up your own QMS on top.

  • Art. 27 FRIA wizard. Commercial edition.

  • Art. 53 upstream pinning by model snapshot. OSS records the provider + model string used; pinning the provider's exact Art. 53 disclosure URL per model snapshot is v0.2.

  • Signed dossier (ed25519 + RFC-3161). OSS produces an unsigned bundle. Commercial edition signs + timestamps.

  • Refresh-token revocation table. OSS uses stateless JWTs. If a user's refresh token is stolen it's valid until expiry. Commercial edition adds a revocation store.

  • Column-level envelope encryption of user_prompt and ai_response. They are stored plaintext in Postgres today. If your threat model includes a backup being stolen, this matters. Commercial edition adds it.

  • SSO (SAML / OIDC). Commercial edition.

  • One-click EU-sovereign deploy (Scaleway / Hetzner Terraform modules). OSS ships the install.sh for any VM; a tested public Terraform module for one-click provisioning to a specific cloud is commercial edition. (The OSS installer is fine on a pre-provisioned VM — it's the provisioning step that isn't yet scripted.)

  • Monitoring, alerting, backups, DR runbook. Commercial edition operates this for you.

  • EU AI Act indemnification. We don't offer this in OSS. Enterprise tier does.

Honest stance

Compliance is a programme, not a product. Lex Custis makes most of the engineering evidence the regulation asks for automatic and verifiable. It does not replace:

  • Your legal counsel on scope interpretation.
  • Your compliance officer on QMS, risk management, and authority correspondence.
  • Your DPO on data-protection impact assessments and Art. 10/27 work.

Treat Lex Custis as the instrumentation layer that makes your team's decisions auditable. That's it. That's the value.