Audience: C-suite, Board Risk Committees, regulators/supervisors, enterprise architects, AI platform engineers, model risk teams, AI safety researchers. Scope: Fortune 500, Global 2000, and G-SIFI financial institutions operating across US, UK, EU, APAC.
This blueprint provides a regulator-ready operating model for advanced AI (including frontier model usage and potential AGI/ASI-adjacent capabilities) anchored to:
- EU AI Act implementation windows (GPAI obligations from 2 Aug 2025, broad application from 2 Aug 2026).
- NIST AI RMF 1.0 and operational playbooks.
- ISO/IEC 42001 AI management systems as certifiable management-system backbone.
- Financial-services model risk and prudential expectations (SR 11-7, Basel-aligned governance, PRA/FCA, MAS, HKMA).
It combines policy, technology, assurance, and response engineering in one reference architecture:
- Three-lines-of-defense AI governance with Board accountability.
- Compliance-as-code (OPA policies + SDLC gates + immutable evidence).
- Model risk lifecycle controls (inventory, validation, drift, challenge, usage restrictions).
- AGI/ASI safety controls (capability thresholds, staged release, containment, kill-switches, compute governance).
- 2026–2030 phased implementation and resource plan.
Date clarity (as of March 26, 2026):
- EU AI Act: obligations already partially active (e.g., prohibited practices and GPAI-related timelines), with major high-risk obligations broadly applying in 2026.
- NIST AI RMF 1.0 remains foundational and is being evolved operationally through companion resources.
- US EO 14110 was issued on Oct 30, 2023 and later rescinded on Jan 20, 2025; organizations should treat it as a historical policy driver and map current obligations to active agency/regulator requirements.
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EU AI Act (High-Risk + GPAI)
- Risk classification, provider/deployer obligations, technical documentation, human oversight, logging, transparency, post-market monitoring, incident reporting.
- For banks/insurers/market infrastructure: materially relevant for creditworthiness, fraud, AML, identity, HR screening, customer communications, and GPAI-enabled decision support.
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NIST AI RMF 1.0
- Four functions: Govern, Map, Measure, Manage.
- Use as common control language across legal, risk, engineering, and internal audit.
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ISO/IEC 42001
- AI management system (AIMS): policy, roles, controls, objectives, internal audit, continual improvement.
- Use to institutionalize governance operating rhythm and external assurance.
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OECD AI Principles
- Values-based baseline: robustness, transparency, accountability, human-centered outcomes.
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Data/privacy and conduct regimes
- GDPR (lawfulness, purpose limitation, data minimization, rights, DPIA, transfers).
- FCRA/ECOA (US consumer lending fairness/adverse action explainability).
- Consumer Duty (UK) and analogous fair outcomes obligations.
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Prudential/model risk supervision
- SR 11-7 model risk management discipline.
- Basel III governance, capital and operational risk interaction.
- PRA/FCA, MAS, HKMA expectations on model governance, outsourcing, operational resilience, and accountable senior management (incl. SMCR in UK).
Create a unified control catalog with 12 control families:
- Governance & accountability
- AI system inventory & tiering
- Data governance & lineage
- Development controls & secure SDLC
- Validation & independent challenge
- Explainability & human oversight
- Fairness/non-discrimination & consumer protection
- Logging, monitoring, and incident response
- Third-party/outsourcing and GPAI supplier controls
- Cybersecurity & resilience
- Change/release management and kill-switch controls
- Documentation, records, and regulatory reporting
Each family maps to legal articles/sections, internal policy IDs, technical controls, test procedures, evidence artifacts, and accountable role (RACI).
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Board Risk Committee / Technology Committee
- Approves AI risk appetite and annual AI assurance plan.
- Receives quarterly reports: high-risk inventory, material incidents, concentration risks (vendors/models), and unresolved exceptions.
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Executive AI Governance Council (EAGC)
- Chaired by CRO/CAIO with CISO, CIO/CTO, CDO, General Counsel, Compliance, Internal Audit observer, and business heads.
- Decision rights: model tiering, production approvals for high-risk AI, exception waivers, emergency shutdown authority.
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Three Lines of Defense
- 1LOD: Product/engineering owns controls in design and operations.
- 2LOD: Risk/compliance sets policy and challenges controls.
- 3LOD: Internal Audit tests design/operating effectiveness.
- Model Owner: business accountability and usage boundaries.
- Model Validator: independent testing (performance, stability, bias, explainability, stress).
- Data Owner/Steward: lawful basis, quality, lineage, retention.
- AI Safety Officer: frontier-capability oversight, containment protocols.
- SMF/Accountable Executive (UK): explicit statement of responsibilities for AI governance outcomes.
- Tier 0: Non-material productivity AI (low impact).
- Tier 1: Customer-influencing, non-decisional.
- Tier 2: Material operational or financial impact.
- Tier 3 (High-Risk): Rights/safety/credit/access impacts, prudential impact, regulatory materiality.
- Tier 4 (Frontier/GPAI/Systemic): advanced capabilities with broad emergent risk or high compute dependency.
Tier drives minimum controls, approvers, testing depth, and monitoring intensity.
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Engagement layer
- Channels/apps, including Next.js explainability frontends for model cards, rationale views, adverse action explanation workflows, override capture.
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Decision & orchestration layer
- Business services invoking models through policy-enforced gateways.
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AI runtime layer
- Traditional ML + LLM/GPAI services with model registry and feature/prompt pipelines.
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Governance control plane
- OPA policy engine (pre-deploy and runtime checks).
- Governance sidecars in Node.js/Python for telemetry, policy attestations, and evidence bundling.
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Evidence and audit layer
- Kafka-based immutable audit streams with retention controls and downstream WORM storage.
- Cryptographic integrity checks, tamper-evident hashes, signed attestations.
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Platform/security layer
- Container orchestration (including hardened Docker Swarm clusters where used), secrets management, IAM, KMS/HSM, network segmentation.
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Automation layer
- Terraform + CI/CD governance automation with policy gates, segregation of duties, break-glass controls, and full deployment provenance.
- Build-time
- Dependency and SBOM scanning, provenance (SLSA-aligned), secrets scanning, policy linting.
- Pre-deploy
- Mandatory risk tier metadata, validator sign-off for Tier 3+, fairness and robustness thresholds.
- Deploy-time
- OPA admission controls, signed artifacts only, environment policy matching.
- Runtime
- Drift, performance, bias, abuse, prompt-injection/jailbreak telemetry; automatic fallback and throttling.
- Post-incident
- Forensic replay from immutable logs; regulator report packs generated from evidence graph.
- Event classes: model registration, data version, approval decisions, inference metadata, override actions, user notices, incident events.
- Integrity pattern:
- Append-only Kafka topics with strict ACLs.
- Periodic hash-chaining and notarized checkpoints.
- Export to WORM-capable storage (retention/legal hold aligned to jurisdictional rules).
- Access governance:
- RBAC + ABAC + purpose binding.
- Dual-control for deletion/legal hold release.
- Quarterly entitlement recertification.
Implement policy bundles for:
- Risk tiering and mandatory controls.
- GDPR lawful basis checks and data minimization constraints.
- FCRA/ECOA explanation/notice conditions for lending decisions.
- SR 11-7 model validation prerequisites.
- Geographic controls (EU/UK/APAC residency and transfer restrictions).
- Vendor/GPAI contract clauses and assurance artifacts.
- Pull request gates: policy unit tests, control completeness score, architecture decision record requirement.
- Release gates: validator attestation for Tier 3/4, legal/compliance approval for use-case scope expansion.
- Production gates: runtime guardrail policy hash must equal approved baseline.
- Continuous controls monitoring: daily policy drift scans with exception SLAs.
- Assign product owners to each control family.
- Publish versioned control APIs and SDKs.
- Track control adoption and override rates as key platform metrics.
- Model definition and intended use (explicit prohibited uses).
- Data suitability and representativeness testing.
- Conceptual soundness review (including prompt/process architecture).
- Outcomes analysis (accuracy, calibration, fairness, stability).
- Ongoing monitoring with challenger models and periodic revalidation.
- Change governance for model updates, prompt changes, and dependency changes.
- Credit underwriting / line management
- Adverse action reason mapping, proxy discrimination testing, reason-code traceability.
- Fraud and AML alerting
- Explainable alert prioritization, false-positive governance, escalation to human investigators.
- Treasury and liquidity forecasting
- Stress scenarios, model overlays, conservative fallback in uncertainty spikes.
- Customer communications
- Hallucination controls, approved knowledge bases, compliance phrase libraries.
- Monthly Model Risk Committee for Tier 3/4.
- Mandatory challenger evidence before major threshold changes.
- Sunset criteria for stale or underperforming models.
Define internal capability levels (C1–C5) across autonomy, code-generation potency, cyber capability, persuasion/social engineering potential, and self-improvement indicators.
- C1–C2: standard enterprise controls.
- C3: enhanced red teaming, stricter human-in-the-loop, restricted tool access.
- C4: containment enclave, dual-key approvals, external expert review.
- C5: executive + Board escalation, deployment moratorium pending safety case.
- Isolated execution environments (network egress controls, tool whitelists).
- Strict permission brokering for code execution and external actions.
- Runtime tripwires (policy violation, anomalous autonomy, data exfil signals).
- Immediate revocation pathways (credential kill, model endpoint quarantine).
- Pre-release adversarial evaluation and capability audits.
- External red-team partnerships for frontier systems.
- Harm modeling for misuse scenarios (fraud acceleration, cyber abuse, market manipulation, disinformation).
- Documented safety case with sign-offs by AI Safety Officer, CISO, CRO, and Legal.
- Inventory and classify AI compute assets (on-prem, cloud, accelerated clusters).
- Attribute compute consumption to approved use cases and model IDs.
- Enforce compute quotas by tier and risk class.
- Monitor concentration risk (single cloud/vendor/model dependence).
- Regionalized deployments for data residency constraints.
- Controlled cross-border transfer workflows and transfer impact assessments.
- Model artifact location controls and cryptographic attestation of residency.
- Contractual controls: audit rights, incident notification SLAs, model update/change notification, safety documentation delivery.
- Supplier scorecards: security posture, legal compliance, transparency maturity, resilience.
- Exit strategy: portability plans and emergency substitution playbooks.
The names below are implemented as enterprise capability domains. If your organization already has similarly named products, map by capability rather than brand.
Purpose: central governance control plane.
- Policy registry (OPA bundles, legal mappings, risk thresholds).
- AI system inventory + tiering workflow.
- Approval orchestration and exception management.
- Evidence graph linking artifacts, approvals, runtime telemetry, incidents.
- Regulator report generation packs (EU AI Act technical docs, SR 11-7 evidence excerpts, DPIA links).
Purpose: controlled AI workflow automation.
- Human-in-the-loop task routing by risk tier.
- Role-based approval checkpoints.
- Full action traceability and replay.
- Override reason capture with mandatory rationale taxonomy.
Purpose: standardized runtime integration for models/tools.
- Model gateway with policy enforcement and token/data guardrails.
- Prompt/template registry with approved variants.
- Tool-use broker with least privilege and runtime attestations.
- Multi-model routing with resilience/fallback profiles.
Purpose: governance UX and executive intelligence layer.
- Board and regulator dashboards.
- Risk heatmaps (by business unit, jurisdiction, model family).
- Control effectiveness KPIs and KRIs.
- Incident command center views and postmortem knowledge base.
- Establish unified AI policy framework and control taxonomy.
- Complete enterprise AI inventory and tiering baseline.
- Deploy minimum compliance-as-code in CI/CD.
- Stand up immutable logging and evidence retention baseline.
- Launch regulator engagement pack and supervisory briefing cycle.
Exit criteria:
- 100% production AI systems inventoried and tiered.
- Tier 3+ models have independent validation and monitoring.
- Board-approved AI risk appetite in force.
- Scale control automation across all material business lines.
- Implement supplier/GPAI assurance program and concentration dashboards.
- Deploy standardized explainability UX for regulated decisions.
- Add incident simulation exercises with regulators (tabletop).
Exit criteria:
-
90% policy controls continuously monitored.
- Mean time to evidence pack (regulator request) < 72 hours.
- Documented AI incident playbooks tested at least twice annually.
- Integrate frontier capability thresholding and containment controls.
- Introduce quantitative model risk capital overlays where relevant.
- External assurance reviews against ISO/IEC 42001 and sector obligations.
Exit criteria:
- Tier 4 systems subject to safety case approval.
- End-to-end control testing demonstrates reproducible compliance evidence.
- Continuous adaptive governance (policy auto-tuning with human approval).
- Cross-border supervisory interoperability and shared evidence schemas.
- Mature scenario planning for AGI-discontinuity events.
Exit criteria:
- Enterprise can safely scale advanced AI with stable audit/regulatory outcomes.
- Governance cost-per-model decreases while control efficacy improves.
- AI Governance Office: 15–30 FTE
- Model Risk (AI/GenAI-specialized): 25–60 FTE
- AI Safety/Red Team: 10–25 FTE
- Platform Engineering (governance controls): 30–80 FTE
- Legal/Compliance Privacy specialists: 15–35 FTE
- Internal Audit AI assurance: 8–20 FTE
- Year 1 foundation uplift: policy + platform + controls + validation uplift.
- Year 2–3: automation expansion and supplier assurance.
- Year 4–5: frontier safety, advanced resilience, supervisory interoperability.
Track by capability value stream rather than only cost center:
- Compliance readiness
- Model risk loss avoidance
- Operational efficiency
- Customer trust and conduct outcomes
- Role-specific curricula for executives, model owners, validators, engineers, and investigators.
- Mandatory annual certification for high-risk AI roles.
- Incident command and red-team drills semi-annually.
- % AI systems inventoried and tiered.
- % Tier 3/4 models with current independent validation.
- Policy automation coverage in SDLC and runtime.
- Mean lead time from model change request to compliant release.
- % decisions with usable explanations delivered within SLA.
- Unapproved model or prompt changes detected.
- Fairness threshold breaches by segment.
- Drift beyond tolerance windows.
- Supplier concentration and critical dependency scores.
- Incident severity rate and time-to-containment.
- Supervisory narrative: explain governance design, risk appetite, accountability chain.
- Evidence walk-through: show immutable logs, approvals, validation artifacts, issue remediation.
- Outcome testing: demonstrate fairness/explainability/robustness on recent production data slices.
- Incident readiness: prove command structure, notification timelines, and lessons-learned loop.
- Forward plan: provide roadmap, milestones, and residual-risk treatment.
Prepare jurisdiction-specific annexes (EU, US, UK, SG, HK) with local citations and accountable owners.
- Approve enterprise AI risk appetite and governance charter.
- Complete AI inventory, tiering, and criticality mapping.
- Implement OPA policy baseline for release gates.
- Deploy Kafka immutable logging + WORM retention flow.
- Establish Tier 3/4 model committee and independent challenge cadence.
- Deploy explainability portal for customer-impacting decisions.
- Build supplier/GPAI assurance framework and contract templates.
- Run first enterprise AI incident simulation.
- Deliver Board dashboard and regulator-ready evidence packs.
- Launch AI safety thresholding pilot for frontier-capability systems.
- No high-risk AI in production without independent validation.
- No model change without traceable approval and rollback path.
- No decisioning AI without auditable explanation and human override.
- No frontier-capability deployment without containment and safety case.
- No third-party GPAI dependency without contractual auditability and exit plan.
Treat AI governance as an operating system, not a policy document. The institutions that succeed from 2026–2030 will unify legal interpretation, engineering controls, model risk discipline, and safety science into a single execution fabric with provable evidence.
This blueprint is intentionally implementation-oriented: if adopted with disciplined change management, it enables both supervisory confidence and faster, safer AI scale.
| Control Family | Example Internal Control ID | EU AI Act | NIST AI RMF | ISO/IEC 42001 | FS Regulatory Anchor | Evidence Artifact |
|---|---|---|---|---|---|---|
| Governance & accountability | AIGOV-01 | Governance, accountability obligations | Govern | Clauses on leadership/planning/support | SR 11-7 governance, SMCR accountability | Board minutes, RACI, charter |
| Inventory & tiering | AIGOV-02 | Risk classification, high-risk scoping | Map | Context/risk assessment controls | PRA/FCA model inventory expectations | Inventory export, tier decision logs |
| Data governance | AIGOV-03 | Logging/traceability, data governance dependencies | Map/Measure | Data and operational controls | GDPR, MAS/HKMA data controls | Data lineage graph, DPIA/TIA records |
| Validation/challenge | AIGOV-04 | Conformity/performance support artifacts | Measure/Manage | Performance monitoring and evaluation | SR 11-7 independent validation | Validation reports, challenger results |
| Explainability/oversight | AIGOV-05 | Human oversight and transparency | Govern/Manage | Operational controls for human oversight | FCRA/ECOA, Consumer Duty | Explanation logs, override audit |
| Monitoring/incident response | AIGOV-06 | Post-market monitoring, serious incident handling | Measure/Manage | Improvement and incident handling | Operational resilience expectations | Incident tickets, containment timeline |
| Third-party/GPAI | AIGOV-07 | GPAI and provider/deployer dependency controls | Govern/Map | External provider controls | Outsourcing and third-party risk rules | Contract clauses, supplier scorecards |
Implementation note: treat this as a starting matrix and extend to full article/section-level mappings for each jurisdictional annex.
- Dedicated cluster or logically isolated tenant for governance logs.
- Topic strategy:
aigov.model_registry.eventsaigov.validation.decisionsaigov.runtime.inference.metaaigov.override.actionsaigov.incident.timeline
- Security baseline:
- mTLS between producers/consumers and brokers.
- ACLs by service identity and least privilege.
- Envelope encryption for sensitive payload fields.
- Immutability pattern:
- No compact/delete policy for core evidence topics.
- Daily Merkle root of topic offsets + payload hashes.
- Signed digest escrow and periodic export to WORM object store.
package aigov.release
default allow = false
allow {
input.tier <= 2
input.model_card_exists
input.security_scan_passed
}
allow {
input.tier >= 3
input.model_card_exists
input.security_scan_passed
input.independent_validation_approved
input.legal_compliance_approved
input.explainability_test_passed
}Each AI-serving workload should emit a normalized evidence envelope:
model_id,model_version,prompt_template_id(if applicable)risk_tier,decision_context,policy_bundle_hashinput_data_contract_version,explanation_referencehuman_override_flag,override_reason_codelatency_ms,confidence,safety_filter_eventstrace_id,request_id,jurisdiction_code,timestamp_utc
- Enforce policy checks in plan/apply pipelines (deny drift from approved baseline tags).
- Require signed module versions from trusted registries.
- Bind environment deployment rights to segregated IAM roles.
- Record all approvals and pipeline metadata into the evidence stream.
- Pre-decision checks:
- data recency and completeness controls,
- prohibited-feature proxy screening,
- fairness threshold checks by protected segments (jurisdiction-appropriate).
- Decision-time controls:
- adverse-action reason code determinism,
- explanation generation with plain-language rendering,
- mandatory human review for boundary-score ranges.
- Post-decision monitoring:
- approval/decline distribution drift,
- adverse impact trend analysis,
- customer complaint correlation analysis.
- Alert model transparency scorecards.
- Analyst feedback loop to reduce false positives and detect automation bias.
- Rule-model hybrid fallback when model confidence degrades.
- Governance on suspicious activity narrative generation (factuality controls).
- Stress and reverse-stress testing for forecasting AI.
- Hard limits: AI recommendations cannot auto-execute high-impact market actions without human authorization.
- Real-time anomaly monitors for regime shifts.
- System boundary and intended capability envelope.
- Hazard analysis and misuse threat model.
- Control claims (preventive/detective/corrective) and test evidence.
- Residual risk statement and acceptance authority.
- Monitoring triggers and rollback/kill criteria.
- External review summary (for Tier 4/C4+ systems).
Escalate immediately to executive crisis governance when any of the following are observed:
- sustained autonomous multi-step planning beyond approved scope,
- successful circumvention of policy guardrails during internal red team,
- emergent high-impact cyber capability indicators,
- repeated unsafe behavior despite policy hardening.
Create annexes per operating region using a common template:
- Annex EU: AI Act obligations by role (provider/deployer/importer/distributor), GDPR links.
- Annex US: federal/state consumer and sector obligations, OCC/FRB/FDIC expectations, model risk anchors.
- Annex UK: PRA/FCA + Consumer Duty + SMCR responsibility mapping.
- Annex SG/HK: MAS/HKMA governance expectations and outsourcing/operational resilience dependencies.
Each annex should include:
- legal citation,
- internal policy mapping,
- control owner,
- required evidence,
- regulatory reporting path,
- breach/incident notification timeline.
- Weekly control implementation stand-up (engineering + risk + compliance).
- Monthly AI Governance Council deep-dive (exceptions and KPI/KRI movement).
- Quarterly Board reporting and risk appetite reaffirmation.
- Gate A (Design): controls mapped, RACI complete, architecture approved.
- Gate B (Build): policy-as-code tests pass, evidence pipeline active, docs complete.
- Gate C (Run): monitoring/KRIs stable for 60 days, incident drills complete.
- Gate D (Scale): independent assurance confirms operating effectiveness.
- Enterprise AI policy suite (approved and version-controlled).
- Complete AI inventory with risk tiering rationale.
- High-risk model validation dossiers and committee minutes.
- Immutable evidence architecture records and retention/legal hold policy.
- Incident response runbooks and exercise outputs.
- Third-party/GPAI risk assessments and contract clause library.
- Board and executive reporting packs (KPI/KRI trend history).
- Forward remediation plan with dates, owners, and residual-risk acceptance.
This package should be deliverable within 48–72 hours under supervisory request conditions.
To accelerate execution and reduce ambiguity, this blueprint includes machine-readable implementation assets:
governance_blueprint/control_mapping_matrix.csv— starter control crosswalk with owners, evidence, and review frequencies.governance_blueprint/roadmap_2026_2030.yaml— phased program plan and exit criteria.governance_blueprint/opa/release_gate.rego— reference OPA release policy for risk-tiered approvals.governance_blueprint/evidence_event_schema.json— normalized evidence event contract for Kafka/WORM pipelines.governance_blueprint/artifact_manifest.json— package manifest with SHA-256 integrity hashes for governance assets.
These artifacts are intended to be adapted into enterprise repositories and integrated into SDLC gates, model lifecycle pipelines, and supervisory evidence workflows.
To prevent documentation drift and ensure governance artifacts remain deployment-ready, include an automated static validation step in CI:
python3 governance_blueprint/validation/validate_artifacts.pyThis verifies:
- control mapping completeness and required fields,
- evidence event schema structure,
- OPA policy structure for tiered release gates,
- roadmap structural integrity checks.
Reference implementation notes are provided in:
governance_blueprint/validation/README.mdgovernance_blueprint/validation/validate_artifacts.py
For validator quality assurance, run:
python3 governance_blueprint/validation/selftest_validate_artifacts.pyFor CI enforcement, wire these checks into .github/workflows/governance-artifacts-ci.yml (or equivalent enterprise pipeline controls).
For manifest integrity lifecycle management, generate/check hashes with:
python3 governance_blueprint/validation/generate_artifact_manifest.py
python3 governance_blueprint/validation/generate_artifact_manifest.py --checkFor developer workstation guardrails, optionally enable local hooks with .pre-commit-config.yaml.
For consistency between local and CI execution paths, use governance_blueprint/validation/run_validation_suite.py as the canonical entrypoint.
If preferred, run the equivalent repo-level Make targets (make gov-suite, make gov-suite-json) for developer ergonomics.