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AI Governance and Human Approval

PensionsPortal.ie uses AI to generate draft advice content, but all AI outputs must be reviewed and explicitly approved by a human broker before they can be issued to a client. This is not merely a policy requirement — it is technically enforced in the application.

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How Human Approval is Technically Enforced

The system maintains a strict separation between AI-generated drafts and approved content at the database schema level:
FieldPurpose
aiDraftStores the raw AI-generated output. Never directly visible to clients.
approvedContentStores content that has been explicitly reviewed and approved by a licensed broker. This is what is issued.
An AI draft cannot be transmitted to a trustee client without the broker first reviewing it and moving it to approvedContent through the approval workflow. There is no pathway to issue AI-generated content without this explicit approval step.

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Change Proposal Model

Any proposed change to scheme documents or advice outputs goes through a ChangeProposal domain object, which enforces a lifecycle:
  1. Draft — AI generates a proposal; status is draft
  2. Under review — Broker reviews the proposal
  3. Approved — Broker explicitly approves; proposal moves to approved status
  4. Issued — Only approved proposals can be issued to clients
This lifecycle is enforced in the application logic and cannot be bypassed by a user-facing action.

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User-Facing Disclosure

All AI-assisted outputs displayed to brokers include a clear disclosure:
“AI-Assisted Draft — Requires broker review and approval before issue”
This disclosure appears in the SoS Drafter (src/components/ai/sos-drafter.tsx) and related components.

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Audit Trail

Every approval action is logged with:
  • The broker user ID
  • The timestamp of approval
  • The diff between the AI draft and the approved content (where applicable)
This creates a complete audit trail for regulatory purposes, including for IORP II and DORA incident review.

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Regulatory Basis

This governance model is designed to comply with:
  • IORP II Article 25 — Trustee obligation to ensure advice is from qualified persons
  • Central Bank of Ireland consumer protection requirements — Suitability and record-keeping obligations for regulated advice
  • EU AI Act (upcoming) — Human oversight requirements for high-risk AI systems in financial services
For trustees: AI-generated content on PensionsPortal.ie is always an intermediate draft. Scheme trustees receive only content that has been reviewed and approved by a qualified human broker. The platform does not permit automated issuance of AI-generated advice.