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Rework MI-19 as Release Approval Gating; sharpen the MI-12 boundary - #99

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AlexKantor87:mi-19-outcome-focused-requirements-and-regulatory-mappings
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AlexKantor87:mi-19-outcome-focused-requirements-and-regulatory-mappings

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@AlexKantor87 AlexKantor87 commented Aug 17, 2026

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Reworks MI-19 into Release Approval Gating and sharpens its boundary with MI-12.

MI-19 — Release Approval Gating

Renamed and broadened. The gate applies to any versioned release — a software artifact, an infrastructure-as-code change set, or both — not only application software. The URL slug is unchanged to preserve existing links.

Requirements refocused on outcomes rather than implementation:

  • The pipeline-specific enforcement requirement ("MUST be enforced by the release pipeline... pipelines MUST verify... MUST fail") is now a mechanism-neutral property: production deployment MUST be technically prevented while the required approval is absent or revoked. The ways to implement that (pipeline, environment protection rules, ITSM lock, policy engine) move to Examples & Commentary.
  • Approval binding is now to an immutable, content-addressable identity rather than the inline examples ("signed artefact digest or tagged commit SHA") — a tag is mutable, and a commit identifies source rather than the released artefact. This follows the wording direction in SDLC022 - Code Review Feedback #81.
  • The two emergency-release requirements are removed: control bypass is being consolidated into a dedicated control (SDLC022 - Code Review Feedback #81) rather than restated per mitigation.

Regulatory mappings added, following the format piloted on MI-1 in #88: NIST 800-53 (CM-3, CM-5, CA-6), EU DORA (Art. 9(4)(e), RTS Arts. 16(2) and 17(1)), UK FCA/PRA (SYSC 15A, SS1/21, FCA technology-change review), FFIEC DAM (II Governance, VII Maintenance).

Quality pass: the empty ## Links section is populated; lowercase cross-refs; meta-reference phrasing removed from the Description; the "time-limite" typo resolved by removing the emergency tier from the tiered-approval example.

MI-12 / MI-19 boundary

Reviewed side by side, MI-19's automated-checks paragraph re-enumerated MI-12's gate criteria (tests passed, vulnerability thresholds, scan attestations), making the two controls read as duplicates. They answer different questions:

  • MI-12 evaluates the current technical posture of an artefact at each deployment event — the same version can pass today and be blocked tomorrow as new findings emerge, scans age, or remediation timelines are breached.
  • MI-19 issues a durable, attributable approval record per release, bound to the release identity; that approval state is one of the conditions a deployment gate verifies.

Both descriptions now state this boundary explicitly and cross-link each other. MI-19's automated-checks paragraph now describes confirming that required evidence and decisions exist (mi-12, mi-1, mi-20, mi-3) and producing the approval record, leaving posture evaluation to mi-12.

MI-12's override requirements and its Emergency Overrides example are removed for the same reason as MI-19's: bypass consolidation per #81.

Refs #96, #81

Remove implementation detail from the requirements: the pipeline-specific
enforcement requirement becomes a mechanism-neutral prevention property,
and the inline identifier examples (artefact digest, tagged commit SHA)
give way to 'immutable, content-addressable identity' per the direction
agreed in finos-labs#81. Enforcement mechanism options move to Examples.

Remove the two emergency-release requirements: control bypass is being
consolidated into a dedicated control (finos-labs#81) rather than repeated per
mitigation.

Add regulatory mappings (NIST 800-53, EU DORA, UK FCA/PRA, FFIEC DAM)
following the MI-1 pilot format, populate the empty Links section, and
apply house style (lowercase cross-refs, spaced em dashes, remove
meta-reference phrasing). Addresses the MI-19 'no regulatory references'
blocker in finos-labs#96.

Signed-off-by: AlexKantor87 <alex@kosli.com>
Broaden the title and summary so the gate applies to any versioned
release - a software artifact, an infrastructure-as-code change set, or
both - not only application software versions. Align the first
requirement and the frontmatter comments in mi-20 and ri-12.

Signed-off-by: AlexKantor87 <alex@kosli.com>
MI-19's Automated Policy Checks paragraph re-enumerated MI-12's gate
criteria almost verbatim, making release approval read as deployment
gating repeated per version. Rewrite it to confirm required evidence
and decisions exist (mi-12, mi-1, mi-20, mi-3) and to state that the
distinguishing output is a durable, attributable approval record;
technical posture evaluation stays mi-12's domain.

Add the reciprocal boundary to MI-12: posture is evaluated per
deployment event, release authorisation is mi-19's concern, and the
approval state is one of the conditions a gate verifies. Cross-link
the two in both directions.

Remove MI-12's override requirements and Emergency Overrides example
for the same reason MI-19's were removed: bypass is consolidating into
a dedicated control (finos-labs#81). Also lowercase the SDLC-PREV-011 cross-ref
per house style.

Signed-off-by: AlexKantor87 <alex@kosli.com>
@AlexKantor87 AlexKantor87 changed the title MI-19: outcome-focused requirements, regulatory mappings, empty Links fixed MI-19 Release Approval Gating: outcome-focused requirements, regulatory mappings, MI-12 boundary Aug 17, 2026
@AlexKantor87 AlexKantor87 changed the title MI-19 Release Approval Gating: outcome-focused requirements, regulatory mappings, MI-12 boundary Rework MI-19 as Release Approval Gating; MI-12 boundary; MI-21 placement fix Aug 17, 2026
@AlexKantor87

AlexKantor87 commented Aug 17, 2026

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The MI-21 work has moved to its own pull request: #100.

@AlexKantor87
AlexKantor87 force-pushed the mi-19-outcome-focused-requirements-and-regulatory-mappings branch from 4b5934e to ead3f05 Compare August 17, 2026 17:41
@AlexKantor87 AlexKantor87 changed the title Rework MI-19 as Release Approval Gating; MI-12 boundary; MI-21 placement fix Rework MI-19 as Release Approval Gating; sharpen the MI-12 boundary Aug 17, 2026
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