> ## Documentation Index
> Fetch the complete documentation index at: https://docs.pensionsportal.ie/llms.txt
> Use this file to discover all available pages before exploring further.

# AI Governance and Human Approval

> How PensionsPortal.ie enforces human review of AI-generated content before issuance.

# 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.

## How Human Approval is Technically Enforced

The system maintains a strict separation between AI-generated drafts and approved content at the database schema level:

| Field             | Purpose                                                                                                     |
| ----------------- | ----------------------------------------------------------------------------------------------------------- |
| `aiDraft`         | Stores the raw AI-generated output. Never directly visible to clients.                                      |
| `approvedContent` | Stores 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.

## 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.

## 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.

## 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.

## 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.