<?xml version="1.0" encoding="UTF-8"?><?xml-stylesheet type="text/xsl" href="/rss.xsl"?><rss version="2.0" xmlns:content="http://purl.org/rss/1.0/modules/content/"><channel><title>Unmitigated Risk</title><description>Essays by Ryan Hurst on security design, the WebPKI, compliance, and AI.</description><link>https://unmitigatedrisk.com/</link><language>en-us</language><item><title>Rejection Is Not a Verdict</title><link>https://unmitigatedrisk.com/2026/09/rejection-is-not-a-verdict/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/09/rejection-is-not-a-verdict/</guid><description>Life offers an almost unlimited supply of chances to be rejected, and it is easy to take each one personally.</description><pubDate>Tue, 15 Sep 2026 19:31:09 GMT</pubDate><content:encoded>&lt;p&gt;Life offers an almost unlimited supply of chances to be rejected, and it is easy to take each one personally.&lt;/p&gt;
&lt;p&gt;Picture a young man who works up the nerve to cross a room, tell a woman he finds her beautiful, and ask for her number. She says no, and he walks away believing she looked him over, weighed what she saw, and found it lacking.&lt;/p&gt;
&lt;p&gt;That may not be what happened at all. She may have slept badly, or been running late, or just ended a relationship, or be seeing someone already. He may have reminded her of someone she can’t stand. She may simply not have wanted to meet anyone that afternoon. If he approached the same woman a year later and said nearly the same words, he might get a very different answer, and nothing about him would need to change for that to happen. The timing would be different, and so would her circumstances and priorities.&lt;/p&gt;
&lt;p&gt;A rejection arrives as a yes or a no, which makes it feel like a clean judgment. The decision behind it is anything but clean. It is an equation with many variables, most of which you can’t see and many of which have nothing to do with you.&lt;/p&gt;
&lt;p&gt;That is true of nearly every rejection you will face, whether it comes from an employer, an investor, a customer, an editor, or an admissions committee, and learning to read rejection accurately is a large part of what long-term success requires. Internships make a good example because they are where most people first meet rejection in large numbers, usually before they have learned how to interpret it.&lt;/p&gt;
&lt;h2&gt;What the rejections seem to say&lt;/h2&gt;
&lt;p&gt;You apply for an internship and get turned down. You apply for another and get turned down again. After twenty of these it is natural to conclude that nobody wants you, and after fifty that conclusion can harden into a belief that you just aren’t good enough.&lt;/p&gt;
&lt;p&gt;Consider what is happening on the other side of those applications. For the student, landing an internship may be the most important thing in their life that year. For the company, filling it may sit somewhere around number 87 on someone’s list. Internships serve real purposes. They build a pipeline of future hires, give junior employees practice at mentoring, bring in fresh ideas, and let successful people and organizations give something back. They also cost time. Someone has to read the applications, run the interviews, scope a project an intern can actually finish, and answer that intern’s questions all summer.&lt;/p&gt;
&lt;p&gt;So the person whose future seems to hang on the decision is often dealing with someone for whom that decision is one small part of a much larger job. That alone injects a great deal of randomness into the outcome, and it is only one variable among many.&lt;/p&gt;
&lt;h2&gt;Equally capable, different outcomes&lt;/h2&gt;
&lt;p&gt;Imagine two applicants who are, by any reasonable measure, equally capable. One lives ten minutes from the office and the other would have to move across the country. The local candidate gets the offer, and nobody involved has concluded that the other person is worse.&lt;/p&gt;
&lt;p&gt;The two could also differ only in when they applied. One sends an application the week the posting goes up, and the other sends one a month later, after the hiring manager already has a shortlist and has stopped reading new applications closely. Applying early doesn’t settle the matter either, because the first applications can sit untouched until someone finds time for them, and whichever resume happens to be on top of the pile when the reviewer finally sits down gets the careful read. Neither applicant can see where they landed in that order, and the result says nothing about which of them is better.&lt;/p&gt;
&lt;p&gt;Or imagine that one of two otherwise identical candidates spent more time on their resume. Instead of listing the name of a class project, they explain what they personally built, and their accomplishments are easy to follow. They get the interview even if they aren’t the stronger engineer, because they did a better job of showing what they had done.&lt;/p&gt;
&lt;p&gt;Cover letters work the same way. Two letters can be equally well written while only one explains why this particular company interests the applicant and connects something the applicant has already done to the company’s work. That letter lands with the person reading it. Hand the same two letters to a different reader and the result could flip.&lt;/p&gt;
&lt;p&gt;One candidate might figure out who leads the group they want to join, reach out on LinkedIn with a thoughtful question, and become a real person instead of another PDF in an applicant tracking system. Another might have an uncle who knows someone at the company and says, “You should at least talk to this kid.” Neither move guarantees anything, because the candidate still has to perform. But one application now gets ten minutes of attention while the other gets twenty seconds, and that difference can decide the outcome.&lt;/p&gt;
&lt;h2&gt;Differences that seem too small to matter&lt;/h2&gt;
&lt;p&gt;Suppose an aerospace company receives applications from two computer science students with similar grades, similar projects, and no prior internships. One of them happened to take private pilot ground school, and the hiring manager flies airplanes. It isn’t hard to guess which resume gets a second look.&lt;/p&gt;
&lt;p&gt;The deciding detail could just as easily be a class project in computer vision when the group has an imaging project planned for the summer, or a university paper supervised by a professor the interviewer knows, or a personal project written in Rust at a company that builds in Rust. The hiring manager might have gone to UW and remember it fondly, or might hold an irrational grudge against it. People make these decisions, and people bring their interests, associations, biases, and moods along with them.&lt;/p&gt;
&lt;p&gt;Sometimes the first filter isn’t the hiring manager at all. A recruiter works from a checklist an engineering manager handed over, without understanding the technology behind it. Your experience is relevant, but you described it in different terms, so you are screened out. Another candidate used the exact words on the checklist and gets an interview. That result says a lot about the screening process and very little about the relative potential of the two applicants.&lt;/p&gt;
&lt;h2&gt;The variables that belong to you&lt;/h2&gt;
&lt;p&gt;I keep the Serenity Prayer on my desk. Whatever you make of its religious framing, its central idea is practical. Learn to tell the things you can change from the things you can’t, and put your effort into the first group.&lt;/p&gt;
&lt;p&gt;You have no say over who reviews your resume, how much time they have to spend on it, or where your application sits in the pile when they start reading. You can’t choose who else applies, including the CEO’s neighbor’s daughter. You can’t stop a company from losing a contract and freezing hiring the week before your interview, and you can’t pick where the hiring manager went to school.&lt;/p&gt;
&lt;p&gt;You do have a say in whether your resume communicates clearly, and in whether you apply soon after a posting opens instead of the day before it closes. You can research the company and learn enough about its business to explain why you care about it. You can build things, write about what you built, and develop interests that make you worth talking to. You can contact people directly instead of relying entirely on an applicant tracking system, and you can ask family, professors, and friends whether anyone in their networks works in the fields that interest you.&lt;/p&gt;
&lt;p&gt;You can also make it obvious that you have a direction. Compare a student who says, “I need an internship this summer,” with one who says, “I want to work on robotics and control systems. I’ve enjoyed building autonomous rovers in a campus club, I’m interested in how machines make decisions from sensor data, and I’d like to spend the summer somewhere I can see how those systems are built in the real world.” The second student may have no more experience than the first, but they have given the reader a reason to picture them inside the organization.&lt;/p&gt;
&lt;h2&gt;Rejection will still happen&lt;/h2&gt;
&lt;p&gt;You can do every one of those things well and still be turned down, sometimes over and over. You might apply to a hundred internships and hear no from ninety-nine of them, but you never needed a hundred internships. You needed one.&lt;/p&gt;
&lt;p&gt;Those ninety-nine rejections don’t add up to a verdict on your worth. Each was a separate decision, produced by its own mix of timing, circumstance, competition, priorities, presentation, relationships, luck, and ability. Ability matters enormously over a career, but in any single decision it is just one of the variables.&lt;/p&gt;
&lt;p&gt;A long run of rejections can still tell you something, because a few variables appear in every one of those decisions. Your resume, the roles you chose to pursue, and the way you describe your work went into all ninety-nine. When the same result keeps coming back, those shared variables are the first place to look, and they happen to be the ones you can change.&lt;/p&gt;
&lt;p&gt;Internships are only the first place most people meet rejection in volume. Later it arrives as a job that goes to another candidate, an investor who passes on a pitch, a customer who picks a competitor, an editor who declines a manuscript, or a promotion that goes to a colleague. The equation is the same in each case, with many variables you can’t see, a few that travel with you, and a single yes or no at the end. People who build something meaningful usually collect far more rejections along the way than anyone else sees, and what distinguishes them is how they respond. They adjust the variables that belong to them and keep going, long after others have read the same results as a verdict and stopped.&lt;/p&gt;
&lt;p&gt;My father likes to ask why God made men so stupid, and then he answers his own question. It was so they could do the impossible. He means the particular bravado of young men, which is often misplaced but sometimes useful. A young man who doesn’t appreciate how long his odds are will still cross the room, make the call, and send the application. Every so often that persistence pays off precisely because he never stopped to calculate how unlikely success was. As we get older, many of us get better at calculating the odds and worse at ignoring them. We start treating each rejection as a judgment about ourselves, and eventually as a reason to stop trying. Understanding what a rejection actually tells us lets us keep the persistence without depending on the ignorance.&lt;/p&gt;
&lt;p&gt;Rejection will still hurt, because you wanted the thing you didn’t get. The useful response is a narrower question than “What is wrong with me?” Ask which variables in the equation belong to you, work on those, and then try again.&lt;/p&gt;
</content:encoded><category>thoughts</category></item><item><title>The Amnesia Cycle and Why AI Is Turning Developers Back Into Testers</title><link>https://unmitigatedrisk.com/2026/08/the-amnesia-cycle-and-why-ai-is-turning-developers-back-into-testers/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/08/the-amnesia-cycle-and-why-ai-is-turning-developers-back-into-testers/</guid><description>I started working in technology around 1993. One of my first jobs was in quality assurance, partly because there was no security profession to join yet.</description><pubDate>Wed, 19 Aug 2026 17:34:06 GMT</pubDate><content:encoded>&lt;p&gt;I started working in technology around 1993. One of my first jobs was in quality assurance, partly because there was no security profession to join yet.&lt;/p&gt;
&lt;p&gt;There were people doing the work, but few companies were hiring for it. That changed within a decade. Until it did, people with the instincts that would later define security engineering landed in adjacent disciplines. Test was one of them.&lt;/p&gt;
&lt;p&gt;That was true for me. I became a test manager fairly quickly, later worked as a test architect, then went on to software development, security, and a bunch of other things.&lt;/p&gt;
&lt;p&gt;More than thirty years later, I find myself watching something funny happen.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;AI is turning software developers back into testers.&lt;/strong&gt;&lt;/p&gt;
&lt;p&gt;Not the kind of testers we were in 1993. What it means to test software has changed several times since then. But at a more abstract level, the work is surprisingly familiar.&lt;/p&gt;
&lt;p&gt;The person is no longer primarily producing the thing. They are increasingly trying to determine whether the thing that was produced is any good.&lt;/p&gt;
&lt;p&gt;And we have been around this loop before.&lt;/p&gt;
&lt;p&gt;We develop a specialty because a problem is hard. We get good enough at it to encode pieces of the expertise into process, tools, and automation. Eventually the machinery works well enough that the underlying expertise starts to look unnecessary. We distribute the responsibility, automate more of it, and convince ourselves that the problem has largely been solved.&lt;/p&gt;
&lt;p&gt;Then the system grows, the environment changes, or a new technology arrives and exposes all of the judgment that never made it into the machinery.&lt;/p&gt;
&lt;p&gt;The responsibility never left. It just changed costume.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/08/image-1.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/08/image-1-1024x370.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;h2&gt;When testing was a profession&lt;/h2&gt;
&lt;p&gt;In the 1990s, software development and software testing were much more clearly separated. Developers wrote software. Test organizations tried to figure out where it broke.&lt;/p&gt;
&lt;p&gt;A lot of the work was manual. People installed builds, exercised features, constructed strange states, tested boundaries, wrote bug reports, and tried to reproduce failures. By modern standards, much of it would look labor-intensive. Some of it really was scut work.&lt;/p&gt;
&lt;p&gt;But the separation had an important organizational property. The person who built the thing and the person whose job was to find out why it was wrong were different people.&lt;/p&gt;
&lt;p&gt;Their incentives were different too. Developers were trying to make the product work and get it shipped. Testers were rewarded for finding the circumstances under which it did not work.&lt;/p&gt;
&lt;p&gt;Those are complementary responsibilities, but they are not the same responsibility.&lt;/p&gt;
&lt;p&gt;Over time, testing acquired a status problem. It was increasingly treated as work that did not require the same level of engineering skill as implementation. One response was to give more of it to junior developers.&lt;/p&gt;
&lt;p&gt;Then we moved further. Instead of a separate organization owning quality, developers would test their own software.&lt;/p&gt;
&lt;p&gt;Much of that change was good.&lt;/p&gt;
&lt;p&gt;Unit testing was good. Test-driven development was good. Continuous integration was good. Automated regression testing was good. Testing closer to the point where software was written eliminated entire classes of expensive downstream failures.&lt;/p&gt;
&lt;p&gt;The nature of testing changed too. It moved away from a model dominated by manually exercising a finished product and toward one where tests could become part of the way software itself was specified and constructed.&lt;/p&gt;
&lt;p&gt;So the story is not that we eliminated QA and that was simply a mistake.&lt;/p&gt;
&lt;p&gt;The mistake was gradually convincing ourselves that because we could automate more of the mechanics, we needed less of the judgment.&lt;/p&gt;
&lt;h2&gt;A test that passes is not evidence that the system is good&lt;/h2&gt;
&lt;p&gt;As automation improved, we became extraordinarily good at running tests.&lt;/p&gt;
&lt;p&gt;A modern software project can execute tens of thousands of tests on every change. We can measure coverage, reject regressions, test configurations, fuzz interfaces, spin up entire environments, and tear them down again without anybody touching them.&lt;/p&gt;
&lt;p&gt;The machinery works.&lt;/p&gt;
&lt;p&gt;But there is a distinction that became easier to overlook.&lt;/p&gt;
&lt;p&gt;A test can work perfectly and still tell you almost nothing useful about the quality of the system.&lt;/p&gt;
&lt;p&gt;The hard question is not always whether the test passed. It is whether passing that test is evidence of the property you actually care about.&lt;/p&gt;
&lt;p&gt;That gets harder as systems become more complicated. A system can have an enormous green test suite while failing in a way nobody thought to represent in the suite.&lt;/p&gt;
&lt;p&gt;There is an important difference between mechanical verification and judgment about what deserves to be verified. One asks whether the checks we wrote passed. The other asks whether those were the right checks.&lt;/p&gt;
&lt;p&gt;Automation became exceptionally good at answering the first question. It did much less to eliminate the difficulty of the second.&lt;/p&gt;
&lt;p&gt;A test suite is an encoding of somebody&apos;s model of how the system can fail. It captures the failures we anticipated, the properties we chose to represent, and the assumptions we knew enough to challenge.&lt;/p&gt;
&lt;p&gt;It says much less about the failures nobody imagined.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/08/image-3.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/08/image-3-1024x566.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;Automation did not eliminate the test problem. It moved the test problem up a level.&lt;/p&gt;
&lt;p&gt;The scarce skill became figuring out what to test, what failure looks like, which assumptions need to be challenged, and what evidence should actually make us confident in the result.&lt;/p&gt;
&lt;p&gt;That is why what is happening with AI feels so familiar.&lt;/p&gt;
&lt;h2&gt;We thought AI would do the testing&lt;/h2&gt;
&lt;p&gt;One of the obvious expectations around generative AI was that it would automate still more testing.&lt;/p&gt;
&lt;p&gt;If the AI can write the implementation, it can certainly write unit tests too. And it can.&lt;/p&gt;
&lt;p&gt;But that misses the more important change.&lt;/p&gt;
&lt;p&gt;AI is making implementation cheap.&lt;/p&gt;
&lt;p&gt;A developer can already cause far more code to be produced than they could reasonably have written themselves. As agents improve, that multiplier gets larger. It is not difficult to imagine one engineer directing dozens, hundreds, or eventually thousands of concurrent software-producing processes.&lt;/p&gt;
&lt;p&gt;At that point, traditional code review is not merely inefficient. It becomes physically impossible.&lt;/p&gt;
&lt;p&gt;Nobody is going to carefully read every line produced by a thousand coding agents.&lt;/p&gt;
&lt;p&gt;The generated output is also not quite like the output of an old deterministic compiler or code generator. These systems are probabilistic. Run them again and you may get a different implementation, a different decomposition, or a different mistake.&lt;/p&gt;
&lt;p&gt;That makes the old assumption that we can inspect the artifact into correctness even less plausible.&lt;/p&gt;
&lt;p&gt;So the human moves up a level.&lt;/p&gt;
&lt;p&gt;Instead of spending most of the time constructing the implementation, we increasingly construct the conditions under which an implementation will be accepted. We write tests, evals, invariants, acceptance criteria, adversarial cases, and constraints. We decide what evidence is sufficient to tell us that the machine-produced result is actually good.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Software developers are becoming testers again.&lt;/strong&gt;&lt;/p&gt;
&lt;p&gt;It is not 1993-style manual QA. It is closer to specification, TDD, evaluation design, systems validation, and the construction of executable evidence.&lt;/p&gt;
&lt;p&gt;But abstractly, it is the same work happening in a different way.&lt;/p&gt;
&lt;p&gt;The form changes. The responsibility does not.&lt;/p&gt;
&lt;h2&gt;What the new testing actually looks like&lt;/h2&gt;
&lt;p&gt;The easy question is whether generated code passes the existing test suite.&lt;/p&gt;
&lt;p&gt;The harder question is whether the suite represents the properties we actually care about.&lt;/p&gt;
&lt;p&gt;Does the generated component behave correctly under inputs we did not anticipate? What happens when independently generated components interact and two locally correct decisions compose into a globally bad result? What happens after the system has been operating for days, accumulating state and acting on the consequences of its own earlier decisions?&lt;/p&gt;
&lt;p&gt;What happens when the environment differs from the conditions represented in our evals? And what happens when an adversary deliberately searches for the assumptions we failed to encode?&lt;/p&gt;
&lt;p&gt;Those questions are not answered by producing more tests mechanically.&lt;/p&gt;
&lt;p&gt;They require somebody to form a theory of failure.&lt;/p&gt;
&lt;p&gt;The scarce skill is increasingly understanding the mechanics of failure. That means knowing where the system boundaries are, which properties must remain true across those boundaries, what assumptions are hidden inside the architecture, and how reasonable local behavior can produce unreasonable global outcomes.&lt;/p&gt;
&lt;p&gt;It also changes what a useful test looks like.&lt;/p&gt;
&lt;p&gt;When implementations are relatively stable, testing specific examples can tell you a lot. When an AI can regenerate the implementation tomorrow, durable properties become more important. The question shifts from whether this implementation produces the expected result for this input toward which properties must remain true across whatever implementations the system produces.&lt;/p&gt;
&lt;p&gt;Those properties might concern correctness, authority, state transitions, isolation, safety, or the relationship between components. The implementation can change while the invariant remains.&lt;/p&gt;
&lt;p&gt;That is a different kind of leverage.&lt;/p&gt;
&lt;p&gt;Verification also stops neatly ending at release. Some failures only emerge through interaction with real environments, long-running state, changing inputs, or behavior that was not represented during development. That pushes part of the evidence gathering into operation through telemetry, observability, runtime checks, and the behavior of the deployed system itself.&lt;/p&gt;
&lt;p&gt;The new tester is therefore not just checking whether an implementation conforms to a specification somebody else already wrote.&lt;/p&gt;
&lt;p&gt;Increasingly, they are responsible for deciding what the specification must say, which properties must survive implementation changes, which failures matter enough to detect, and what evidence is sufficient for the resulting system to deserve trust.&lt;/p&gt;
&lt;p&gt;That is a substantially higher-order form of the same old responsibility.&lt;/p&gt;
&lt;h2&gt;High-quality scut work&lt;/h2&gt;
&lt;p&gt;There is a funny status inversion hiding in this.&lt;/p&gt;
&lt;p&gt;Test used to be treated as scut work. Then we gave more of it to junior developers. Then we told every developer they were responsible for doing it themselves. Then we automated as much of it as we could.&lt;/p&gt;
&lt;p&gt;Now we are automating the part we used to think was the prestige work, writing the software, and leaving the developer sitting above the machinery trying to determine whether any of what it produced is good.&lt;/p&gt;
&lt;p&gt;We may have turned one of the industry&apos;s prestige jobs into &lt;strong&gt;very high-quality scut work&lt;/strong&gt;.&lt;/p&gt;
&lt;p&gt;The funny part is that the scut work may now be where much of the value lives.&lt;/p&gt;
&lt;p&gt;When implementation is expensive, the person who knows how to implement something is scarce. When implementation becomes cheap, the scarce person is the one who knows what should be built, what properties it needs to have, how it is likely to fail, what assumptions are hidden inside it, and what evidence would convince us that it works.&lt;/p&gt;
&lt;p&gt;Generation gets cheaper. Judgment does not.&lt;/p&gt;
&lt;h2&gt;Security already did this&lt;/h2&gt;
&lt;p&gt;I have seen almost the same cycle happen with security.&lt;/p&gt;
&lt;p&gt;In retrospect, it is probably not an accident that so many early security people came through test. Both disciplines train you to look at a system somebody else believes works and ask what they have failed to consider.&lt;/p&gt;
&lt;p&gt;Testing asks how the behavior can violate what was intended. Security asks how trust, authority, or assumptions can be violated even when the system appears to be functioning normally.&lt;/p&gt;
&lt;p&gt;Both reward a certain kind of skepticism.&lt;/p&gt;
&lt;p&gt;When I started, security engineering barely existed as a normal software profession. By the late 1990s it was becoming one. By the early 2000s, it was clearly a distinct industry with dedicated teams and career paths.&lt;/p&gt;
&lt;p&gt;That specialization happened because security was hard and ordinary development organizations were not consistently good at it.&lt;/p&gt;
&lt;p&gt;Then we started saying something that was also fundamentally correct. Security should not be something another group bolts onto the product afterward. Developers should build secure systems themselves.&lt;/p&gt;
&lt;p&gt;&quot;Security is everyone&apos;s responsibility.&quot;&lt;/p&gt;
&lt;p&gt;There is nothing wrong with that principle.&lt;/p&gt;
&lt;p&gt;The problem is what happens when we confuse responsibility with expertise.&lt;/p&gt;
&lt;p&gt;A product developer is trying to ship a product. They have schedules, features, performance requirements, compatibility issues, reliability problems, customer demands, and dozens of other things competing for attention.&lt;/p&gt;
&lt;p&gt;Security becomes one of many things they are supposed to get right.&lt;/p&gt;
&lt;p&gt;When that proves insufficient, organizations build machinery around the problem. We add secure development lifecycle processes, scanners, policy gates, paved-road platforms, and controls designed to make the safe thing easier than the unsafe thing.&lt;/p&gt;
&lt;p&gt;All of those things can help.&lt;/p&gt;
&lt;p&gt;But notice what we are doing.&lt;/p&gt;
&lt;p&gt;After deciding the specialist function should be distributed into the rest of engineering, we are encoding pieces of that specialist judgment back into systems and processes.&lt;/p&gt;
&lt;p&gt;A scanner encodes somebody&apos;s knowledge of what a vulnerability looks like. A secure-by-default platform encodes somebody&apos;s judgment about which choices should be permitted. A policy gate encodes somebody&apos;s model of what conditions need to hold before software should be released.&lt;/p&gt;
&lt;p&gt;The specialist may become less visible as that expertise gets embedded into the platform, but the expertise did not cease to exist. It became infrastructure.&lt;/p&gt;
&lt;p&gt;Eventually there is enough machinery that it again becomes tempting to ask whether we really need the specialists.&lt;/p&gt;
&lt;p&gt;Then the abstraction leaks.&lt;/p&gt;
&lt;p&gt;A threat appears outside the model encoded in the scanner. A platform assumption no longer holds. A new system does something the existing governance framework was never designed to reason about.&lt;/p&gt;
&lt;p&gt;Then we discover that we automated the known answers, not the ability to recognize new questions.&lt;/p&gt;
&lt;h2&gt;AI security and the latest rediscovery&lt;/h2&gt;
&lt;p&gt;AI makes this pattern almost comical because we are currently rediscovering old classes of security problems with new names.&lt;/p&gt;
&lt;p&gt;Prompt injection is obviously not literally SQL injection. The implementation is different, the interpreter is different, and the failure modes are different.&lt;/p&gt;
&lt;p&gt;But someone who spent the 1990s and 2000s dealing with SQL injection, command injection, script injection, confused deputies, trust boundaries, privilege separation, and the consequences of letting untrusted input become control should find the family resemblance hard to miss.&lt;/p&gt;
&lt;p&gt;We have spent decades learning that you should be very careful when information from an untrusted party can influence what a privileged system interprets as instructions.&lt;/p&gt;
&lt;p&gt;Now we have built enormously capable interpreters whose primary interface is natural language. We mix instructions and data in the same context, connect them to tools, and act surprised when hostile input changes what they do.&lt;/p&gt;
&lt;p&gt;The technology is new. The institutional failure mode is not.&lt;/p&gt;
&lt;p&gt;The same thing is happening in conversations about containment and sandboxing. We are once again discovering that powerful systems need boundaries, that those boundaries need to be enforced rather than merely described, and that capabilities should be constrained by something stronger than an instruction asking the system to behave.&lt;/p&gt;
&lt;p&gt;None of that makes AI security trivial. The new systems create genuinely new problems. But novelty at one layer does not erase the accumulated lessons at another.&lt;/p&gt;
&lt;p&gt;We knew versions of these things thirty years ago. What keeps recurring is not the exact vulnerability. It is the belief that a new abstraction has somehow relieved us of the old responsibility.&lt;/p&gt;
&lt;p&gt;That is where the amnesia comes in.&lt;/p&gt;
&lt;h2&gt;The amnesia cycle&lt;/h2&gt;
&lt;p&gt;You could describe the pattern as &lt;strong&gt;specialization, codification, automation, perceived redundancy, loss of judgment, scaling failure, and rediscovery&lt;/strong&gt;.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/08/image.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/08/image-1024x467.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;That is the amnesia.&lt;/p&gt;
&lt;p&gt;We rarely forget the artifacts of the previous generation. We keep the test frameworks, scanners, development processes, controls, and automation.&lt;/p&gt;
&lt;p&gt;What we forget is &lt;strong&gt;why the people who created those things thought the problem was hard in the first place.&lt;/strong&gt;&lt;/p&gt;
&lt;p&gt;Eventually we confuse the existence of the machinery with possession of the expertise that created it.&lt;/p&gt;
&lt;p&gt;A passing test suite becomes evidence of quality. A security scanner becomes evidence of security. An AI eval becomes evidence that the AI is doing the right thing.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/08/image-2.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/08/image-2-1024x472.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;Until the system moves outside the assumptions those mechanisms encode.&lt;/p&gt;
&lt;p&gt;Then the old problem appears again, wearing different clothes.&lt;/p&gt;
&lt;h2&gt;The responsibility never leaves&lt;/h2&gt;
&lt;p&gt;That is the through line I see between testing, security, and what is now happening with AI-assisted development.&lt;/p&gt;
&lt;p&gt;We are very good at abstracting away mechanics. That is what engineering does.&lt;/p&gt;
&lt;p&gt;But when we successfully automate the mechanics, it is easy to convince ourselves that we automated the underlying responsibility too.&lt;/p&gt;
&lt;p&gt;We did not.&lt;/p&gt;
&lt;p&gt;Testing did not disappear when the dedicated QA organization disappeared. Security did not disappear when we made it everyone&apos;s responsibility. Verification will not disappear because an AI can generate both an implementation and a test suite that says the implementation is fine.&lt;/p&gt;
&lt;p&gt;Somebody still has to decide what &quot;fine&quot; means. Somebody has to recognize the assumptions the automation does not know it is making. Somebody has to decide which failures matter. Somebody has to determine what evidence would falsify the claim that the system is working.&lt;/p&gt;
&lt;p&gt;Somebody has to distinguish a system that successfully passes its tests from one that deserves to be trusted.&lt;/p&gt;
&lt;p&gt;The responsibility never leaves. It changes costume.&lt;/p&gt;
&lt;p&gt;I started my career in a world where developers wrote the software and people like me tested it. We spent the next thirty years treating test first as work developers should not have to do, then as work developers should do themselves, and finally as work machines should increasingly do for them.&lt;/p&gt;
&lt;p&gt;Now the machines are starting to write the software.&lt;/p&gt;
&lt;p&gt;And the developers are increasingly responsible for figuring out whether any of it is good.&lt;/p&gt;
&lt;p&gt;Apparently the tester won.&lt;/p&gt;
</content:encoded><category>ai</category><category>thoughts</category></item><item><title>Hurst University</title><link>https://unmitigatedrisk.com/2026/08/hurst-university/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/08/hurst-university/</guid><description>For as long as my children can remember, I have told them that they are students at Hurst University.</description><pubDate>Mon, 17 Aug 2026 17:33:41 GMT</pubDate><content:encoded>&lt;p&gt;For as long as my children can remember, I have told them that they are students at Hurst University.&lt;/p&gt;
&lt;p&gt;It has no campus, no accreditation, and no admissions process. Joining the family is enough to get you enrolled. Graduation is another matter.&lt;/p&gt;
&lt;p&gt;There is only one requirement. By the time you leave the house, you should be capable of building a future for yourself.&lt;/p&gt;
&lt;p&gt;I don&apos;t mean that you should know what you are going to do for the rest of your life. That is one of the stranger questions we ask young people. Most adults I know have changed direction enough times that pretending an eighteen-year-old is making a permanent occupational choice is unserious.&lt;/p&gt;
&lt;p&gt;What I mean is more fundamental. You should know how to learn, and you should know how to work. When you encounter something you don&apos;t understand, you should have some idea how to get from ignorance to competence. You should know how to take a hit without deciding the hit defines you, how to recognize when your assumptions were wrong, and how to change direction without treating everything behind you as wasted.&lt;/p&gt;
&lt;p&gt;Most importantly, you should increasingly understand that the responsibility for what happens next belongs to you.&lt;/p&gt;
&lt;p&gt;That is Hurst University.&lt;/p&gt;
&lt;p&gt;There is nothing new about the idea. If anything, it is an old model of education with a family name attached to it.&lt;/p&gt;
&lt;p&gt;For most of human history, becoming educated and becoming useful were close to the same thing. Children watched adults do real work. Then they helped. Then they were trusted with some small part of it. They made mistakes where mistakes were survivable, were corrected by somebody who knew more than they did, and tried again. As competence increased, the work got harder and supervision got lighter. Eventually the person who had been taught became somebody who could be trusted to act without waiting to be told what to do next.&lt;/p&gt;
&lt;p&gt;That transfer is the part I care about most. The student eventually has to become responsible for the education.&lt;/p&gt;
&lt;p&gt;I learned that the hard way, and then I had to watch one of my children learn it too.&lt;/p&gt;
&lt;p&gt;He was not slow. He was seeking out serious material for pleasure at an age when adults found it surprising. But the way he took in information did not match the way the school delivered it, and the instruments the school trusted returned the wrong answer about him. The system then acted on the wrong answer. He began to notice he was being handled as a different kind of student, and he could not work out why.&lt;/p&gt;
&lt;p&gt;The part I remember is not the meetings. It is that he started to wonder whether the school knew something about him that he didn&apos;t.&lt;/p&gt;
&lt;p&gt;I eventually moved him somewhere more willing to respond to an individual child, which helped. The more important intervention was a conversation.&lt;/p&gt;
&lt;p&gt;I told him what I believed to be true. No institution was ever going to be able to take full responsibility for his education. Some things were going to be harder for him than for other people, and that was not going to change.&lt;/p&gt;
&lt;p&gt;Then I told him that his challenges were his superpower.&lt;/p&gt;
&lt;p&gt;I meant it literally, and I explained why. Most people are never forced to learn how they learn. They get through on the method they were handed, and they only discover its limits much later, if ever. He was going to have to build his own method starting now, at nine, because the handed one did not work for him. That is a brutal assignment and it is also an enormous head start. The world keeps rewarding people who can acquire what they need without being given it, and he was going to be practicing that while everyone else was still being taught.&lt;/p&gt;
&lt;p&gt;Then I told him he was a student at Hurst University, and that when he graduated from this house he was going to be fine.&lt;/p&gt;
&lt;p&gt;He is grown now. In his twenties he built a business and sold it to one of the largest financial services companies in the world, which is a thing you cannot do without becoming a fast and relentless student of whatever is in front of you. Entrepreneurs are not people who already know how. They are people who find out in time.&lt;/p&gt;
&lt;p&gt;He is one of the sharpest people I know and one of the most prepared, and the second of those is the one he built. He worked out early that being the smartest person in the room and being ready for the room are different things, and that only one of them was under his control. He stopped waiting to find out which he would get. That habit came out of the friction, and I am not sure anything else would have produced it.&lt;/p&gt;
&lt;p&gt;I was a student at Hurst University long before I had a name for it.&lt;/p&gt;
&lt;p&gt;I was dyslexic and dysgraphic and did not present well to the educational system. At one point my parents were told they should prepare themselves for the possibility that I would never be capable of supporting myself.&lt;/p&gt;
&lt;p&gt;That prediction did not age well.&lt;/p&gt;
&lt;p&gt;I went to college young and moved out at sixteen. Some of that was rebellion, but mostly I wanted independence in the literal sense. I wanted control over my own life, including the economic responsibility that came with it.&lt;/p&gt;
&lt;p&gt;A lot of my education after that happened without anybody designing it. Computers gave me problems I cared enough about to solve. Programming led into systems. Systems led into networking. Networking led into security. Security eventually required understanding companies, incentives, law, economics, organizations, and people. I kept encountering things I did not know and learning enough to get through the next door.&lt;/p&gt;
&lt;p&gt;One capability created a reason to acquire another.&lt;/p&gt;
&lt;p&gt;None of it started with me.&lt;/p&gt;
&lt;p&gt;My father grew up on a subsistence farm, where you fix what breaks with what is in the barn because the alternative is doing without. He taught himself rocket chemistry as a kid off that same principle and was working on satellite hardware by his early twenties. I have &lt;a href=&quot;https://unmitigatedrisk.com/2026/03/we-built-it-with-slide-rules-then-we-forgot-how/&quot;&gt;written about him before&lt;/a&gt;, so I will not tell it twice.&lt;/p&gt;
&lt;p&gt;What matters here is that he never called any of it an education. It was just what you did when you needed to know something.&lt;/p&gt;
&lt;p&gt;So I did not invent this. I inherited it, gave it a name, and made the handoff deliberate. That last part is the part that matters, because none of it moves on its own. It has to be handed over on purpose, by somebody who decides to bother.&lt;/p&gt;
&lt;p&gt;Years ago, when I &lt;a href=&quot;https://unmitigatedrisk.com/2015/06/help-wanted-apprentice-to-learn-trade/&quot;&gt;wrote about apprenticeship&lt;/a&gt;, I described four things that had mattered enormously in my own development: access, direction, challenges, and support. I still think that framework is right, but I now see something underneath it. Those are not merely the ingredients of a good apprenticeship. They are the ingredients of an environment that gradually teaches someone to direct themselves.&lt;/p&gt;
&lt;p&gt;Give somebody access to things worth learning. Put people around them who know more than they do. Give them problems slightly beyond their current ability. Support them enough that failure remains recoverable. Then, slowly, stop telling them what to do next.&lt;/p&gt;
&lt;p&gt;That last part is the actual transfer.&lt;/p&gt;
&lt;p&gt;Having three children made this clearer, because the same philosophy looks completely different depending on the student.&lt;/p&gt;
&lt;p&gt;My second child has always worked. At four he was doing long division and by 6 or 7 he could recite the major bone and muscle groups. As a teenager he became a nationally ranked fencer, which is not something that happens to a person for being quick. It happens through years of drilling the same movement badly until it is good, losing in front of people, and going back the next day.&lt;/p&gt;
&lt;p&gt;So the story I used to tell myself about him, that things came easily and he had therefore never built the habit, does not survive the evidence. He built it early. He built it in a domain nobody assigned him.&lt;/p&gt;
&lt;p&gt;What was true is that school rarely asked him for it. He was admitted to several of the best aerospace programs in the world and ultimately chose computer engineering, and he is now somewhere the standard is set by people who are also very good and where thinking fast is the baseline rather than the edge.&lt;/p&gt;
&lt;p&gt;So what I am watching is not a young man learning to work. It is someone moving a work ethic he already owns out of the place he first built it and into the place he intends to live. That transfer is the entire point of this essay, and he is doing it in front of me.&lt;/p&gt;
&lt;p&gt;My third is different again. Nearly all of her identity is currently organized around a single competitive sport, roughly twenty-six hours a week of it. That is not a complaint. Twenty-six hours a week of anything difficult teaches repetition, correction, pain tolerance, delayed gratification, and performing while people watch. The work ethic already exists.&lt;/p&gt;
&lt;p&gt;The problem is that she believes the work ethic belongs to the sport. Her brother has already shown that it doesn&apos;t, which is the most useful thing an older sibling can do.&lt;/p&gt;
&lt;p&gt;Activities end. The machinery that produced the excellence should travel.&lt;/p&gt;
&lt;p&gt;Aptitude changes the educational problem. It does not remove the educational problem.&lt;/p&gt;
&lt;p&gt;A child who struggles may need to learn that difficulty is not the same as inability. A child who rarely struggles may need enough friction to discover the value of preparation. A child who becomes excellent in one domain may need to discover that excellence is partly a process that can be carried elsewhere.&lt;/p&gt;
&lt;p&gt;The curriculum changes because the student changes. The goal does not.&lt;/p&gt;
&lt;p&gt;The goal is agency. By agency I mean the ability to encounter something unfamiliar and say, with some credibility, &quot;I don&apos;t know how to do this yet, but I know how to begin.&quot;&lt;/p&gt;
&lt;p&gt;That may be the most durable thing an education can produce.&lt;/p&gt;
&lt;p&gt;My father was not the only one. My mother was doing the same thing in a different register, and I was even slower to see it.&lt;/p&gt;
&lt;p&gt;She started as a hair stylist. Later she became a tool-and-die worker at Boeing. Then she moved into knowledge work and eventually retired as a business analyst.&lt;/p&gt;
&lt;p&gt;Described by job title, those look like unrelated careers, the sort of résumé that gets read as drift. Described by behavior, they are the same story repeated several times. She kept becoming qualified to do things she had not previously known how to do.&lt;/p&gt;
&lt;p&gt;Nothing about cutting hair prepares you to hold tolerances on a machined part. Nothing about machining prepares you to take apart how a business actually works and put it back together as a requirement. What carried across was not the content. It was the practice of arriving somewhere without the necessary knowledge and acquiring it in public, in front of people who already had it, while the work still had to get done.&lt;/p&gt;
&lt;p&gt;She did that at least three times, each time later in life than the last, each time with more to lose. Watching it happen taught me more than any explanation of it would have.&lt;/p&gt;
&lt;p&gt;I think we put far too much weight on occupational identity. We ask people what they &quot;are&quot; when what we mean is what they are being paid to do right now. Those are not the same thing.&lt;/p&gt;
&lt;p&gt;A mechanic who becomes an engineer does not arrive empty-handed. A construction worker who moves into software already understands sequencing, dependencies, tolerances, physical constraints, customers, mistakes, and what happens when plans encounter reality. A salesperson who becomes a product leader knows things about incentives and people that do not appear in a product-management textbook.&lt;/p&gt;
&lt;p&gt;Learning one serious domain teaches you more than the facts of that domain. It teaches you something about systems, and, if you are paying attention, something about how you yourself become competent.&lt;/p&gt;
&lt;p&gt;That is why the question &quot;What are you going to do with your life?&quot; is not useful. Ask instead what you are going to do next.&lt;/p&gt;
&lt;p&gt;You are not choosing forever. You are choosing next.&lt;/p&gt;
&lt;p&gt;That does not make the decision unimportant. It changes what makes the decision good. A good next step should leave you with more than you had before. More competence, more judgment, more context, more relationships, more credibility, more capital, or simply more options.&lt;/p&gt;
&lt;p&gt;Then you choose again.&lt;/p&gt;
&lt;p&gt;This is also why I have never been comfortable with &quot;follow your dreams&quot; as career advice. Dreams are useful. They give us energy and they make us try things. But desire and strategy are not the same thing.&lt;/p&gt;
&lt;p&gt;People have aptitudes whether we like that fact or not. The world has needs whether we like that fact or not. Some capabilities are scarce, some are common, and some interests map more naturally than others onto work that can support a life. If you expect something to support your life, understanding how it creates value is part of taking responsibility for the decision.&lt;/p&gt;
&lt;p&gt;Years ago I was riding the gondola between the peaks at Whistler with three young women. One of them had recently graduated and was telling the others about an argument she had had with her boss. She had a degree now, and she thought she should be paid more. Her boss told her he could not pay her more simply because she had acquired the degree.&lt;/p&gt;
&lt;p&gt;She was furious. Why had she bothered getting it?&lt;/p&gt;
&lt;p&gt;Then, somewhere in the conversation, she mentioned that she worked at a sandwich shop.&lt;/p&gt;
&lt;p&gt;I never learned what the degree was in. That is probably why the story stuck with me. The degree may have been enormously valuable, and may have opened an entirely different career a month later. But the credential itself had not changed the economic value of the work she was performing that afternoon.&lt;/p&gt;
&lt;p&gt;The point is the distinction between learning something, possessing evidence that you learned something, and becoming capable of doing something the world values. Those things overlap, but they are not identical.&lt;/p&gt;
&lt;p&gt;Eventually reality gets a vote.&lt;/p&gt;
&lt;p&gt;That phrase matters to me because it applies well beyond credentials. You can believe you understand a system until you have to build one. You can believe you understand customers until you have to sell something to them. You can believe you understand leadership until somebody else&apos;s livelihood depends on your judgment. You can believe you understand risk until the decision is yours and the consequences arrive with it.&lt;/p&gt;
&lt;p&gt;Capability develops when knowledge begins colliding with consequence.&lt;/p&gt;
&lt;p&gt;That is why work, projects, apprenticeship, competition, and responsibility matter so much. They are not simply places to apply learning. They are part of how learning becomes judgment.&lt;/p&gt;
&lt;p&gt;And judgment is difficult to acquire without being wrong.&lt;/p&gt;
&lt;p&gt;My father used to ask, &quot;Do you know why God made young men so stupid?&quot;&lt;/p&gt;
&lt;p&gt;&quot;So they could do the impossible.&quot;&lt;/p&gt;
&lt;p&gt;He usually said it about the early space program, and that was not a coincidence. The young men in the joke were him and the people he worked with. He was not describing a category of person. He was describing a room he had been in.&lt;/p&gt;
&lt;p&gt;There is a limit to the principle. Ignorance can get you killed. But experience accumulates reasons a thing will not work, and there is a danger in becoming so sophisticated about risk that the sophistication becomes a reason never to take one.&lt;/p&gt;
&lt;p&gt;If you are going to attempt difficult things, some of them will not work. What matters is what happens next.&lt;/p&gt;
&lt;p&gt;Failure itself is not automatically useful. Failing repeatedly without changing anything is repetition. The useful part is the loop afterward. What happened, what assumption was wrong, what did I misunderstand, what was inside my control, and what should change next time?&lt;/p&gt;
&lt;p&gt;The attempt failed. That is information.&lt;/p&gt;
&lt;p&gt;&quot;I am a failure&quot; is something else.&lt;/p&gt;
&lt;p&gt;Rejection works much the same way. Many worthwhile things require volunteering for outcomes somebody else partly controls. Apply for the job. Ask for the opportunity. Pitch the customer. Publish the idea. Start the company. Compete.&lt;/p&gt;
&lt;p&gt;Somebody gets to say no.&lt;/p&gt;
&lt;p&gt;If no is psychologically intolerable, you eventually begin designing your life so nobody ever gets the opportunity to say it. That feels safer, but it also shrinks the range of possible futures.&lt;/p&gt;
&lt;p&gt;This is why resilience is less something you explain to a child than something you progressively load. An athlete does not begin with the maximum weight. A gymnast does not begin with the hardest skill. You give somebody difficulty at a scale they can survive, let reality push back, help them understand what happened, and then load a little more.&lt;/p&gt;
&lt;p&gt;Over time they accumulate evidence about themselves. Discomfort ends. Embarrassment is survivable. Criticism can contain useful information. Preparation changes outcomes. Being wrong does not destroy you. Failure can be followed by another attempt.&lt;/p&gt;
&lt;p&gt;This is what I mean when I tell my children that the hardest thing in life is managing your own psychology. Intelligence does not save you from fear. Talent does not save you from insecurity. Being right does not save you from ego. Knowing what you ought to do does not guarantee that you will do it.&lt;/p&gt;
&lt;p&gt;A surprising amount of adulthood is remaining capable of acting while your own psychology is trying to convince you not to.&lt;/p&gt;
&lt;p&gt;Which brings me to the message I worry about most, because it arrives sounding like sophistication.&lt;/p&gt;
&lt;p&gt;Somewhere between the start of high school and the end of it, one of my children began telling me a story about his own future. Previous generations had taken the housing. Previous generations had taken the wages. The arithmetic of an ordinary adult life no longer worked, and there was not much point pretending otherwise.&lt;/p&gt;
&lt;p&gt;I pushed back, and I want to be careful about what I was pushing back on. I was not arguing that housing is affordable or that the numbers are fine. Constraints are real, and a young person who cannot see them is not being educated, he is being flattered.&lt;/p&gt;
&lt;p&gt;What I objected to was the shape of the conclusion. A structural fact had quietly become a personal verdict. He was not describing a difficult environment he would have to navigate. He was describing an outcome that had already been decided, which meant navigation was beside the point.&lt;/p&gt;
&lt;p&gt;That is the mirror image of &quot;follow your dreams,&quot; and it fails for the same reason. One says the world will accommodate you. The other says the world will not permit you. Both remove the part where what you actually do makes a difference.&lt;/p&gt;
&lt;p&gt;Narratives shape agency. Give young people tools, not verdicts.&lt;/p&gt;
&lt;p&gt;The same idea applies to the people and environments we choose.&lt;/p&gt;
&lt;p&gt;I have told my children for years that you cannot aspire to what you have not seen or experienced. We like to think our imagination is independent. It isn&apos;t.&lt;/p&gt;
&lt;p&gt;If you have never met anyone who built a company, building a company feels like something done by a different category of human being. Then you spend time around someone who has done it and the thing moves from abstract possibility into the set of things ordinary humans apparently do.&lt;/p&gt;
&lt;p&gt;Spend time around engineers and engineering becomes concrete. Spend time around excellent tradespeople and craftsmanship becomes visible. See someone change careers later in life and reinvention becomes less frightening. Watch someone take a serious risk, fail, recover, and try again, and failure becomes less terminal.&lt;/p&gt;
&lt;p&gt;This is part of what apprenticeship does extraordinarily well. The apprentice is not merely receiving instruction. The apprentice is watching what competent people consider normal.&lt;/p&gt;
&lt;p&gt;And normal is contagious. So are standards. So are ambitions. So are fears.&lt;/p&gt;
&lt;p&gt;Whether people like the implication or not, we become, in meaningful ways, like the people with whom we spend our time. Which is why I have come to think of the whole environment as three inputs worth choosing deliberately. People shape your standards. Problems shape your capabilities. Feedback shapes your calibration.&lt;/p&gt;
&lt;p&gt;Those are decisions, and like any decision they are worth revisiting. I am not disciplined about this and I have stayed in lanes longer than I should have. But without some mechanism for reconsideration, inertia starts impersonating intention.&lt;/p&gt;
&lt;p&gt;You do not need to predict your life. You do need to keep steering it.&lt;/p&gt;
&lt;p&gt;All of this was already true before AI. AI makes one part of it harder to ignore.&lt;/p&gt;
&lt;p&gt;Instruction is getting cheap and abundant. The judgment that used to accumulate as a byproduct of doing unimportant work is not. I have written about both of those elsewhere, &lt;a href=&quot;https://unmitigatedrisk.com/2025/11/the-vanishing-on-ramp/&quot;&gt;the vanishing on-ramp&lt;/a&gt; and &lt;a href=&quot;https://unmitigatedrisk.com/2025/10/llms-are-the-new-printing-press-why-im-optimistic-about-my-kids-future/&quot;&gt;what turns scarce once reasoning is cheap&lt;/a&gt;, and will not argue them again here.&lt;/p&gt;
&lt;p&gt;The piece that belongs in this essay is smaller and harder. Every one of those questions is a decision about what to do next, and there is no longer anyone obvious to hand it to. A model will tell you what is true. It will not decide what you are willing to own.&lt;/p&gt;
&lt;p&gt;That does not require a new educational philosophy. It makes an old one newly relevant.&lt;/p&gt;
&lt;p&gt;You need access. You need direction. You need problems that matter. You need people who know more than you do. You need enough consequence for reality to get a vote. And eventually you need responsibility for deciding what happens next.&lt;/p&gt;
&lt;p&gt;Which brings me back to the thing Hurst University was actually built around.&lt;/p&gt;
&lt;p&gt;Family.&lt;/p&gt;
&lt;p&gt;When children are young, the family carries almost everything. Food, shelter, transportation, money, protection, opportunity, judgment, and most of the consequences of decisions all sit primarily with the parents.&lt;/p&gt;
&lt;p&gt;Childhood is, in part, the gradual transfer of that weight. Not all at once. That would be abandonment. A little at a time, while mistakes are still cheap and there is somebody nearby who can help make sense of them.&lt;/p&gt;
&lt;p&gt;At first we choose for them. Then we let them choose between things we have selected. Then they make decisions we would not have made. Then they live with some of the consequences. We advise more and decide less.&lt;/p&gt;
&lt;p&gt;If the process works, responsibility moves almost imperceptibly from one side of the relationship to the other.&lt;/p&gt;
&lt;p&gt;Eventually they leave the house. They do not leave the family.&lt;/p&gt;
&lt;p&gt;That distinction is more important than I understood when I first started making the Hurst University joke. The goal was never independence in the sense of needing nobody. Families do not work that way, and neither does the rest of life. The goal was to change your position inside the family.&lt;/p&gt;
&lt;p&gt;When you are small, the family carries you. For a long time that is its job. Then you begin carrying more of yourself. Your decisions become yours. Your mistakes become yours. Your work becomes yours. Your education becomes yours. Eventually the roof over your head becomes yours too.&lt;/p&gt;
&lt;p&gt;And somewhere along the way, if things have gone well, another transition begins. You become capable of carrying some weight for the people who once carried all of yours.&lt;/p&gt;
&lt;p&gt;That is much closer to what I mean by graduation.&lt;/p&gt;
&lt;p&gt;Not that you know what you are going to do for the next forty years. Not that you have accumulated the correct credentials. Not that you have stopped needing your parents, your siblings, or anyone else.&lt;/p&gt;
&lt;p&gt;You leave the house able to participate in the family as an adult. You can build enough of a life to carry yourself, and enough capability that when the people you love need something from you, you have something to give.&lt;/p&gt;
&lt;p&gt;The graduate of Hurst University is not the person who has all the answers. It is the person who has become difficult to make helpless.&lt;/p&gt;
&lt;p&gt;Thirty years ago I did not have all of this worked out. I had a joke about Hurst University and a conviction that my children needed to leave the house able to make a future for themselves.&lt;/p&gt;
&lt;p&gt;I understand the joke a little better now.&lt;/p&gt;
&lt;p&gt;The future was never the thing I could give them. The best I could do was help them become people capable of building one.&lt;/p&gt;
</content:encoded><category>ai</category><category>parenting</category><category>thoughts</category></item><item><title>From Periodic Audit to Continuous Assurance</title><link>https://unmitigatedrisk.com/2026/08/from-periodic-audit-to-continuous-assurance/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/08/from-periodic-audit-to-continuous-assurance/</guid><description>I have been writing about the limitations of audits and compliance systems for several years.</description><pubDate>Thu, 06 Aug 2026 23:13:04 GMT</pubDate><content:encoded>&lt;p&gt;I have been writing about the limitations of audits and compliance systems for several years.&lt;/p&gt;
&lt;p&gt;In &lt;a href=&quot;https://unmitigatedrisk.com/2021/03/accountability-and-transparency-in-modern-systems/&quot;&gt;Accountability and Transparency in Modern Systems&lt;/a&gt;, I wrote about systems producing evidence continuously rather than assembling it periodically for an auditor.&lt;/p&gt;
&lt;p&gt;In &lt;a href=&quot;https://unmitigatedrisk.com/2022/08/what-would-it-look-like-to-go-back-to-first-principles-when-it-comes-to-root-store-management-in-2022/&quot;&gt;First Principles for Root Store Management&lt;/a&gt;, I looked back at the decision to require WebTrust for publicly trusted CAs and argued that, if we were designing the system today, much more of the trust decision should be based on continuously verifiable behavior.&lt;/p&gt;
&lt;p&gt;That led to &lt;a href=&quot;https://unmitigatedrisk.com/2023/02/the-limitations-of-audits-what-you-need-to-know/&quot;&gt;The Limitations of Audits&lt;/a&gt;, &lt;a href=&quot;https://unmitigatedrisk.com/2025/05/rethinking-compliance-ai-skill-liquidity-and-the-quest-for-verifiable-truth/&quot;&gt;Rethinking Compliance&lt;/a&gt;, and &lt;a href=&quot;https://unmitigatedrisk.com/2025/10/compliance-at-the-speed-of-code/&quot;&gt;Compliance at the Speed of Code&lt;/a&gt;.&lt;/p&gt;
&lt;p&gt;The common thread was that the systems we are trying to assure change much faster than the mechanisms we use to understand them.&lt;/p&gt;
&lt;p&gt;Over the last year, I have spent considerably more time on this problem, both thinking about it and building systems intended to work differently. That work convinced me that the problem is deeper than periodicity alone.&lt;/p&gt;
&lt;p&gt;I have pulled that thinking together into two new long-form pieces.&lt;/p&gt;
&lt;ul&gt;
&lt;li&gt;&lt;strong&gt;&lt;a href=&quot;https://rmhrisk.github.io/assurance-model/&quot;&gt;The Assurance Model Was Built for a World That No Longer Exists&lt;/a&gt;&lt;/strong&gt; looks at how the modern assurance model developed, what it actually establishes, and five distinct ways the evidence available can fail to justify the conclusion people ultimately rely on.&lt;/li&gt;
&lt;li&gt;&lt;strong&gt;&lt;a href=&quot;https://rmhrisk.github.io/continuous-assurance/&quot;&gt;Why Continuous Assurance Did Not Happen Until Now&lt;/a&gt;&lt;/strong&gt; asks why decades of automation gave us continuous evidence without continuous reasoning, what AI changes in that equation, and what a different assurance architecture might look like.&lt;/li&gt;
&lt;/ul&gt;
&lt;p&gt;They are intended to be read together.&lt;/p&gt;
&lt;p&gt;The first explains how we got here.&lt;/p&gt;
&lt;p&gt;The second explores what comes next.&lt;/p&gt;
</content:encoded><category>ai</category><category>standards</category><category>thoughts</category></item><item><title>From Chains to Trees</title><link>https://unmitigatedrisk.com/2026/08/from-chains-to-trees/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/08/from-chains-to-trees/</guid><description>The WebPKI has two structures that are not the same shape.</description><pubDate>Tue, 04 Aug 2026 22:34:37 GMT</pubDate><content:encoded>&lt;p&gt;The WebPKI has two structures that are not the same shape.&lt;/p&gt;
&lt;p&gt;One is a cryptographic graph of signed bindings. Public keys, names, entitlements, and the keys that authorized them. The other is a governance hierarchy of accountability. It explains why a relying party accepts that authority at all, and when it stops accepting it.&lt;/p&gt;
&lt;p&gt;Nearly every interesting failure in the history of the system lives in the gap between them. Misissuance, compromise, distrust events, and the long struggle with revocation are all stories about that mismatch.&lt;/p&gt;
&lt;p&gt;I wrote two long-form pieces that try to make the distinction legible.&lt;/p&gt;
&lt;p&gt;The first walks through the classical system as it actually exists. What a certificate is, how trust is delegated, how root programs and policy actually work, and why the governance layer has always mattered more than the certificate chain itself.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://rmhrisk.github.io/classical-webpki/&quot;&gt;A Deep Dive on the Classical WebPKI&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;The second examines the redesign now underway. Post-quantum signatures are simply too large for the classical model at public scale. The response is Merkle Tree Certificates. A CA logs certificates into its own tree, signs the tree head, and each certificate carries a short inclusion proof. One signature covers the batch. The proof is the path.&lt;/p&gt;
&lt;p&gt;This is not merely a cryptographic migration. It is the ecosystem cashing in a forced upgrade to close a decade-old compromise in Certificate Transparency. Transparency stops being a post-issuance promise and becomes the issuance mechanism itself. The wire format changes. Most of the governance carries forward.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://rmhrisk.github.io/pq-webpki/&quot;&gt;The Post-Quantum WebPKI&lt;/a&gt;&lt;/p&gt;
</content:encoded><category>certificates</category><category>security</category><category>thoughts</category></item><item><title>The Status Quo Outlived Its Status</title><link>https://unmitigatedrisk.com/2026/07/the-status-quo-outlived-its-status/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/07/the-status-quo-outlived-its-status/</guid><description>In security we like to say that the problems live in the gaps between systems. Each system, on its own, is usually coherent. It has a threat model, invariants, and someone who owns it. The seam between two systems is…</description><pubDate>Fri, 17 Jul 2026 14:40:54 GMT</pubDate><content:encoded>&lt;p&gt;In security we like to say that the problems live in the gaps between systems. Each system, on its own, is usually coherent. It has a threat model, invariants, and someone who owns it. The seam between two systems is owned by nobody, and each side quietly assumes the other is handling the thing that neither is. The load balancer assumes the backend validates. The parser assumes the canonicalizer normalized. The audit covers the software but not the network it runs on. Attackers don&apos;t have to beat either component. They just have to find the assumption neither side wrote down. The attacker gets to pick the threat model, and they pick the one that lives in the seam.&lt;/p&gt;
&lt;p&gt;Once you see this pattern, you see it everywhere, and not just in security.&lt;/p&gt;
&lt;h2&gt;Quality Lives in the Gaps of Ownership&lt;/h2&gt;
&lt;p&gt;In software quality, the same topology produces a different failure class. Security gaps produce exploits. Ownership gaps produce jank.&lt;/p&gt;
&lt;p&gt;A user&apos;s journey through a product is inherently horizontal. They sign up, configure, use, get billed, get help. But ownership is vertical, carved along team boundaries. So the experience degrades precisely at the handoffs. The onboarding flow owned by one team dumps you into a product owned by another, with terminology that doesn&apos;t match, settings that don&apos;t carry over, and an error message that references a concept from a third team&apos;s domain model. Every screen passed its own review. The journey never got one, because the journey has no owner.&lt;/p&gt;
&lt;p&gt;This is the same root cause as the security version. Contracts between components are written in terms of what each side provides, not what the whole must feel like or withstand. Functionality composes. Quality attributes don&apos;t. Not security, not usability, not performance, not consistency. Those are emergent properties of the composition, and emergent properties are exactly what per-team accountability structures can&apos;t see. A dashboard that takes eight seconds to load is usually five services each meeting their SLO.&lt;/p&gt;
&lt;h2&gt;You Ship the Org Chart in N Dimensions&lt;/h2&gt;
&lt;p&gt;Conway&apos;s law is usually quoted as a statement about architecture, that organizations design systems which mirror their communication structures. But architecture is just the most legible projection. The org chart also manifests in the security posture, where trust boundaries land wherever the reporting lines do. It shows up in the latency profile, where every org boundary becomes a network hop plus a queue plus a retry policy. It shows up in the data model, where the same &quot;customer&quot; is defined four ways because four VPs own four systems. It shows up in the compliance scope, where audits map to cost centers rather than to where the risk actually lives. It even shows up in the documentation, where each team documents its interior and nobody documents the crossings.&lt;/p&gt;
&lt;p&gt;You don&apos;t ship your org chart once. You ship it in every dimension at the same time.&lt;/p&gt;
&lt;p&gt;And it&apos;s stickier than the chart on the wall, because the formal org chart is only the visible part. The real partitioning is cultural. It is who trusts whom, which teams have history, where the scar tissue from the last reorg sits, and who won the last budget fight. Systems calcify around those boundaries. That&apos;s why reorgs so rarely fix seam problems. You can redraw the chart in a day, but the shipped artifact embodies the org chart as it existed at every point in the system&apos;s history. Legacy code is really legacy org structure. You&apos;re maintaining the fossil record of decade-old turf wars, and the team that could explain a given seam disbanded three reorgs ago.&lt;/p&gt;
&lt;h2&gt;Bureaucracy Is the Fixative&lt;/h2&gt;
&lt;p&gt;Here&apos;s where it hardens. Process is how organizations serialize distrust between units. Every approval gate, every ticket queue, every review board is a treaty boundary between fiefdoms, and treaties optimize for non-aggression, not for the emergent properties of the whole.&lt;/p&gt;
&lt;p&gt;The bureaucratic instinct when a seam fails is to add process at the seam. A checklist, a sign-off, a form. This papers over the gap without giving it an owner, and now the seam has a compliance artifact defending its existence.&lt;/p&gt;
&lt;p&gt;Which brings us to the uncomfortable part. Bureaucracy defends the status quo long past the point where the status quo lost its status. Not out of malice, and usually not even out of preference. The mechanism is simpler and more forgivable than that. Process is memory without comprehension.&lt;/p&gt;
&lt;p&gt;Every rule is a compressed lesson. Some incident happened, someone got burned, a control was born. But the compression is lossy. The rule survives while the context doesn&apos;t. The organization keeps executing the answer long after everyone who understood the question is gone. It&apos;s Chesterton&apos;s fence, except nobody can find the fence&apos;s author, the field it enclosed is now a parking lot, and there&apos;s a Fence Compliance team whose headcount depends on the fence.&lt;/p&gt;
&lt;p&gt;That&apos;s the inversion point. Controls that began as instruments become constituencies. A process accretes staff, tooling, budget, an annual review cycle. It stops being a means and becomes a stakeholder. And stakeholders defend themselves.&lt;/p&gt;
&lt;h2&gt;Asymmetric Bookkeeping&lt;/h2&gt;
&lt;p&gt;The genius of bureaucratic self-defense is that it never has to argue the status quo is good. It only has to make change expensive.&lt;/p&gt;
&lt;p&gt;Every proposal to remove a control gets evaluated by asking what risk removal creates. Nobody asks what risk retention creates. The cost of the existing process is denominated in currencies the review process can&apos;t count, things like velocity, morale, and opportunities that quietly went elsewhere, while the cost of change is denominated in the one currency it&apos;s built to count. With bookkeeping that asymmetric, the ratchet only turns one way.&lt;/p&gt;
&lt;p&gt;There&apos;s a reliable tell for when status is lost but the defense continues. The justifications go circular. Ask why we do this and the answer stops referencing a threat or an outcome and starts referencing the process itself. It&apos;s required for the audit. It&apos;s policy. That&apos;s the template. When a control&apos;s referent is another control, you are no longer managing risk. You are maintaining a liturgy. And liturgies are stable. That&apos;s what they&apos;re for.&lt;/p&gt;
&lt;p&gt;The people defending the liturgy usually aren&apos;t cynics, either. Institutions promote the people who thrived under the current rules, which means the people with the authority to change the system are precisely the ones whose careers validate it. They don&apos;t defend the status quo because they&apos;ve weighed it and found it good. They defend it because it&apos;s the ladder they climbed, and it&apos;s genuinely hard to see your own ladder as arbitrary. The system doesn&apos;t need guards. It manufactures believers. That&apos;s why correction so often comes from outside, from a competitor, a collapse, or a technology that routes around the institution entirely, rather than from reform. Reform requires the institution to metabolize the idea that its own selection function is the problem, which is roughly asking the liturgy to audit itself.&lt;/p&gt;
&lt;h2&gt;Deletion Has No Constituency&lt;/h2&gt;
&lt;p&gt;So what do you do about it? Two things, and both are harder than they sound.&lt;/p&gt;
&lt;p&gt;First, admit that the seams are the system, and staff them accordingly. You can&apos;t fix an n-dimensional Conway problem with a one-dimensional intervention. A design system fixes the UX projection. A service mesh fixes the network projection. A GRC tool fixes the audit projection. But the generator is the accountability topology itself, so the pathology just re-expresses in whatever dimension you didn&apos;t treat. The only durable moves are changing the human topology, which is rare, painful, and temporary, or forcing the interfaces to be explicit, adversarially specified, and owned as products. That&apos;s the real lesson of the Amazon API mandate. It wasn&apos;t about services. It was about giving the gaps owners.&lt;/p&gt;
&lt;p&gt;Second, build a decay function. Controls get created by incidents, which are vivid and have advocates. Control removal has no incident, no advocate, no ceremony. The beneficiary of deletion is diffuse while the loser is a specific person in the room. So organizations accumulate process the way arteries accumulate plaque, one reasonable deposit at a time. Sunset clauses, zero-based process reviews, and deletion treated as a first-class ritual with the same ceremony as launch are ideas everyone nods at and almost nobody funds. The organizations that stay fast are the ones that treat removing a rule as an achievement, not an admission.&lt;/p&gt;
&lt;p&gt;Because the status quo isn&apos;t defended because it won an argument. It&apos;s defended because it&apos;s the null hypothesis, and the burden of proof only ever runs one direction. Every so often, you have to flip the burden and make the process re-justify itself in terms of an outcome rather than another process. If it can&apos;t, it isn&apos;t protecting you anymore.&lt;/p&gt;
&lt;p&gt;It&apos;s just protecting itself.&lt;/p&gt;
</content:encoded></item><item><title>Why FIPS 140 Means Running Old Code</title><link>https://unmitigatedrisk.com/2026/07/why-fips-140-means-running-old-code/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/07/why-fips-140-means-running-old-code/</guid><description>You need to use FIPS 140 because of compliance, but have you ever asked what that requirement is actually for? What security properties are the authors of these policies trying to achieve?</description><pubDate>Mon, 13 Jul 2026 15:33:16 GMT</pubDate><content:encoded>&lt;p&gt;You need to use &lt;a href=&quot;https://rmhrisk.github.io/fips-140-3-corpus/&quot;&gt;FIPS 140&lt;/a&gt; because of compliance, but have you ever asked what that requirement is actually for? What security properties are the authors of these policies trying to achieve?&lt;/p&gt;
&lt;p&gt;In high-assurance deployments, the practical goal is usually to establish a meaningful security boundary around cryptographic keys. Organizations want explicit controls over who and what can use a key, and they do not want the answer to be every application or administrator with access to the host. They are also worried about key theft and abuse. For important signing and decryption keys, keeping the key out of the hands of the application and host OS is often the simplest way to force reasonable key-protection practices.&lt;/p&gt;
&lt;p&gt;These are real problems. When the threat group Storm-0558 acquired a highly sensitive Microsoft MSA signing key, operational failures allowed key material to escape the isolated signing environment and become accessible from a compromised engineering environment. That single extraction let the attackers forge tokens and compromise customer email accounts at scale. It is much harder to see that happening when a key is non-exportable and managed inside a hardware boundary. HSMs are not the only way to get these properties, but they are the one tool that forces you to think hard about how you operationalize a key, and that discipline has value.&lt;/p&gt;
&lt;p&gt;The trade-off is that you end up running old software you cannot patch for upstream security vulnerabilities. In the best case, you are years behind.&lt;/p&gt;
&lt;p&gt;Worse, this is usually non-memory-safe code that is entirely opaque to you. The firmware, the middleware, and the technical documentation are kept strictly behind lock and key by the vendor. You cannot inspect the code to see if it is vulnerable, and independent review is virtually impossible. The HSM vendor may have proactively patched those vulnerabilities, but more likely they have not.&lt;/p&gt;
&lt;p&gt;The cryptography in these modules almost never breaks. What breaks is the plumbing. For example, when an HSM takes in a payload like an administrative command or an authentication token of some sort, it has to parse it. This may mean relying on complex parsers or business logic, often written in aging C code. Because that plumbing is not memory safe, a single malformed input can lead to a buffer overflow or remote code execution right past the validated boundary, or even worse, a long-forgotten feature combined with new code could bypass policy controls around accessing the module altogether.&lt;/p&gt;
&lt;p&gt;Take the U-Boot forks as another example. When you look at how these embedded systems are actually built, they lean heavily on bootloaders, embedded operating systems, and vendor firmware that sit outside the cryptographic boundary but inside your trust story. A vendor might fork U-Boot, validate their module, and then that code is essentially frozen.&lt;/p&gt;
&lt;p&gt;Think about what boot verification actually involves. Something has to parse the firmware image, figure out which bytes are covered by the signature, compute the digest, and check the signature. The math for the signature might be FIPS validated, but the parsing, the offset arithmetic, and the handling of attacker-controlled structures is all just non-memory-safe C code.&lt;/p&gt;
&lt;p&gt;When researchers find vulnerabilities in X.509 parsing or U-Boot image processing, the flaws are not in the cryptography. They are in the plumbing. And because vendor version strings in this opaque, locked-down firmware often have no meaningful relationship to upstream release numbers, that fork may be a decade old.&lt;/p&gt;
&lt;p&gt;The real danger is that two curves are moving in opposite directions. The attack surface is being examined continuously. AI and automated variant analysis are getting exponentially better at finding previously unknown exploitable memory-safety bugs in old C code. Meanwhile, the validated base firmware remains essentially fixed.&lt;/p&gt;
&lt;p&gt;We do not have to guess about this. I recently published a &lt;a href=&quot;https://rmhrisk.github.io/fips-140-3-corpus&quot;&gt;data project analyzing recent FIPS 140-3 validations&lt;/a&gt;. The data shows how frozen these systems actually are. &lt;strong&gt;Out of 415 validated modules we looked at, 324 of them, 78 percent, showed no recorded public update after their initial validation.&lt;/strong&gt; The knowledge of security issues compounding every week is colliding with code that barely moves.&lt;/p&gt;
&lt;p&gt;FIPS 140 compliance buys you necessary domain separation and forces good operational habits. But the way the market achieves that separation often leaves you depending on a static, aging, and opaque codebase. The certificate tells you that a particular version met the requirements when it was evaluated. It does not tell you that the same code remains secure years later. At some point, the certificate becomes evidence not only of what was validated, but of how long the underlying system has stood still.&lt;/p&gt;
</content:encoded><category>security</category><category>thoughts</category></item><item><title>The Certification Ends Where the Code Begins</title><link>https://unmitigatedrisk.com/2026/07/the-certification-ends-where-the-code-begins/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/07/the-certification-ends-where-the-code-begins/</guid><description>Disclosure: I am an advisor to Binarly.</description><pubDate>Fri, 10 Jul 2026 22:36:46 GMT</pubDate><content:encoded>&lt;p&gt;&lt;em&gt;Disclosure: I am an advisor to Binarly.&lt;/em&gt;&lt;/p&gt;
&lt;p&gt;I recently built the &lt;a href=&quot;https://rmhrisk.github.io/fips-140-3-corpus/&quot;&gt;FIPS 140-3 Corpus&lt;/a&gt;, a dataset that pulls together the public record of FIPS validations. It combines CMVP certificate records, Security Policies, implementation details, operational environments, firmware versions, algorithm claims, and lifecycle data into something you can actually query and analyze rather than read one certificate at a time.&lt;/p&gt;
&lt;p&gt;I built it because I have spent enough years around certification programs to know that the interesting information is rarely in any single document. It emerges when you look at the record as a system. Once you do, a pattern shows up that I think deserves more attention than it gets. The public evidence tells you a great deal about what was evaluated and almost nothing about whether the code that shipped actually behaves the way the evaluation assumed.&lt;/p&gt;
&lt;h2&gt;What the paper trail shows&lt;/h2&gt;
&lt;p&gt;When you read Security Policies in bulk, you start seeing the same dependencies over and over. Validated modules lean on bootloaders, embedded operating systems, update agents, and vendor firmware that sit outside the cryptographic boundary but inside the trust story. The certificate covers the module. The security property depends on everything around it.&lt;/p&gt;
&lt;p&gt;U-Boot is a good example. Several modules in the corpus disclose it as part of their firmware or boot environment, and in some of those cases it participates directly in verifying firmware integrity before execution. Think about what that verification actually involves. Something has to parse the firmware image, figure out which bytes are covered by the signature, compute the digest, check the signature, and then decide what to run. RSA and SHA-256 handle two steps in that sequence. The parsing, the offset arithmetic, the decision about which fields are authenticated and which are attacker controlled, all of that is ordinary C code, and it is exactly where things tend to go wrong.&lt;/p&gt;
&lt;p&gt;Binarly&apos;s researchers recently published &lt;a href=&quot;https://www.binarly.io/blog/unfit-to-boot-breaking-u-boots-fit-signature-verification&quot;&gt;Unfit to Boot&lt;/a&gt;, which found previously unknown vulnerabilities in U-Boot&apos;s FIT image processing and signature verification path. The flaws were not in the cryptography. They were in the handling of attacker controlled structures before and around the verification operation. The math was fine. The plumbing was not.&lt;/p&gt;
&lt;p&gt;This is the oldest lesson in applied cryptography and we keep relearning it. The primitive is almost never the weakest link. The code that feeds the primitive is.&lt;/p&gt;
&lt;h2&gt;Where the evidence runs out&lt;/h2&gt;
&lt;p&gt;Here is where it gets uncomfortable. A Security Policy might identify its bootloader with a string like CNN35XX-UBOOT-4.03-03. That tells you a vendor U-Boot derivative is present. It tells you almost nothing else. Which upstream revision was it forked from? What did the vendor change? Which FIT features were compiled in? Were the fixes for known parsing flaws ever backported? Can externally supplied firmware even reach those code paths in this product?&lt;/p&gt;
&lt;p&gt;None of that is answerable from the certification record. Vendor version strings in embedded firmware often have no meaningful relationship to upstream release numbers. The fork may be a decade old. The fixes may have been applied selectively, or renamed, or lost in a rebase nobody documented.&lt;/p&gt;
&lt;p&gt;Conventional software composition tools do not close this gap either. They work by matching. Filenames, manifests, version strings, hashes, YARA rules, CVE mappings. That approach answers a useful question, namely whether a binary appears to contain a component already known to be vulnerable. Firmware defeats it routinely. Dependencies get statically linked into larger executables, symbols get stripped, and vendor forks drift far enough from upstream that the signatures stop matching anything.&lt;/p&gt;
&lt;p&gt;And matching cannot help with flaws nobody has found yet. Before the Unfit to Boot research existed, there was no CVE to map, no affected version range, no signature to match. Someone had to go look at the implementation first. Credit to the Binarly team for doing that work, and disclosure noted, but the point stands independent of any vendor. Until somebody examines what actually shipped, every downstream tool, database, and compliance process is working from an empty record.&lt;/p&gt;
&lt;h2&gt;Why I care about this for HSMs and BMCs&lt;/h2&gt;
&lt;p&gt;The corpus is full of devices that sit in unusually trusted positions. HSMs hold the keys for certificate authorities, payment systems, and governments. BMCs sit beneath the host operating system with control over firmware updates, recovery, and remote administration. I have spent much of my career depending on the first category and being quietly worried about both.&lt;/p&gt;
&lt;p&gt;These devices are exactly where the paper trail is weakest. They accumulate long lived vendor forks, inherited open source components, proprietary parsers, and hardware specific code written over many years, most of it statically linked and distributed only as compiled firmware. HSM firmware makes the visibility problem even worse. It is almost never publicly accessible, and on the rare occasion you do get an image, it is often encrypted or obfuscated, frequently with a key shared across the product line. Whatever that design accomplishes, it means customers and independent researchers see less of the code than a motivated attacker willing to recover the key. So we end up trusting these devices on the strength of certifications that, as the U-Boot example shows, stop well short of the code paths where real failures happen.&lt;/p&gt;
&lt;p&gt;That does not make the certifications worthless. It makes them a starting point. A validation record that discloses a U-Boot derivative in the boot chain has handed you a concrete question to ask your vendor. What evidence supports the claim that your product is unaffected by this class of flaw? Has anyone analyzed the released binary, or is the answer derived from a spreadsheet of version strings? Which fields of an incoming update are actually authenticated before any code touches them? Vendors who can answer those questions with evidence are telling you something important. So are vendors who cannot.&lt;/p&gt;
&lt;h2&gt;Documentation, inference, evidence&lt;/h2&gt;
&lt;p&gt;The way I think about it, assurance comes in layers and each layer answers a different question. The certificate tells you what was evaluated and under what assumptions. The corpus connects those artifacts across the whole ecosystem and exposes the shared dependencies and recurring architectures the individual documents obscure. The final layer is evidence about what actually shipped, and it can come from several places. Vendors tracking their forks against upstream and documenting backports. Independent analysis of released binaries. Researchers publishing the failure modes of mechanisms everyone assumed were sound.&lt;/p&gt;
&lt;p&gt;Most of the industry stops at the first layer. Procurement checks for the certificate, the checkbox gets ticked, and the boot chain full of forked bootloader code goes unexamined until someone publishes research like Unfit to Boot and everyone scrambles to figure out whether they are affected.&lt;/p&gt;
&lt;p&gt;I built the corpus to make the second layer easier, so that the public record can generate the right questions instead of just decorating RFP responses. The questions are the point. A validation record that names a bootloader fork should end in a conversation with the vendor about what is in it, not in a filed PDF. Trust in labels got us the last twenty years of firmware security. Trust supported by evidence is going to have to get us the next twenty.&lt;/p&gt;
</content:encoded><category>security</category><category>technology</category><category>thoughts</category></item><item><title>Steve Jobs, AI, and the Problem of Analysis Without Ownership</title><link>https://unmitigatedrisk.com/2026/07/steve-jobs-ai-and-the-problem-of-analysis-without-ownership/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/07/steve-jobs-ai-and-the-problem-of-analysis-without-ownership/</guid><description>There is an old Steve Jobs clip from a 1992 MIT Sloan talk that feels newly relevant in the age of AI. In the talk, available here as Steve Jobs MIT 1992 Lecture, Jobs is asked about consultants. His answer is not that…</description><pubDate>Thu, 09 Jul 2026 16:28:09 GMT</pubDate><content:encoded>&lt;p&gt;There is an old Steve Jobs clip from a 1992 MIT Sloan talk that feels newly relevant in the age of AI. In the talk, available here as &lt;a href=&quot;https://www.youtube.com/watch?v=AKhGVG2BxXY&quot;&gt;Steve Jobs MIT 1992 Lecture&lt;/a&gt;, Jobs is asked about consultants. His answer is not that consultants are unintelligent or useless. His criticism is more subtle. He says consultants often get to see a lot, analyze a lot, and recommend a lot, but they do not stay with the work long enough to own the consequences.&lt;/p&gt;
&lt;p&gt;They do not spend years living with the product, the team, the tradeoffs, the mistakes, the customers, the budgets, the bugs, or the recovery. They may see the fruit, as Jobs put it, but they “never really taste it.”&lt;/p&gt;
&lt;p&gt;That distinction matters.&lt;/p&gt;
&lt;p&gt;There is a kind of knowledge that comes from observation, and there is a different kind of knowledge that comes from ownership. Observation can make you articulate. Ownership makes you careful. Observation helps you describe what should happen. Ownership teaches you what actually happens when a recommendation meets constraints, incentives, politics, timelines, systems, and human behavior.&lt;/p&gt;
&lt;p&gt;There is also a kind of knowledge that only comes from time.&lt;/p&gt;
&lt;p&gt;Some problems cannot be understood in a single sitting. You need to carry them around for a while. You read, step away, come back, notice what still bothers you, test a different framing, sleep on it, and then see the thing that was hiding in plain sight. That kind of soaking is not inefficiency. It is often how judgment forms.&lt;/p&gt;
&lt;p&gt;That is the parallel to AI.&lt;/p&gt;
&lt;p&gt;AI is making analysis abundant. It can read more than we can read, summarize faster than we can summarize, find patterns across larger datasets, generate plausible options, and produce recommendations that sound polished and confident. That is useful. But it is not the same as judgment.&lt;/p&gt;
&lt;p&gt;Used poorly, AI becomes consulting at machine scale. It is fast, articulate, and superficially impressive, but disconnected from whether its recommendations actually survive contact with reality.&lt;/p&gt;
&lt;p&gt;It can say what should be done without knowing what happened after someone tried to do it. It can identify risks without understanding which ones mattered. It can produce a roadmap without living through the missed dependency, the customer objection, the policy constraint, the budget cut, the migration failure, or the second-order effect six months later.&lt;/p&gt;
&lt;p&gt;It can also make us confuse speed of response with depth of understanding. That may be the deeper risk. AI can collapse the slow work of thinking into the first plausible answer. It can make a problem feel resolved before we have really spent time with it. It can produce fluency before we have earned conviction.&lt;/p&gt;
&lt;p&gt;That does not make AI useless. It makes the design problem clearer.&lt;/p&gt;
&lt;p&gt;The lazy version of the AI story is the self-driving car analogy, namely once the machine becomes safer, faster, or more consistent, the human gets pushed out of the loop. There will be domains where that is true. But much of knowledge work is different. The goal is not only to execute a task correctly. The goal is to understand the problem well enough to make better decisions the next time.&lt;/p&gt;
&lt;p&gt;Execution tools can displace. Reasoning tools should compound.&lt;/p&gt;
&lt;p&gt;That is why the most interesting promise of AI is not simply that it becomes a better consultant or even a better operator. It is that AI can help humans become better operators.&lt;/p&gt;
&lt;p&gt;Used well, AI becomes a way to think with the material. It helps us understand datasets that are too large to hold in our heads. It lets us explore problem spaces from more angles. It helps test assumptions, compare interpretations, surface edge cases, and ask better questions. It can show us patterns we would have missed, but the value is not just the pattern. The value is that, through the process of interrogation, we understand the problem more deeply ourselves.&lt;/p&gt;
&lt;p&gt;AI should not shorten our attention so much as deepen what our attention can hold.&lt;/p&gt;
&lt;p&gt;A good AI system should help us return to a problem with more context than we had the last time. It should preserve the questions we asked, the assumptions we tested, the contradictions we found, the evidence that mattered, and the places where our understanding changed. It should make it easier to spend real time with the problem, not merely produce an answer faster.&lt;/p&gt;
&lt;p&gt;In that sense, the best use of AI is not instant certainty. It is structured patience.&lt;/p&gt;
&lt;p&gt;It lets us soak in a problem more effectively. By that I mean it enables us to hold more evidence in view, revisiting prior interpretations, comparing today’s answer to yesterday’s uncertainty, and gradually turning analysis into understanding.&lt;/p&gt;
&lt;p&gt;The goal should not be to outsource judgment to AI. The goal should be to use AI to improve the conditions under which judgment is formed.&lt;/p&gt;
&lt;p&gt;A good AI system should not merely say, “Here is the answer.” It should help us see why the answer might be true, where it might be fragile, what evidence supports it, what alternatives exist, and what would change our mind. It should help us move from diagnosis to action, from action to feedback, and from feedback to learning.&lt;/p&gt;
&lt;p&gt;That is the line between AI as consultant and AI as learning partner.&lt;/p&gt;
&lt;p&gt;This is also where many AI products will disappoint. Dashboards full of findings, risks, summaries, and recommendations can look impressive while still leaving the actual burden on the human team. They create the appearance of progress without necessarily improving understanding. The human still has to decide what matters, translate the finding into action, make the change, verify the outcome, and remember the lesson later.&lt;/p&gt;
&lt;p&gt;The point is not that findings and recommendations are useless; they are necessary. Findings are the beginning of the loop, not the end of it. Systems that stop there are not doing judgment automation. They are doing analysis transfer.&lt;/p&gt;
&lt;p&gt;The more interesting systems will close the loop. They will connect analysis to execution, execution to verification, and verification to institutional memory. Not because humans should be removed from the process, but because humans should be able to reason from a better substrate.&lt;/p&gt;
&lt;p&gt;This is where Jobs&apos; point lands today. The scarce thing is not access to analysis. AI will make analysis abundant. The scarce thing is accumulated judgment, something that only comes from acting, observing, correcting, and learning over time.&lt;/p&gt;
&lt;p&gt;Observation gives you language. Ownership gives you consequence. Time gives you depth. Feedback gives you judgment.&lt;/p&gt;
&lt;p&gt;Jobs’ critique of consulting was not just a warning about consultants. It was a warning about any tool, process, or person that gets rewarded for sounding right without having to live with whether they were right.&lt;/p&gt;
&lt;p&gt;AI will be most valuable not when it becomes the smartest consultant in the room, but when it helps teams build judgment faster, seeing more, acting sooner, sitting with the problem longer, verifying outcomes, and remembering what reality taught them.&lt;/p&gt;
&lt;p&gt;The future of AI in knowledge work should not be analysis without ownership. It should be ownership made smarter.&lt;/p&gt;
</content:encoded><category>ai</category><category>thoughts</category></item><item><title>The Breaker, the Priest, and the Philosopher</title><link>https://unmitigatedrisk.com/2026/06/the-breaker-the-priest-and-the-philosopher/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/06/the-breaker-the-priest-and-the-philosopher/</guid><description>Spend enough years in security and you notice that the people whose judgment you actually trust are rarely the ones with the cleanest credentials.</description><pubDate>Thu, 18 Jun 2026 17:19:19 GMT</pubDate><content:encoded>&lt;p&gt;Spend enough years in security and you notice that the people whose judgment you actually trust are rarely the ones with the cleanest credentials.&lt;/p&gt;
&lt;p&gt;They are the ones who have been wrong in public often enough to develop taste. Their authority is earned backward, from scars rather than definitions. When they look at a scheme and say, no, that is wrong, and here is the deeper reason, they are not deriving it from first principles. They are recognizing a shape they have been cut by before.&lt;/p&gt;
&lt;p&gt;That is worth taking seriously. In security you get little standing to philosophize until you have shipped something, broken something, defended something, or watched something fail. The person who starts from what is identity, or what is trust, but has never lived with the consequences of an answer, barely exists as a respected type. The people who carry real philosophical weight almost always came up through contact with failure first.&lt;/p&gt;
&lt;p&gt;So the security philosopher is not the pure theorist. The philosopher is what a survivor of failure becomes once the failures start to rhyme and a reflective habit sets in. Most often that survivor is a breaker, because breaking is the most direct contact you can have with the gap between how a system should work and how it does. But breaking is not the only contact that leaves marks, and that turns out to matter later.&lt;/p&gt;
&lt;p&gt;Everyone who matures this way is answering one question, whether or not they say it out loud.&lt;/p&gt;
&lt;p&gt;Why does this keep happening?&lt;/p&gt;
&lt;p&gt;You earn the right to answer by watching it happen enough times that fixing the bug stops feeling like an answer. Whatever conclusion you settle on is what you turn into. Some decide people do not understand the systems deeply enough. Some, that bad claims go unchallenged too long. Some, that security is downstream of engineering. Some, that the bytes are downstream of institutions and power. Some, that the abstractions themselves are broken. Some, that the failure is intrinsic and the only honest response is to keep hunting.&lt;/p&gt;
&lt;p&gt;Those answers create the taxonomy. The genus is philosopher. The species are sorted by the answer each one gives, and by the way each one tries to make that answer true for other people.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/06/security-philosopher-taxonomy.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/06/security-philosopher-taxonomy-1024x819.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;h2&gt;The Sage&lt;/h2&gt;
&lt;p&gt;The Sage believes it keeps happening because nobody understands the systems deeply enough.&lt;/p&gt;
&lt;p&gt;The Sage transmits by instantiation rather than argument. The worldview gets built into a tool, written into a book, embedded in a way of working, and you absorb it by use. A fuzzer can teach an entire philosophy of bug finding. Coverage becomes the thing worth chasing. The tool makes the argument every time it runs, so nobody has to persuade you in a thread. The position is already standing in the room, made of working code.&lt;/p&gt;
&lt;p&gt;The Sage is contemplative, the monk of the genus. The work is not quiet because it is timid. It is quiet because it expects reality to do the teaching.&lt;/p&gt;
&lt;h2&gt;The Gadfly&lt;/h2&gt;
&lt;p&gt;The Gadfly believes it keeps happening because people are wrong in public and nobody corrects them.&lt;/p&gt;
&lt;p&gt;The Gadfly&apos;s philosophy exists only in motion. It lives in the thread, the argument, the review comment, the refusal to let an incorrect claim stand. This is Socratic in the original and irritating sense. You learn what is true by watching the argument refuse to die.&lt;/p&gt;
&lt;p&gt;The Gadfly may share the Sage&apos;s diagnosis exactly. People do not understand the system. But the method is the opposite. The Sage builds, the Gadfly fights. Both believe misunderstanding is the enemy. They differ on whether the cure is a tool or a wound.&lt;/p&gt;
&lt;h2&gt;The Builder Evangelist&lt;/h2&gt;
&lt;p&gt;The Builder Evangelist believes it keeps happening because security is downstream of bad engineering.&lt;/p&gt;
&lt;p&gt;This is the breaker who concludes the dramatic failure is only the visible symptom. The real incident happened earlier, in how software was designed, reviewed, deployed, owned, or forgotten. The answer is not more heroics. It is to change how teams build, with security folded into normal engineering life rather than bolted on as a gate at the end or a priesthood that arrives with findings after everyone has moved on. The insight only counts if it propagates into how people actually work.&lt;/p&gt;
&lt;p&gt;The missionary energy is the tell. Converts always have it, and this is the convert&apos;s slot. Philosophy that has to spread to count as true.&lt;/p&gt;
&lt;h2&gt;The Statesman&lt;/h2&gt;
&lt;p&gt;The Statesman believes it keeps happening because the bytes are downstream of institutions, incentives, and power.&lt;/p&gt;
&lt;p&gt;This one did not go deeper into the stack. They went up, out of the assessment shop and into platforms, governments, trust programs, procurement, incident governance, the places where the adversary is sometimes the org chart and sometimes a nation. The wisdom gets cashed out in policy and in who sits at which table.&lt;/p&gt;
&lt;p&gt;The risk of the type is floating clear of the actual bytes. The best Statesmen never do. They remember the policy is only real if it changes what happens at the machine, the credential, the incident bridge. The worst become fluent in altitude and lose contact with the ground.&lt;/p&gt;
&lt;h2&gt;The Theorist&lt;/h2&gt;
&lt;p&gt;The Theorist believes it keeps happening because the abstractions themselves are unsound.&lt;/p&gt;
&lt;p&gt;This is the opposite vector from the Statesman. Where the Statesman goes up toward power, the Theorist goes down toward formalism. Weird machines. Exploitation as programming a machine nobody meant to build. Security as a subset of reliability. Trust as an operational claim, not a noun.&lt;/p&gt;
&lt;p&gt;This is the species that comes closest to the academic register, but the ticket was still bought through breaking first. The formalism is trusted because the person doing it has felt the abstraction fail in their hands. That is the difference between earned theory and decorative theory.&lt;/p&gt;
&lt;h2&gt;The Refusenik&lt;/h2&gt;
&lt;p&gt;The Refusenik is the apex breaker who declines to metamorphose at all. Not from inability. From principle.&lt;/p&gt;
&lt;p&gt;The refusal is itself an answer. It keeps happening because failure is intrinsic to systems of any real complexity, and pretending a framework or a doctrine can end it is the deeper error. There is no theory waiting at the top of the climb, only the next finding. So the Refusenik stays the predator and calls the philosophizing a comfortable retreat from the only thing that is real, the work in front of them.&lt;/p&gt;
&lt;p&gt;This is the lower bound of the taxonomy. It proves that becoming a philosopher of the discursive kind is a choice, not an inevitability, and it does so by holding a real position rather than an empty one. Some of the best who ever lived remain here permanently, and they are right to.&lt;/p&gt;
&lt;h2&gt;The Priest&lt;/h2&gt;
&lt;p&gt;The Priest is the auditor, the compliance keeper, the custodian of the framework. The Priest is the scandal of the taxonomy, but not for the reason the field assumes.&lt;/p&gt;
&lt;p&gt;The reflexive complaint is that the Priest arrived without breaking. No public exploit, no system torn open, no credential earned the old way. By the breaker&apos;s accounting, no scars at all. That accounting is the actual error.&lt;/p&gt;
&lt;p&gt;Much compliance really is theater. Much audit work mistakes evidence for reality. Much framework worship trains people to pass inspections while risk keeps moving underneath them. None of that is in dispute. But at scale the Priest is often the only force keeping an organization&apos;s vital signs visible. Compliance read generously is not theater. It is a pulse, one of the few observable ways to ask whether the organization is doing the things it claims to.&lt;/p&gt;
&lt;p&gt;And the Priest does have scars, just not the kind the breaker recognizes. The Priest learns by watching organizations lie to themselves in patterns, watching the same control fail the same way across a dozen audits, watching risk reappear in process and ownership long after the technical finding was closed. That is sustained contact with failure. It leaves marks. The breaker simply does not read them as marks, because they did not draw blood the familiar way.&lt;/p&gt;
&lt;p&gt;So the scandal is not that the Priest skipped the initiation. It is that the breaker cannot see the Priest&apos;s scars as scars. Seeing them requires fusing two diagnoses that rarely live in the same person. The Builder Evangelist says automate or drown. The Statesman says the real system is organizational health. The generous read of the Priest requires both at once, and most people who came up breaking cannot hold both, so they read the Priest as the enemy.&lt;/p&gt;
&lt;p&gt;Sometimes they are right. Sometimes they are only defending their own credentialing system.&lt;/p&gt;
&lt;h2&gt;The seam in the taxonomy&lt;/h2&gt;
&lt;p&gt;Two forces are doing the work here. One is diagnosis, the answer to why this keeps happening. The other is temperament, how you try to transmit that answer. The clean version of the theory says these collapse into one, that the way you transmit is downstream of what you concluded and who you are. The Sage builds because he decided depth is the problem and because he is contemplative. The Gadfly fights because he decided public error is the problem and because he cannot leave it alone.&lt;/p&gt;
&lt;p&gt;But the Sage and the Gadfly may share the same diagnosis. If they do, they are one species wearing two faces, and the real joint is diagnosis, with transmission as a surface effect. The alternative is that transmission is itself fundamental, that how you choose to make a thing true for other people is a deeper fact about you than the proposition you are trying to make true.&lt;/p&gt;
&lt;p&gt;I do not think this is settled, and I am not sure it should be. A taxonomy that resolved it cleanly would claim to know which of two people who believe the same thing is the more serious, on the sole basis of whether they build or fight. That is a claim worth resisting.&lt;/p&gt;
&lt;h2&gt;The point&lt;/h2&gt;
&lt;p&gt;Security does not really trust credentials. It trusts scars. That instinct is mostly healthy. It keeps empty abstraction out of the room and gives weight to people who can smell a failure coming rather than just describe one.&lt;/p&gt;
&lt;p&gt;But every credentialing system has a blind spot, and the breaker&apos;s is believing that only breaking confers standing. The whole taxonomy is one argument against that belief, because every species on it earned its authority through a different kind of contact with failure.&lt;/p&gt;
&lt;p&gt;The breaker learns by cutting into systems.&lt;/p&gt;
&lt;p&gt;The builder learns by watching teams repeat the same mistakes.&lt;/p&gt;
&lt;p&gt;The statesman learns by watching incentives defeat correctness.&lt;/p&gt;
&lt;p&gt;The theorist learns by watching abstractions collapse.&lt;/p&gt;
&lt;p&gt;The priest learns by watching organizations lie to themselves in patterns.&lt;/p&gt;
&lt;p&gt;The refusenik learns by never looking away from the hunt long enough to be comforted by a story about it.&lt;/p&gt;
&lt;p&gt;Five are reflective and one refuses reflection, but all six are forms of earned contact, and none is the only one that counts. What you become is the answer you settle on for why this keeps happening, and the way of making it true for others that you cannot help but reach for.&lt;/p&gt;
&lt;p&gt;The breakers who refuse the question stay hunters. The keepers who never broke anything are mistrusted for it, sometimes fairly and sometimes not. Everyone else becomes a philosopher of one species or another, whether or not they would accept the word.&lt;/p&gt;
&lt;p&gt;The only real question is which one you became.&lt;/p&gt;
</content:encoded><category>security</category><category>thoughts</category></item><item><title>The Prompt Is an Argument</title><link>https://unmitigatedrisk.com/2026/06/the-prompt-is-an-argument/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/06/the-prompt-is-an-argument/</guid><description>If you accept that, the next question is unavoidable. What kind of record should a good prompt be?</description><pubDate>Thu, 18 Jun 2026 16:51:45 GMT</pubDate><content:encoded>&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/2026/06/the-prompt-is-the-meaning/&quot;&gt;The prior piece&lt;/a&gt; made a narrow claim. &lt;strong&gt;The prompt is the record, because a system can only act on what reaches it&lt;/strong&gt;. Intent that stays in your head does not govern anything. Context that never reaches the model does not constrain anything. Purpose that is not in the prompt, the retrieved material, the tools, the policies, or the examples is not part of the decision environment.&lt;/p&gt;
&lt;p&gt;If you accept that, the next question is unavoidable. &lt;strong&gt;What kind of record should a good prompt be?&lt;/strong&gt;&lt;/p&gt;
&lt;p&gt;For goal-oriented work, it should be an argument. More precisely, it should be enthymematic, an argument that leaves its obvious premise unstated for the audience to supply.&lt;/p&gt;
&lt;p&gt;The form is Aristotle&apos;s. He called the enthymeme the body of proof, the strongest of rhetorical proofs, a kind of syllogism with a premise left out. Its strength comes from the omission. Stating what the audience already accepts is tedious, while assuming the right premise makes the conclusion feel almost self-evident. That power holds on one condition. The missing premise has to be one the audience can already supply.&lt;/p&gt;
&lt;p&gt;A capable model supplies a premise readily. It does not reliably supply yours, and from the output alone you cannot tell which one it used. Where your premise and its default mostly agree, the gap is cheap. Where the wrong one is costly, or where you have to reconstruct the reasoning later, it is not.&lt;/p&gt;
&lt;p&gt;Look at a bad prompt with that in mind.&lt;/p&gt;
&lt;blockquote&gt;
&lt;p&gt;&quot;Write about DevOps automation.&quot;&lt;/p&gt;
&lt;/blockquote&gt;
&lt;p&gt;That is a topic, not a goal. The model can go anywhere. CI/CD, infrastructure as code, job displacement, Kubernetes, a bland survey that explains nothing. It did not disobey. The prompt simply did not contain an argument for it to advance, so it advanced none.&lt;/p&gt;
&lt;p&gt;Now the same subject with the premise restored.&lt;/p&gt;
&lt;blockquote&gt;
&lt;p&gt;&quot;Explain why DevOps automation is becoming more viable now that production systems can be modeled, tested, and validated in synthetic environments.&quot;&lt;/p&gt;
&lt;/blockquote&gt;
&lt;p&gt;This carries a claim the first version left in your head. Automation gets safe where results can be checked. Coding agents became useful because code has feedback loops. It compiles or it does not, tests pass or fail, the type system objects. As production systems become modelable and testable, operations starts to acquire the same machinery, so it starts to look more automatable for the same reason coding did. You could not spell all of that out if you tried. The context behind any goal is unbounded, so every prompt is already a compression, and the only real choice is what to keep. Keep the load-bearing premise and drop what the model already handles. Here that premise is the causal claim, present enough that the model knows which answers would count as success, the one it would otherwise have to invent.&lt;/p&gt;
&lt;p&gt;That is the difference between a task prompt and a goal prompt. A task prompt says do X. A goal prompt says do X in service of Y, because Z is the relationship that matters. The &quot;because Z&quot; is where most prompt failures live.&lt;/p&gt;
&lt;p&gt;People leave it out because they assume the model already holds the frame. They write as if it knows the business context, the adversary, the institutional scar tissue, the product strategy, the audience, the risk appetite, the standard of correctness. Then a plausible, fluent, useless answer comes back and surprises them. The model was not confused. It was unconstrained. It got a task without the premise that made the task mean anything.&lt;/p&gt;
&lt;p&gt;Humans skip premises constantly and get away with it. A lawyer says &quot;that creates a reliance problem&quot; and the room knows the shape of the issue. An engineer says &quot;that breaks rollback&quot; and the team feels the operational cost. A security person says &quot;that moves the trust boundary&quot; and the people who have lived with the system know why it matters. The shorthand works because the history is shared. A model does not inherit that history unless you hand it over. It does not know which premise is obvious inside your company, which analogy is carrying the real weight, which part of the request is decorative and which part is load-bearing. It does not know that &quot;make this clearer&quot; meant keep the technical claim but cut the wording that lets a reader hear monocausality.&lt;/p&gt;
&lt;p&gt;This is why writing a good prompt feels more like drafting than asking. A good lawyer does not write words that merely sound like the client&apos;s intent. A good lawyer writes words that survive interpretation by someone else, later, under pressure, with incentives to read them the wrong way. The document has to carry its operative meaning forward once the author has left the room. A prompt carries the same burden into a system that completes patterns from whatever materials it has. Leave the wrong premise implicit and the model may complete the argument in the wrong direction. Omit it and the model substitutes a generic one. Supply several competing premises and the model optimizes for the one easiest to write about rather than the one that matters. That is how a prompt produces fluent nonsense. Not that the model cannot write, but that the prompt did not preserve the reasoning.&lt;/p&gt;
&lt;p&gt;So before writing a goal-oriented prompt, ask one question. What has to be true for this output to be useful? Not what topic it should cover, what format it should take, how long it should run. What has to be true. The answer is usually the missing premise. For a product strategy it is often the market wedge. For a security review it is the attacker&apos;s actual path. For an executive summary it is the decision the executive has to make. For a critique it is the standard the work should be judged against. For a rewrite it is the misunderstanding you are trying to prevent.&lt;/p&gt;
&lt;p&gt;That premise does not have to appear as a formal sentence. It can live in the framing, in an example, in the acceptance criteria, in the source material, or in an instruction about what not to optimize for. It only has to be somewhere in the record. Otherwise the system is not helping you pursue a goal. It is producing text near a topic.&lt;/p&gt;
&lt;p&gt;In a single prompt you can hold the whole record in view. A production system spreads it out. The effective prompt is no longer the user&apos;s sentence. It is that sentence plus the system instruction, the developer instruction, the retrieved documents, the available tools, the policies, the examples, the memory, the model version, and the configuration around all of it. The argument is distributed across those layers, which makes enthymematic design more important rather than less. The question stops being what the user asked and becomes what argument the system received. Did retrieval supply the missing premise or omit it? Did the tool definitions encode the right standard for action? Did the policy layer quietly override the user&apos;s goal? Did the examples teach the wrong pattern?&lt;/p&gt;
&lt;p&gt;Those are governance questions. A system that cannot reconstruct its effective prompt cannot reconstruct the argument it acted on. And a system that cannot reconstruct that argument cannot explain why its output was reasonable or unreasonable, compliant or not, safe or merely plausible.&lt;/p&gt;
&lt;p&gt;The enthymeme works when the missing premise is shared enough to be supplied safely. That is the one condition these systems do not meet on their own.&lt;/p&gt;
&lt;p&gt;So the work is not to make prompts longer. It is to make them carry the right inference.&lt;/p&gt;
&lt;p&gt;The missing premise will be supplied either way. The only question is by whom. You provide it, or you let the system invent it.&lt;/p&gt;
</content:encoded><category>ai</category></item><item><title>The Prompt Is the Meaning</title><link>https://unmitigatedrisk.com/2026/06/the-prompt-is-the-meaning/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/06/the-prompt-is-the-meaning/</guid><description>Why textualism, original public meaning, and AI governance all turn on the same uncomfortable fact: intent does not travel unless it becomes part of the record.</description><pubDate>Tue, 02 Jun 2026 22:50:30 GMT</pubDate><content:encoded>&lt;p&gt;&lt;strong&gt;Why textualism, original public meaning, and AI governance all turn on the same uncomfortable fact: intent does not travel unless it becomes part of the record.&lt;/strong&gt;&lt;/p&gt;
&lt;p&gt;There is an old fight in legal interpretation about where meaning lives.&lt;/p&gt;
&lt;p&gt;Intentionalists look for purpose. They ask what Congress meant to do, what the drafters were trying to accomplish, and what problem the law was meant to solve. Legislative history matters in this view because floor speeches, committee reports, drafter notes, and surrounding debate can reveal the intent behind the enacted words.&lt;/p&gt;
&lt;p&gt;Textualists are skeptical of that move. They argue that the law is the text that was enacted, not the private intentions of the people who helped write it. The words are the law. The meaning is what the text would have conveyed to a reasonable reader, not what a motivated advocate can later reconstruct from a convenient committee report.&lt;/p&gt;
&lt;p&gt;Originalists make a related move in constitutional interpretation. Original public meaning says the Constitution means what its words would have been understood to mean by the public at the time of ratification. Not what a drafter secretly intended. Not what a later judge wishes it said. The meaning is anchored in the text, the historical context, and the interpretive record available at the relevant time.&lt;/p&gt;
&lt;p&gt;You do not have to be a textualist or an originalist to see the infrastructure point.&lt;/p&gt;
&lt;p&gt;Once a system has to act on language, intent is not enough. Intent has to travel through something. It has to travel through text, context, rules of interpretation, and a record of what was available to the interpreter when the decision was made. Otherwise, “what I meant” becomes an after-the-fact story.&lt;/p&gt;
&lt;p&gt;Anyone who has spent time debugging prompts has run into the same problem.&lt;/p&gt;
&lt;p&gt;You thought you were telling the model to be careful. You were actually telling it to hedge every answer into uselessness. You thought you were asking it to be concise. You were actually removing the context it needed to be right. You thought you were giving it freedom to reason. You were actually giving it permission to invent.&lt;/p&gt;
&lt;p&gt;The words on the page were doing work you did not realize they were doing.&lt;/p&gt;
&lt;p&gt;That is the uncomfortable part of working with language models. A prompt is not what you meant. It is not the conversation you wish you had with the model. It is not the background assumptions in your head. It is not the thing you would have clarified if another person had looked confused.&lt;/p&gt;
&lt;p&gt;A prompt is the artifact the system received, interpreted, and acted on.&lt;/p&gt;
&lt;p&gt;That is why the analogy to textualism matters. In human organizations, we constantly rely on unwritten context. We rely on shared history, institutional memory, tone, relationships, and the ability to stop and ask, “wait, what did you mean by that?” Human communication survives ambiguity because humans have recovery mechanisms.&lt;/p&gt;
&lt;p&gt;AI systems do not get those recovery mechanisms for free.&lt;/p&gt;
&lt;p&gt;There is no hallway conversation where you explain that when you said X you obviously meant Y. No shared institutional memory unless it is supplied. No unstated assumptions unless they are embedded somewhere in the context. No ability to rely on “what everyone knew” unless what everyone knew made it into the materials the system was given.&lt;/p&gt;
&lt;p&gt;The system only has the record.&lt;/p&gt;
&lt;p&gt;This does not mean the model is a textualist judge. It is not. The originalist’s reasonable reader is a legal construct. A model is a versioned, probabilistic system operating inside a specific runtime. The same words can produce different behavior under a different model, a different instruction hierarchy, a different retrieval result, a different tool definition, a different policy layer, or a different configuration.&lt;/p&gt;
&lt;p&gt;So the lesson is not that the model found the one correct meaning of your prompt. The lesson is that your intent did not travel.&lt;/p&gt;
&lt;p&gt;Intent does not become operational just because it existed in your head. Context does not exist just because your team would have understood it. Purpose does not govern the system unless it is encoded in the materials the system actually sees.&lt;/p&gt;
&lt;p&gt;This is the prompt engineering lesson people often miss. Prompt engineering is not merely a collection of magic phrases, though some prompt patterns work for model-specific reasons that are not obvious from the surface text. At its core, prompt engineering is drafting. It is the work of turning intention into operative language.&lt;/p&gt;
&lt;p&gt;That is why it feels so much like legal drafting. You are not writing what you wish the system understood. You are writing the thing the system will act on.&lt;/p&gt;
&lt;p&gt;In production AI systems, that “thing” is larger than the sentence the user typed.&lt;/p&gt;
&lt;p&gt;The operative prompt includes the system instruction, the developer instruction, the retrieved documents, the tool definitions, the prior turns, the examples, the policies, the memory, the model version, the ranking logic that decided which facts were included and which were left out, and the configuration that shaped how deterministic or creative the output could be.&lt;/p&gt;
&lt;p&gt;That is the effective prompt.&lt;/p&gt;
&lt;p&gt;This is where context engineering starts to absorb prompt engineering. The hard problem is no longer merely finding better words to ask the model. The hard problem is constructing the interpretive environment in which the model can behave reliably enough, predictably enough, and accountably enough for the job it is being asked to do.&lt;/p&gt;
&lt;p&gt;Legal interpretation has always depended on more than raw text. Textualists still need grammar, usage, canons of construction, dictionaries, historical context, and an account of the reader. Original public meaning still needs evidence of how words were used at the relevant time. Even the most text-centered theories need a record.&lt;/p&gt;
&lt;p&gt;AI systems make that dependency operational.&lt;/p&gt;
&lt;p&gt;What was the user prompt? What system instruction controlled it? What policy applied? What documents were retrieved? What facts were omitted? Which tool schemas were available? Which model ran? Which version of the surrounding system produced the answer?&lt;/p&gt;
&lt;p&gt;These are not merely implementation details. They are the interpretive record of the system.&lt;/p&gt;
&lt;p&gt;That is why the prompt is the meaning. Not because the model is a perfect reader. Not because the words have one stable meaning across all systems. Not because intent is irrelevant. But because the system can only act on what made it into the operative prompt. If something was not in that record, it was not available to govern the system’s behavior.&lt;/p&gt;
&lt;p&gt;At that point the issue changes. It is no longer just an interpretation problem. It becomes an evidence problem.&lt;/p&gt;
&lt;p&gt;For a toy prompt, failure looks like annoyance. The answer was too verbose. The model misunderstood. The prompt needed tuning.&lt;/p&gt;
&lt;p&gt;For a production system, failure looks like a governance gap. The system made a decision, but nobody can reconstruct what it was asked, what it knew, what it was allowed to do, what policy constrained it, what model produced it, or which version of the surrounding context shaped the result.&lt;/p&gt;
&lt;p&gt;If you cannot reconstruct the effective prompt, you cannot explain the output. If you cannot explain the output, you cannot evaluate whether the system behaved correctly. If you cannot evaluate whether it behaved correctly, you cannot govern it.&lt;/p&gt;
&lt;p&gt;This is why prompts need version control. Retrieved documents need provenance. Tool definitions need change history. Policy layers need to be preserved. Model versions need to be tied to outputs. Evaluations need to capture not just the answer, but the context that made the answer plausible.&lt;/p&gt;
&lt;p&gt;But preservation is only the first step. A record without evaluation is archaeology. A record without monitoring is trivia. A record without enforcement is a diary. Governance requires the record, but it also requires machinery that acts on it: tests, policy gates, drift detection, human review, incident analysis, and change control.&lt;/p&gt;
&lt;p&gt;Otherwise, the organization has outputs but not governance.&lt;/p&gt;
&lt;p&gt;A log tells you what happened. A record tells you what the system was asked to do, what it was allowed to know, what constraints it was operating under, and why the resulting behavior was plausible from the materials available to it.&lt;/p&gt;
&lt;p&gt;Without that, accountability collapses into storytelling.&lt;/p&gt;
&lt;p&gt;The team says the model was supposed to be careful. The prompt says “avoid unsupported claims,” but the retrieved material was stale. The policy says “follow the customer’s procedure,” but the procedure was missing from context. The audit says the system made a decision, but nobody can reconstruct the versioned bundle of instructions, documents, tools, model, policies, and configuration that shaped it.&lt;/p&gt;
&lt;p&gt;At that point, you are not governing the system. You are narrating around it.&lt;/p&gt;
&lt;p&gt;That is the deeper lesson from textualism, originalism, and prompt debugging.&lt;/p&gt;
&lt;p&gt;Text is never just text. It is text plus an interpretive frame, text plus context, text plus a record of what counted as meaning at the time. In law, we fight about that because rights, obligations, and institutional power depend on it. In AI systems, we are turning that fight into software.&lt;/p&gt;
&lt;p&gt;The prompt is not your intent.&lt;/p&gt;
&lt;p&gt;The output is not self-explaining.&lt;/p&gt;
&lt;p&gt;The effective prompt is the record.&lt;/p&gt;
&lt;p&gt;You may not fully own the model. You may not own the provider’s policy stack. You may not own the training process, the safety layers, or the hidden machinery that shapes the output.&lt;/p&gt;
&lt;p&gt;But you can own your side of the interpretive record. You can preserve what you supplied, what the system saw, what it was allowed to do, what it returned, how it was evaluated, and what changed afterward.&lt;/p&gt;
&lt;p&gt;That is the infrastructure of accountable AI.&lt;/p&gt;
&lt;p&gt;The prompt is the meaning because the prompt, properly understood, is the record the system acted on.&lt;/p&gt;
&lt;p&gt;You either govern that record, or you inherit someone else’s explanation.&lt;/p&gt;
</content:encoded><category>thoughts</category></item><item><title>A CA That Produces Evidence, Not Promises</title><link>https://unmitigatedrisk.com/2026/05/a-ca-that-produces-evidence-not-promises/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/05/a-ca-that-produces-evidence-not-promises/</guid><description>In my last post I argued that high-assurance systems should stop asking to be trusted on the basis of institutional promises and start producing verifiable runtime evidence about what actually happened. This post is the…</description><pubDate>Sat, 23 May 2026 23:32:34 GMT</pubDate><content:encoded>&lt;p&gt;&lt;em&gt;&lt;strong&gt;In my &lt;a href=&quot;https://unmitigatedrisk.com/2026/05/a-ca-built-for-the-threat-model-we-actually-have/&quot;&gt;last post&lt;/a&gt; I argued that high-assurance systems should stop asking to be trusted on the basis of institutional promises and start producing verifiable runtime evidence about what actually happened. This post is the worked example. A certificate authority built that way, what choices it forced, and what is and is not done yet.&lt;/strong&gt;&lt;/em&gt;&lt;/p&gt;
&lt;p&gt;When I was at Google I got to work a bit with the BeyondCorp folks. What most didn’t understand is that the BeyondCorp Google used internally was substantially different from the BeyondCorp they launched to customers. On Windows and Linux, the path was TPM-backed device credentials associated with each machine, turning possession of the laptop and an authenticated credential into another factor. The deployment timelines varied by platform, but the important point was the architectural shape hardware-bound device identity became part of the access decision.&lt;/p&gt;
&lt;p&gt;You will notice I didn&apos;t mention Macs. That&apos;s because Apple, although it had a similar secure processor on its devices, did not give customers attestations over keys stored inside it. We could put keys in the Secure Enclave. We could not prove to a third party that we had. For years we tried to get Apple to change that. Eventually they did, and what they shipped was not what we asked for.&lt;/p&gt;
&lt;p&gt;We didn&apos;t get the ability to put arbitrary keys in the enclave under our control with attestation. We got a device-bound credential signed by Apple that let us verify, at enrollment time, that a request was coming from one of our devices. We used that as a bootstrap to enroll a short-lived credential that the OS stored and used for day-to-day authentication. Apple&apos;s attestation answered the &lt;em&gt;which device&lt;/em&gt; question. Our short-lived credential answered everything that came after.&lt;/p&gt;
&lt;p&gt;That worked. The standardization piece is &lt;a href=&quot;https://datatracker.ietf.org/doc/draft-ietf-acme-device-attest/&quot;&gt;draft-ietf-acme-device-attest&lt;/a&gt;, an IETF working group document I co-author, which lets the same ACME flow carry an Apple &lt;a href=&quot;https://www.youtube.com/watch?v=Yu0kvmZFlmg&quot;&gt;Managed Device Attestation&lt;/a&gt; statement, a TPM key attestation, or a YubiKey assertion without the CA needing to special-case each platform. Apple&apos;s adoption was what unlocked normalizing on a single way across the fleet to authenticate these devices.&lt;/p&gt;
&lt;p&gt;That normalization is the relying-party side of the credential story. The hard-edge property, &lt;em&gt;this key lives on this specific device, signed by a chain you can verify back to the manufacturer&lt;/em&gt;, is now what we expect from a workload, a laptop, a phone, a passkey, a SPIFFE workload identity. MFA was the first compensating control for the weaknesses in passwords and API keys and bearer tokens. Passkeys, SPIFFE, and certificate-based zero-trust segmentation are the structural answer. We replaced the secret-you-know with a key-you-hold and bound it to hardware where we could.&lt;/p&gt;
&lt;p&gt;Google&apos;s internal production systems run the same shape, with &lt;a href=&quot;https://cloud.google.com/blog/products/identity-security/titan-in-depth-security-in-plaintext&quot;&gt;Titan&lt;/a&gt; chips as the foundational substrate for the devices that get on the network for internal and cloud workloads.&lt;/p&gt;
&lt;p&gt;That shift is well underway on the side of the wire that &lt;em&gt;uses&lt;/em&gt; credentials.&lt;/p&gt;
&lt;p&gt;The side that &lt;em&gt;issues&lt;/em&gt; them is still mostly software on a server with an API key and a SOC 2 report.&lt;/p&gt;
&lt;p&gt;If issuance hasn&apos;t kept up with what we now expect from credential holders, what would catching up actually look like? The &lt;a href=&quot;https://unmitigatedrisk.com/2026/05/a-ca-built-for-the-threat-model-we-actually-have/&quot;&gt;previous post&lt;/a&gt; made the general argument. The CA should be asked to produce evidence, not to be trusted. This post is what that actually looks like when you build it. A certificate authority where the issuance path itself is the evidence, where the policy that fired is part of what was measured, where the key release is gated on the measurement of the binary asking for it, and where every issued certificate is accompanied by a portable bundle a relying party can verify against trust anchors they already hold.&lt;/p&gt;
&lt;p&gt;The architecture is designed to run on both AWS and Google Cloud. On AWS, enclave-based deployments use Nitro Enclave attestations, while VM-level deployments can use NitroTPM-backed evidence for measured boot, instance identity, and workload state. On Google Cloud, Confidential VM deployments use AMD SEV-SNP or Intel TDX attestation for the protected execution environment, with Cloud HSM as the key custodian. Where the system needs VM identity, boot-state evidence, or platform posture outside the confidential-computing attestation itself, it can also use vTPM-based evidence.&lt;/p&gt;
&lt;p&gt;That breadth is intentional, and I&apos;ll come back to why. But the real load-bearing architectural choice is not which cloud, HSM, enclave, VM, or attestation primitive we use. It is the shape of the issuance system inside each trust boundary.&lt;/p&gt;
&lt;h2&gt;Two components, one evidence chain&lt;/h2&gt;
&lt;p&gt;The split is structural, not procedural.&lt;/p&gt;
&lt;p&gt;In a single-binary CA, policy enforcement and signing authority are separated by code paths inside one process. A vulnerability in the policy evaluator is a vulnerability in the signing authority, because they share an address space. The compartments exist in the source code. They do not exist at runtime.&lt;/p&gt;
&lt;p&gt;Here, the compartments are real. The architecture splits issuance into two attested components.&lt;/p&gt;
&lt;p&gt;The registration authority receives the certificate request, resolves identity from authoritative sources, evaluates the issuance policy against the requester&apos;s posture and attestation, and produces a signed authorization context. The signing oracle holds the path to the CA&apos;s signing key and produces the signature. Each runs in a separate attested environment. Each is measured separately. Each has its own keys. Both are written in Go. Memory-safe in normal code, reproducible without ceremony, and a standard library that already covers most of what a CA needs.&lt;/p&gt;
&lt;p&gt;The RA and the oracle are different binaries, with different measurements, with different keys, on different network endpoints, joined by mutually-attested TLS where each side has independently verified the other&apos;s measurement before either will talk. A compromise of the RA does not give the attacker the signing key, because the signing key is not in the RA&apos;s address space and is not reachable from the RA&apos;s network position. A compromise of the oracle does not give the attacker the policy evaluator&apos;s identity providers, because the oracle has no identity providers wired into it. The interface between them is narrow, signed, and replay-protected.&lt;/p&gt;
&lt;p&gt;This is the cross-machine version of the kernel-userland boundary. The kernel does not trust userland&apos;s claim that a syscall is authorized. It does the check itself, every time. The oracle does the same thing for the parts of issuance it can verify independently.&lt;/p&gt;
&lt;p&gt;What this buys is a bounded blast radius on a compromised RA.&lt;/p&gt;
&lt;p&gt;If an attacker takes over the RA, including the RA&apos;s signing key, the damage is bounded only to the extent that the oracle requires independently verifiable evidence for the facts that matter. For profile authorization, key binding, replay protection, RA authorization, and certificate structure, the oracle can check those facts locally.&lt;/p&gt;
&lt;p&gt;For domain control validation, the same is true only when the evidence is cryptographic or independently corroborated, such as DNSSEC-validatable DNS evidence or signed observations from independent multi-perspective validators. The current implementation does not yet do either of these things, but adding support for them is a straightforward extension of the model. Without that, however, an RA compromise can still become a validation compromise.&lt;/p&gt;
&lt;p&gt;That distinction matters. The oracle does not make an RA trustworthy. It makes the RA&apos;s assertions conditional. Where the RA presents verifiable evidence, the oracle can check it. Where the RA presents only its own statement about what it observed, the oracle can enforce structure, freshness, profile policy, replay protection, and RA authorization, but it cannot turn that statement into ground truth.&lt;/p&gt;
&lt;p&gt;The architectural property is not that the oracle magically knows every fact the RA observed. It is structural separation plus independent verification wherever the fact is independently verifiable. Every other property the rest of this post will describe, measured policy, gated key release, per-operation attestation, portable evidence, depends on that boundary.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/05/svgviewer-png-output-3.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/05/svgviewer-png-output-3-1024x751.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;h2&gt;What I mean by evidence&lt;/h2&gt;
&lt;p&gt;Before walking through the attestations, it is worth being precise about the word evidence.&lt;/p&gt;
&lt;p&gt;A raw measurement is a narrow statement, this binary had this digest, this key was generated by this HSM, this quote was signed by this platform, this public key matches the attested key. Those statements matter because they are the hard edge of the system.&lt;/p&gt;
&lt;p&gt;But they are not enough to explain issuance. A certificate is issued because policy evaluated a set of facts and authorized a specific profile for a specific requester at a specific time.&lt;/p&gt;
&lt;p&gt;So evidence here means the decision record, the raw attestations where they can be disclosed, the verifier results, the policy digest, the profile binding, the facts the policy evaluated, the signed authorization context, the oracle&apos;s per-operation attestation, the custodian&apos;s key-release evidence, and the transparency proof.&lt;/p&gt;
&lt;p&gt;draft-ietf-acme-device-attest helps with the requester-side device and key attestation. The CA-side runtime evidence chain is still built from platform-specific TEE, TPM, HSM, KMS, and transparency-log evidence. The point is not that one standard covers all of it. The point is that the CA should preserve the evidence chain instead of collapsing it into a one-bit pass/fail result or a promise.&lt;/p&gt;
&lt;h2&gt;What each attestation lets you verify&lt;/h2&gt;
&lt;p&gt;Cross-checking only matters if the things being checked are concrete. Four attestations cross the issuance flow, each one produced by a different party, each one letting the next party check something specific. It is worth walking through what each one actually lets you verify before going further.&lt;/p&gt;
&lt;h3&gt;The client&apos;s attestation&lt;/h3&gt;
&lt;p&gt;What the RA verifies: that the requestor controls the private key whose public half is in the certificate request, that the key lives on a specific piece of hardware, that the hardware has a manufacturer-vouched identity, and that the key was generated under conditions the policy can reason about.&lt;/p&gt;
&lt;p&gt;The shape of the attestation changes between platforms. A TPM-bound key on a Windows or Linux machine, a Secure Enclave key on an Apple device, and a key in a YubiKey&apos;s PIV slot each arrive in a different format with a different signing chain and different platform-specific fields. The function is the same. Each one carries a binding between the key in the CSR and a piece of hardware, an identifier for that hardware, the conditions under which the key can be used, and a certificate chain back to a manufacturer the policy can decide whether to trust.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://datatracker.ietf.org/doc/draft-ietf-acme-device-attest/&quot;&gt;draft-ietf-acme-device-attest&lt;/a&gt; is the wire format that carries any of these in the same ACME flow, so the CA doesn&apos;t need to special-case each platform. What the policy sees in the end is the same five things regardless of which platform produced them. &lt;em&gt;Does the requestor control the private key. Is the key on a piece of hardware. Whose hardware. Under what conditions can it be used. Does the manufacturer chain trace back to a root the policy will accept.&lt;/em&gt;&lt;/p&gt;
&lt;h3&gt;The RA&apos;s environment attestation&lt;/h3&gt;
&lt;p&gt;What anyone holding the document can verify: that the RA ran a specific measured image inside an attested execution environment, that the cloud provider signed off on the measurement, that the workload identity or role is the one the deployment expects, and that the public key bound to that measured environment for the rest of its lifetime is the one in the document.&lt;/p&gt;
&lt;p&gt;AWS Nitro, AMD SEV-SNP, and Intel TDX each produce a different document, but the load-bearing contents are the same: a measurement of what was loaded, an identifier for the platform that produced it, the operating context, and a vendor chain back to a root the relying party can verify.&lt;/p&gt;
&lt;p&gt;Worth being explicit about what the document does not let you verify. It does not tell you who deployed the measured environment, who runs the cloud account, or what the operator intended to run. It tells you what was measured. The operator&apos;s intent is a separate question, answered by the published image list and the policy that names which measurements are acceptable. A relying party who trusts the hardware vendor&apos;s chain can verify the measurement. They still have to verify, separately, that the measurement is one they should accept.&lt;/p&gt;
&lt;h3&gt;The oracle&apos;s environment attestation&lt;/h3&gt;
&lt;p&gt;What it lets the RA verify, during handshake: that the oracle the RA is about to send an authorization context to is running the published image, and that the signing key the oracle will use for its half of the mutual TLS is the one bound to that image at boot.&lt;/p&gt;
&lt;p&gt;What it lets a relying party verify, after issuance: the same thing, plus one additional binding. The oracle produces a &lt;em&gt;fresh&lt;/em&gt; attestation for every signing operation, and the attestation is bound to the certificate that operation just produced and to the RA on the other end of the conversation that authorized it. Where the RA&apos;s boot-time attestation carries the long-lived public key the measured environment will sign with, the oracle&apos;s per-operation attestation pins this specific certificate to this specific oracle measurement with this specific RA.&lt;/p&gt;
&lt;p&gt;The difference between boot-time and per-operation attestation is the difference between &quot;the box looked right when it started&quot; and &quot;the box looked right when it did the thing you actually care about.&quot; Boot-time attestation is what most confidential-computing deployments do today. It tells a relying party the deployment was valid at startup. It tells them nothing about whether the deployment was still valid five hours later when an actual issuance happened. Per-operation attestation closes that gap.&lt;/p&gt;
&lt;h3&gt;The custodian&apos;s attestation&lt;/h3&gt;
&lt;p&gt;The CA private key is not loaded by the operator. It is held by a custodian, an HSM with discrete-silicon attestation, a cloud KMS that gates use on attestation, or another measured execution environment. The custody model matters. In the HSM case, the CA key is non-exportable. The signing oracle never receives the private key. It sends a signing request to the HSM, and the HSM signs only when the relevant policy, authorization, and attestation conditions are satisfied. In the software-protected or KMS-protected case, the key, or the key-encryption material needed to use it, may be wrapped so it is usable only inside a signing oracle whose attestation matches a published image.&lt;/p&gt;
&lt;p&gt;What the custodian&apos;s evidence lets a relying party verify depends on that model. For an HSM-held key, the evidence is not that the key was released. It is that the non-exportable key was used by a particular custodian, under particular firmware, configuration, policy, and authorization conditions. For a wrapped software or KMS-backed key, the evidence can show that key material was made usable only because the oracle&apos;s measurement matched a measurement on the published list. Either way, if an operator runs a different binary, however benign the reason, the signing path fails. The dragon&apos;s teeth around the data center are still there. They no longer have to do the whole job.&lt;/p&gt;
&lt;p&gt;For a concrete look at what one of these documents actually contains, rather than just what it proves, the Peculiar Ventures attestation library parses examples from each of these platforms, including the Marvell HSM attestation produced by Google Cloud HSM. An attestation without a verifier is a claim. With a verifier, it is something a relying party can act on.&lt;/p&gt;
&lt;h2&gt;Policy as mechanism, not promise&lt;/h2&gt;
&lt;p&gt;Reading all of those attestations means the policy that evaluated them has to be something concrete enough to read.&lt;/p&gt;
&lt;p&gt;Today&apos;s CAs publish a CP/CPS. The Certificate Policy and Certification Practice Statement is a document describing what the CA will and will not do. An auditor samples evidence once a year against the document. The document and the system that produces certificates are not cryptographically linked. The relying party trusts that the document describes the system. The auditor&apos;s annual report is the closing of the loop.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://www.cedarpolicy.com/&quot;&gt;Cedar&lt;/a&gt; policies are different. They are a domain-specific language with declarative semantics, written under version control, statically analyzable, and small enough to read in a sitting. The policy that fires inside the signing oracle is compiled into the measured binary. The digest of the policy travels in the evidence bundle that accompanies the certificate. A relying party can re-fetch the source at the named digest, read the rules, and decide for themselves whether the policy that authorized their certificate is a policy they accept.&lt;/p&gt;
&lt;p&gt;The contrast that matters operationally is the one between policy-as-promise and policy-as-mechanism. A CP/CPS is a promise. The auditor verifies, by sample, that the practice resembles the promise. A Cedar policy compiled into a measured binary, with its digest in the bundle, is a mechanism. The relying party verifies, per certificate, that the rules that fired are the rules the CA published.&lt;/p&gt;
&lt;p&gt;There is a sharp footgun specific to Cedar that is worth naming because the answer to it is part of the architecture. Cedar&apos;s evaluator skips a policy that throws while accessing an attribute that was not present. The convenient result is that policies stay readable in the absence of optional context. The inconvenient result is that a &lt;code&gt;forbid&lt;/code&gt; policy with an unguarded attribute access can silently drop, which is a fail-open. The lint at build time requires a &lt;code&gt;has&lt;/code&gt; guard before any optional attribute access. A policy that would have failed open is now a build error. The defense-in-depth move is structural. The policy author cannot ship a fail-open by accident.&lt;/p&gt;
&lt;h2&gt;What this looks like in practice&lt;/h2&gt;
&lt;p&gt;An employee gets a new smart card from corporate IT in a sealed blister pack. They plug it in.&lt;/p&gt;
&lt;p&gt;The enrollment client on the laptop sees a card it doesn&apos;t know. It reads the card&apos;s GlobalPlatform Card Production Lifecycle data and the card recognition data, learns this is a factory-fresh retail token from a manufacturer it has a trust root for, and verifies the card identity attestation back to that root. The card is genuine. It has never been provisioned. The enrollment client knows what kind of token it is looking at and what the policy says to do with one.&lt;/p&gt;
&lt;p&gt;The client provisions the token. It generates a new keypair on the card under a policy that requires user PIN for use and marks the key non-exportable. The card produces a key attestation: a statement signed by the card&apos;s manufacturer-installed attestation key asserting that &lt;em&gt;this specific public key was generated on this specific token, has these specific usage constraints, and will never leave the hardware&lt;/em&gt;. The enrollment client builds a CSR for the new key and has the card sign it, which is the standard proof that the requestor controls the corresponding private key. It then packages the CSR, the user&apos;s identity claim, and the card&apos;s attestation into an ACME request and sends it to the RA.&lt;/p&gt;
&lt;p&gt;That is the first link. The chain is going to have several.&lt;/p&gt;
&lt;p&gt;The RA receives the request inside its measured execution environment. It verifies the CSR signature against the public key in the CSR, which proves the requestor controls the corresponding private key. It verifies the card&apos;s attestation against the manufacturer chain. &lt;em&gt;Yes, this is a genuine retail token from a manufacturer we trust. Yes, the key in the CSR is on the card. Yes, the usage constraints match policy.&lt;/em&gt; It resolves the identity claim against the corporate identity provider. &lt;em&gt;Yes, this user exists. Yes, they are entitled to this credential type. Yes, their device posture matches.&lt;/em&gt; It evaluates the Cedar policy against the cross-product of the device, the identity, and the requested profile. &lt;em&gt;Yes, all of it permits issuance.&lt;/em&gt; It builds an authorization context, signs it with the key bound to its measured environment, and sends it to the signing oracle.&lt;/p&gt;
&lt;p&gt;The signing oracle receives the context inside its own measured execution environment, over mutually-attested TLS where both sides have verified the other&apos;s measurement before they would talk. It does not simply believe what the RA told it. For facts backed by independently verifiable evidence, the oracle re-verifies that evidence against its own configured verifier. In this example, it re-verifies the card&apos;s attestation, cross-checks the claims the RA made about the card, the requested profile, and the requester, validates the profile binding, the certificate type, the validity window, the structural invariants the profile requires, and confirms that this RA is authorized to ask for this kind of issuance. It rejects replays. Only then does it ask the custodian for the signing key. The custodian releases it because the oracle&apos;s attestation matches the published image. The oracle signs. It produces a fresh per-operation attestation binding this certificate to this measured execution environment and to the RA that authorized it. The issuance is written to a transparency log that independent witnesses cosign.&lt;/p&gt;
&lt;p&gt;The bundle that comes back to the enrollment client contains the card&apos;s attestation that the key is on the token, the RA&apos;s signed authorization context naming the identity, the profile, the policy digest, and the verifiers it ran, the oracle&apos;s per-operation attestation binding the signature to a measured binary on a measured platform, the custodian&apos;s evidence that the key was released only because the oracle&apos;s measurement matched, the transparency log inclusion proof and witness cosignatures showing the issuance was published before the certificate was returned, and the certificate itself.&lt;/p&gt;
&lt;p&gt;Every party in the flow did the logical equivalent of what every other party did. It verified upstream evidence against a manufacturer, platform, custodian, or witness root it already trusted, did its work, and produced its own evidence for the downstream party to verify. The bundle packages those attestations and proofs so the subscriber, or anyone the subscriber shares it with, can re-walk the chain end to end against the same trust roots, without having to take any single party&apos;s word for it.&lt;/p&gt;
&lt;p&gt;The card manufacturer&apos;s root says the key is on the hardware. The chip vendor&apos;s TEE root says the RA ran the measured image. The chip vendor&apos;s TEE root says the oracle ran the measured image. The HSM vendor&apos;s root says the key was released to a measurement that matched. The witness network&apos;s cosignatures say the log is what the operator published, not a fork served to one relying party. A relying party who trusts each of those roots can verify the certificate&apos;s basis of issuance from the evidence bundle, instead of relying only on the CA&apos;s institutional promise.&lt;/p&gt;
&lt;p&gt;The CA is not asked only to be trusted. The CA produced evidence.&lt;/p&gt;
&lt;h2&gt;What is built&lt;/h2&gt;
&lt;p&gt;The architecture above runs in preproduction today on AWS and Google Cloud.&lt;/p&gt;
&lt;p&gt;On AWS, that means Nitro Enclaves for enclave-based issuance components and NitroTPM-backed evidence for VM-level identity, measured boot, and workload posture. On Google Cloud, it means AMD SEV-SNP and Intel TDX Confidential VMs for protected execution, Cloud HSM as custodian, and vTPM-based evidence where VM boot state or workload identity needs to be represented.&lt;/p&gt;
&lt;p&gt;Classical ECDSA and post-quantum &lt;a href=&quot;https://csrc.nist.gov/pubs/fips/204/final&quot;&gt;ML-DSA-65&lt;/a&gt; (FIPS 204) hierarchies operate in parallel. &lt;a href=&quot;https://csrc.nist.gov/pubs/fips/203/final&quot;&gt;ML-KEM-768&lt;/a&gt; (FIPS 203) is the subject key for TLS key-exchange certificates. Cedar policy with the fail-open lint is enforced in the oracle. Per-operation attestation, evidence bundles, the custodian gating key release on measurement, mutually attested TLS between RA and oracle, end-to-end on both clouds.&lt;/p&gt;
&lt;p&gt;Each trust domain signs from its own sub-CA, and classical and post-quantum issuance never share a key. Machine, machine-with-EAP, user, group, workload, smart card, TPM AK, and SSH all sit under separate sub-CAs; classical and PQ are separated within each family. A compromise of any single signing key bounds the damage to one family-and-algorithm slice. The architecture treats hierarchy multiplicity as security-domain separation, not as an algorithm-bridging side effect.&lt;/p&gt;
&lt;p&gt;Profiles wired up today cover machine authentication including EAP-TLS, DNS-validated TLS server certificates, workload identity including SPIFFE-style URI identifiers, user and group signing and encryption, smart card and PIV logon, TPM AK bootstrap, and SSH user, workload, and host certificates. Each family that supports both has a classical and a post-quantum variant.&lt;/p&gt;
&lt;p&gt;The platform breadth is there because no single TEE family fits every customer environment, and the architecture should not be hostage to one chip vendor or one cloud.&lt;/p&gt;
&lt;h2&gt;The 2029 problem&lt;/h2&gt;
&lt;p&gt;None of what I&apos;ve described above is algorithm-bound. That matters because the algorithms are about to change.&lt;/p&gt;
&lt;p&gt;In March 2026, Google&apos;s Heather Adkins and Sophie Schmieg &lt;a href=&quot;https://blog.google/innovation-and-ai/technology/safety-security/cryptography-migration-timeline/&quot;&gt;set 2029 as the target&lt;/a&gt; for completing Google&apos;s migration to post-quantum cryptography. Google&apos;s timeline matters beyond Google. They run Chrome and Android, and when they move, the WebPKI moves with them. &lt;a href=&quot;https://www.nsa.gov/Press-Room/News-Highlights/Article/Article/3148990/nsa-releases-future-quantum-resistant-qr-algorithm-requirements-for-national-se/&quot;&gt;CNSA 2.0&lt;/a&gt; puts 2027 on software and firmware signing in National Security Systems and 2030 on general use. The CABF is working through its own timeline. Federal procurement requirements are already moving.&lt;/p&gt;
&lt;p&gt;The CA infrastructure that exists today was designed for the snapshot of math problems that the 2029 transition invalidates. Every CA in production is going to be re-architected before it lands. The algorithms expire. The migration is not optional.&lt;/p&gt;
&lt;p&gt;The transition itself is going to be heterogeneous. The classical-PQC X.509 path is going to run for a long time alongside what eventually replaces it. &lt;a href=&quot;https://datatracker.ietf.org/doc/draft-ietf-plants-merkle-tree-certs/&quot;&gt;Merkle Tree Certificates&lt;/a&gt; — batched, transparency-native issuance with much smaller per-certificate overhead — are a likely part of the answer to ML-DSA&apos;s signature size on the wire. The architecture above does not care which container format the certificate is in. The attested issuance pipeline, the custodian-gated key release, the evidence bundle, the transparency log — all of it operates on the &lt;em&gt;issuance&lt;/em&gt; side. MTC issuance benefits from runtime evidence the same way X.509 issuance does, and the patterns in this post carry over.&lt;/p&gt;
&lt;p&gt;A CA built on the runtime-evidence pattern does not cost more to deploy at the moment you are already rebuilding. It costs more &lt;em&gt;only&lt;/em&gt; if you skip the rebuild, and skipping is not on the table. The hardware-anchored credential side of the wire has been arriving in production for a decade. The issuance side is the part still running on the old shape. The PQ deadline is the forcing function that makes the issuance side move. The choice is between rebuilding the old shape with new algorithms, and rebuilding it with the same discipline that the relying-party side has spent the last decade adopting.&lt;/p&gt;
&lt;p&gt;Short lifetimes with &lt;a href=&quot;https://www.rfc-editor.org/rfc/rfc9773&quot;&gt;ARI&lt;/a&gt; make the operational side tractable. Seven-day certificates with ARI-driven renewal turn the PQ migration from a flag day into a moving window. The fleet rotates without an emergency, without anyone touching a machine, because the CA can shorten the renewal window for specific machines or profiles whenever it wants to.&lt;/p&gt;
&lt;p&gt;That is what the next CA looks like. It is not a different CA than the one I have been describing. It is the same one.&lt;/p&gt;
</content:encoded></item><item><title>A CA Built for the Threat Model We Actually Have</title><link>https://unmitigatedrisk.com/2026/05/a-ca-built-for-the-threat-model-we-actually-have/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/05/a-ca-built-for-the-threat-model-we-actually-have/</guid><description>This builds on earlier posts on what attestation actually proves, what confidential computing is and isn&apos;t, and an honest accounting of the problems with the current generation of TEEs. None of those problems go away…</description><pubDate>Sat, 23 May 2026 20:35:05 GMT</pubDate><content:encoded>&lt;p&gt;&lt;em&gt;&lt;strong&gt;This builds on earlier posts on &lt;a href=&quot;https://unmitigatedrisk.com/2025/12/attestation-what-it-really-proves-and-why-everyone-is-about-to-care/&quot;&gt;what attestation actually proves&lt;/a&gt;, &lt;a href=&quot;https://unmitigatedrisk.com/2026/04/confidential-computing-what-it-is-what-it-isnt-and-how-to-think-about-it/&quot;&gt;what confidential computing is and isn&apos;t&lt;/a&gt;, and an &lt;a href=&quot;https://unmitigatedrisk.com/2026/04/confidential-computings-inconvenient-truth/&quot;&gt;honest accounting of the problems&lt;/a&gt; with the current generation of TEEs. None of those problems go away here. The argument is that despite those limitations, attestation is an important tool. Certificate issuance is overdue to use it.&lt;/strong&gt;&lt;/em&gt;&lt;/p&gt;
&lt;p&gt;Back in the 1990s, I was doing some consulting for DigiNotar, &lt;a href=&quot;https://www.researchgate.net/publication/269333601_Black_Tulip_Report_of_the_investigation_into_the_DigiNotar_Certificate_Authority_breach&quot;&gt;yes, that DigiNotar&lt;/a&gt;. They had CA facilities in a data center whose perimeter still had WWII-era anti-tank obstacles, large concrete barriers sometimes called &quot;dragon&apos;s teeth.&quot; Of course, this was an artifact of the facility&apos;s history, but data centers are designed from a security perspective with layers of physical protection, including barriers, mantraps, biometrics, individual vaults with cages, individual racks with their own locks and biometrics, cameras, and more. The threat of physical theft, destruction, or manipulation is exactly what these facilities are designed to mitigate.&lt;/p&gt;
&lt;p&gt;When building a CA inside one of these facilities, we design yet another layer of protection. Administration networks are segmented from transaction networks, interconnects from supporting infrastructure, the issuance environment from the systems holding root keys. We add our own physical segmentation on top of that so we can build controls around multiple parties being necessary for the more sensitive operations, while still letting routine hardware maintenance happen on the schedule the SLA needs.&lt;/p&gt;
&lt;p&gt;These are all useful and important things, but the reality is that CA key material is not likely to be physically stolen. It is more likely to be compromised from the outside. We solve these problems through design, not by writing more code.&lt;/p&gt;
&lt;p&gt;Meaningfully measured code forces design upstream of the code itself.&lt;/p&gt;
&lt;p&gt;A measurement of a monolithic blob proves almost nothing useful. A measurement that names a specific role, a specific security domain, and a specific assertion the verifier is supposed to act on, proves something. The roles, the domain boundaries, and the questions the verification has to answer have to exist before any code is written, or the attestation is a signature on nothing in particular.&lt;/p&gt;
&lt;p&gt;In operating system design, we have similar problems. In naive systems, we load cryptographic keys into memory on a running, network-connected system, accidentally exposing ourselves to memory-disclosure bugs where a network attacker can steal keys. Heartbleed is the canonical example, but the class is what matters. We do this because it is simpler and faster, but it is also less secure. As systems designers, we address this by moving those keys out of the process of the network-connected application and into a different user context. That way, an attacker cannot simply get the network-connected service to dump memory. They have to get persistence and cross a kernel-enforced user boundary.&lt;/p&gt;
&lt;p&gt;This is old wisdom. Least privilege and privilege separation exist because network-facing code should not also be the thing that controls the keys.&lt;/p&gt;
&lt;p&gt;A parallel showed up in early cryptocurrency exchanges. Hot wallets were used as signing oracles because the design and deployment work needed to prevent that had not been done, and many of the high-profile compromises of that era trace back to that gap. The exchanges that survived learned to put boundaries between the wallet and the network. That boundary did most of the work. The dragon&apos;s teeth around the building did the rest.&lt;/p&gt;
&lt;p&gt;When third parties need to rely on external services operating in these environments, they often rely on auditors to attest that management assertions about operational practices are actually being followed. These assessments are usually performed by CPAs, not security specialists, which can limit their value. They also often rely on sampling a small portion of transactions to confirm that the controls being evaluated are being followed. That sample is drawn from evidence provided by the entity being audited, which is also the party paying for the audit.&lt;/p&gt;
&lt;p&gt;All of the things discussed above help bring some minimal level of transparency and verifiability, but it is turtles all the way down, layer on layer, none of them reaching the runtime where the actual compromise happens. This is where confidential computing, and solutions like Private Cloud Compute, start to matter.&lt;/p&gt;
&lt;p&gt;Policy changes meaning in this model. In the traditional assurance world, policy is a written promise. The CA publishes a CP or CPS, the operator commits to following it, and the auditor samples evidence to decide whether that promise was kept. In a runtime-evidence model, policy becomes part of the mechanism. A measured binary evaluates a specific policy, produces a decision, and the digest of that policy travels with the evidence. The shift is from policy as promise to policy as enforcement, from “trust us, this is what we do” to “this is the policy the measured system actually applied.”&lt;/p&gt;
&lt;p&gt;Apple&apos;s Private Cloud Compute is the worked example. PCC nodes attest to the binary they are running, refuse to do work for clients that cannot verify that attestation, and publish every production build for public inspection. The user&apos;s device, not Apple, decides whether a given node is acceptable. That inversion, the relying party verifying the service rather than the service asserting to the relying party, is the part of the pattern that matters. The pieces are not new individually. The combination, at the scale Apple shipped it, proves the pattern is real. The third-party security reviews prove the architecture is serious. Attacks on confidential computing do not refute that point. They prove there is now a boundary worth attacking, measuring, and improving.&lt;/p&gt;
&lt;p&gt;Apple is not the only proof point. &lt;a href=&quot;https://signal.org/blog/private-contact-discovery/&quot;&gt;Signal used SGX remote attestation for private contact discovery in 2017&lt;/a&gt;, with clients verifying that the enclave was running the expected open-source code. &lt;a href=&quot;https://engineering.fb.com/2021/09/10/security/whatsapp-e2ee-backups/&quot;&gt;WhatsApp&apos;s end-to-end encrypted backups use an HSM-based Backup Key Vault&lt;/a&gt; to keep recovery keys out of the ordinary service path, and that design was &lt;a href=&quot;https://www.nccgroup.com/media/fzwdxklh/_ncc_group_whatsapp_e001000m_report_2021-10-27_v12.pdf&quot;&gt;publicly reviewed by NCC Group&lt;/a&gt;. &lt;a href=&quot;https://www.microsoft.com/en-us/research/project/confidential-consortium-framework/&quot;&gt;Microsoft&apos;s Confidential Consortium Framework&lt;/a&gt; powers &lt;a href=&quot;https://learn.microsoft.com/en-us/azure/confidential-ledger/overview&quot;&gt;Azure Confidential Ledger&lt;/a&gt;. Different systems, different threat models, same direction of travel. High-assurance services are moving from institutional assurances toward runtime evidence.&lt;/p&gt;
&lt;h2&gt;What it looks like&lt;/h2&gt;
&lt;p&gt;Concretely, a CA built on the Private Cloud Compute pattern looks like this.&lt;/p&gt;
&lt;p&gt;Issuance is split into two attested components. The first, the registration authority, takes the certificate request, resolves identity from authoritative sources, evaluates the issuance policy, and produces a signed authorization context. The second, the signing oracle, holds the CA private key and produces the signature. Each runs in a separate attested enclave, and each is measured separately. This means policy can evolve without re-measuring the key-custody component, and keys can rotate without re-measuring the policy component.&lt;/p&gt;
&lt;p&gt;The policy layer matters here too. Each component is not just running code, it is making a verifiable policy decision before it acts. The RA decides whether the request is authorized and the identity evidence is sufficient. The signing oracle decides whether the RA, the request, and the authorization context are acceptable before it signs. The evidence does not just say which binary ran. It also says which policy that binary evaluated.&lt;/p&gt;
&lt;p&gt;The two components do not trust each other because they are on the same network. They trust each other through attestation, mutually verified at every connection, and the signing oracle does not merely accept the RA’s conclusion. Before it signs, it independently verifies the RA’s attestation, checks that the authorization context is fresh, confirms that the request is bound to an allowed profile, and verifies that the policy facts asserted by the RA match the evidence presented to the oracle. A compromised RA, even one with its own signing key, does not get to mint an out-of-profile certificate, bypass attestation, or turn the CA key into a general-purpose signing oracle.&lt;/p&gt;
&lt;p&gt;The CA private key is not loaded by the operator. It is held by a custodian, a hardware security module, a cloud KMS, or another enclave, and it is wrapped so that the custodian will release it only to a signing oracle whose attestation matches a published image. The list of acceptable images is small, public, and updated through a documented process. An operator who runs a different binary, however benign the reason, does not get the key. The dragon&apos;s teeth around the data center are still there. They no longer have to do the whole job.&lt;/p&gt;
&lt;p&gt;Both the RA binary and the oracle binary are built from public source and are reproducibly buildable. Anyone can rebuild from the published sources, compare their measurement to the one in the attestation, and confirm that the two match. This is the part of the model that makes trust mean something specific. Not the operator&apos;s word, not the auditor&apos;s snapshot, not the CA&apos;s policy statement, but the build process and the published source. To verify what a particular issuance was actually done by, you would not need to be admitted to the data center. You would need a compiler.&lt;/p&gt;
&lt;p&gt;Each issued certificate is accompanied by a portable evidence bundle, signed by the attested issuance system. The bundle names the binary that produced the signature, the attestation root that vouched for the binary, the RA policy decision, the oracle policy decision, the identity assertion the RA accepted, and the inputs the oracle independently verified before signing. A relying party who trusts the chip vendor&apos;s attestation root can determine for themselves whether the issuance was performed by code on the published list, against the policy on the published list, by an RA that accepted the identity claim it claimed to accept. The CA is not asked to be trusted. The CA is asked to produce evidence.&lt;/p&gt;
&lt;p&gt;None of this removes the HSM, the auditor, or the operator. The HSM is still excellent at the threat it was built for, and a custodian holding a key wrapped to an attestation policy is still doing HSM work under the hood. The auditor is still needed to attest that the published policy is sensible, that the source matches the binary, that the threat model is honest, and that the runbook is followed in the moments where attestation cannot help. The operator is still needed to run the infrastructure and respond when things break.&lt;/p&gt;
&lt;p&gt;What changes is what they are asked to prove.&lt;/p&gt;
&lt;p&gt;Today, a relying party mostly gets institutional assurances. The CA says it followed its policy. The auditor samples evidence and says the controls were operating. The operator says the production system was the one described. Those are useful assurances, but they are indirect. They do not let the relying party inspect the actual path between a request, a policy decision, and a signature.&lt;/p&gt;
&lt;p&gt;A Private Cloud Compute style CA changes that. It turns the issuance path itself into evidence. The question is no longer only whether the CA says it followed the rules. The question becomes which measured binary evaluated this request, which measured binary signed it, which policy digest was used, which identity evidence was accepted, what validation methods were used during issuance, and whether all of that matches the public commitment the CA made.&lt;/p&gt;
&lt;p&gt;When the source is open and reproducibly buildable, that evidence includes a hash of the code that made the decision and signed attestations about the runtime elements that went into that decision. When the code is not open source, third parties can come in and validate the source, the build process, and the correctness of the claims, as Apple did with Private Cloud Compute. The public hashes then let others verify that the code claiming to provide these guarantees is, in fact, the code that ran.&lt;/p&gt;
&lt;p&gt;Open source is not magic, and the point is not faith in &quot;many eyes.&quot; The point is that this shifts the emphasis from betting on physical security and operational practice audits to secure system design and cryptographic evidence about what code actually ran and what it actually did.&lt;/p&gt;
&lt;p&gt;That is the threat model mismatch, and it is not only a CA problem. We built the WebPKI around buildings, cages, ceremonies, HSMs, and audits because those were the tools we had. We did the same thing cryptographically. We built systems around the assumption that factoring large composites and solving discrete logs on elliptic curves were out of reach. Q-day changes that assumption. Runtime compromise changes the operational assumption just as fundamentally.&lt;/p&gt;
&lt;p&gt;We apply the same instincts in any environment we want to call high-assurance. They still matter, but most of the failures we care about are not physical failures. They are logical, remote, operational failures in the runtime path. The rate of change makes that gap wider every year. Annual audits are retrospective, and between them systems change thousands of times, so what the auditor described is rarely what is actually running when a relying party sees a certificate.&lt;/p&gt;
&lt;p&gt;Cryptography turns security problems into key-management problems. AI turns assurance problems into runtime-evidence problems. Once agents are making decisions, calling tools, and changing state, the question is no longer what policy you wrote or what control an auditor sampled. The question is what actually ran, what it saw, what boundary contained it, what policy constrained it, and what evidence survived execution.&lt;/p&gt;
&lt;p&gt;A Private Cloud Compute style CA gives us a way to make that path visible, attestable, and independently verifiable. The same pattern applies wherever the gap between what we say a system does and what it actually does at runtime matters.&lt;/p&gt;
</content:encoded><category>ai</category><category>certificates</category><category>security</category><category>thoughts</category></item><item><title>The First AI-Built Zero-Day Is Not the Interesting Part</title><link>https://unmitigatedrisk.com/2026/05/the-first-ai-built-zero-day-is-not-the-interesting-part/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/05/the-first-ai-built-zero-day-is-not-the-interesting-part/</guid><description>In the mid 90s I worked at a company called Cybersafe. Today it would get labeled an IAM/SSO vendor. What we actually built was a first-generation security platform: Kerberos, password management, PKI-based MFA, key…</description><pubDate>Mon, 11 May 2026 20:23:44 GMT</pubDate><content:encoded>&lt;p&gt;In the mid 90s I worked at a company called Cybersafe. Today it would get labeled an IAM/SSO vendor. What we actually built was a first-generation security platform: Kerberos, password management, PKI-based MFA, key management, host intrusion detection, and what would now be called zero trust access. The company failed for the usual startup reasons. People. Corporate Politics. Timing. The technology was a decade ahead of its market.&lt;/p&gt;
&lt;p&gt;One debate from that period has stayed with me. As we expanded into host intrusion detection, the question of automated response kept surfacing. Could a system safely act on its own to contain an intrusion in progress? Drop a connection. Kill a process. Isolate a host. Nobody on the team could imagine a credible answer. The false positive risk was unbounded. The response itself could be weaponized. The rule sets were not trustworthy enough to delegate authority. We shipped detection and let humans make the call.&lt;/p&gt;
&lt;p&gt;That debate has an answer now, and it is not the one we expected. Automation on the offensive side is not new. Worms, exploit kits, credential stuffing, and phishing infrastructure have been automated for decades. What is new is broad delegated &lt;em&gt;judgment&lt;/em&gt; at machine speed, in the hands of people who do not have to worry about false positives because the blast radius is somebody else&apos;s network.&lt;/p&gt;
&lt;h2&gt;What the report actually shows&lt;/h2&gt;
&lt;p&gt;The interesting question is not whether AI helped produce a zero-day. That was inevitable. The interesting questions are operational. What kinds of systems make bad machine judgment cheap enough to deploy at scale. What kinds of defensive systems are still pretending human review is the control boundary.&lt;/p&gt;
&lt;p&gt;Google Threat Intelligence Group&apos;s &lt;a href=&quot;https://cloud.google.com/blog/topics/threat-intelligence/ai-vulnerability-exploitation-initial-access&quot;&gt;latest AI Threat Tracker report&lt;/a&gt; documents the first zero-day exploit that GTIG says it has high confidence was developed with AI assistance. The headline framing is technically correct. The specifics tell a more interesting story.&lt;/p&gt;
&lt;p&gt;The exploit was a Python script that bypassed 2FA on an open-source web-based system administration tool. It required valid user credentials in the first place. The criminal group planned a mass exploitation campaign, and Google disrupted it through responsible disclosure to the vendor. GTIG identified the artifact as AI-developed because the code carried obvious tells. A hallucinated CVSS score. Textbook Python formatting. Detailed help menus. Educational docstrings characteristic of training data. The artifact still carried the seams of its production.&lt;/p&gt;
&lt;p&gt;This is not the LLM failing at the hard part. The vulnerability itself is a real find. GTIG specifically notes that the 2FA flaw stems from a hardcoded trust assumption, a high-level semantic logic flaw of the kind that fuzzers and static analyzers tend to miss but that frontier LLMs can reason about by reading developer intent. The model did discovery work that previously required a competent human auditor. Where the operation broke down was in weaponization. The attacker shipped an artifact that still looked like a tutorial.&lt;/p&gt;
&lt;p&gt;This is a familiar failure pattern showing up on the offensive side for the first time. Fluency reads as competence. The attacker trusted an artifact with hallucinated metadata and educational comments still attached because it &lt;em&gt;looked&lt;/em&gt; like a real exploit, in the same way over-eager engineering teams hand agents production credentials because the agent &lt;em&gt;sounded&lt;/em&gt; like it knew what it was doing. The criminals here got bitten by the same dynamic that has been producing outages and data loss in vibe-coded production systems for the last eighteen months. The substrate is doing some of the work of inviting the misconfiguration.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://x.com/JohnHultquist/status/2053828380621996411&quot;&gt;Hultquist&apos;s thread on the report&lt;/a&gt; is hedged correctly. The importance is the trajectory, not this specific specimen. Pull the camera back and the rest of the report is more interesting than the lede.&lt;/p&gt;
&lt;h2&gt;Three things worth surfacing&lt;/h2&gt;
&lt;p&gt;&lt;strong&gt;APT45 sending thousands of repetitive prompts.&lt;/strong&gt; The &lt;a href=&quot;https://cloud.google.com/blog/topics/threat-intelligence/apt45-north-korea-digital-military-machine&quot;&gt;North Korean group&lt;/a&gt; has been observed using recursive prompting to analyze CVEs and validate proof-of-concept exploits at scale. That is the industrial-scale answer to LLM variance. Solve the quality problem by amortizing across volume, then have humans cherry-pick the outputs that survived validation. The same statistical strategy that makes modern fuzzing work, applied one layer up the stack. The model does not have to be reliable. The pipeline has to be cheap enough that unreliability does not matter.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;CANFAIL and LONGSTREAM using LLM-generated decoy code.&lt;/strong&gt; A Russia-nexus intrusion cluster has been deploying malware that uses LLM-generated code to conceal malicious functionality. GTIG documented &lt;a href=&quot;https://www.virustotal.com/gui/collection/malware--6cae6e39-72de-5b9e-aebe-47243e3dc63a/iocs&quot;&gt;LONGSTREAM&lt;/a&gt; containing 32 instances of code querying the system&apos;s daylight saving status, repetitive benign-looking activity used to camouflage the malicious core. &lt;a href=&quot;https://www.virustotal.com/gui/collection/malware--30f26e32-0393-5023-92ef-f677f1def61c/iocs&quot;&gt;CANFAIL&lt;/a&gt; carries similar filler logic with LLM-generated comments self-describing the decoy blocks. The stylistic noise of LLM output is becoming the obfuscation layer. The verbose docstrings. The textbook structure. The over-explained variable names. These used to be tells. They are now camouflage. Any heuristic built on the AI-tell will start producing false negatives.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;The &lt;code&gt;wooyun-legacy&lt;/code&gt; skill plugin.&lt;/strong&gt; A specialized GitHub repository is being distributed as a Claude code skill plugin that integrates a distilled knowledge base of over 85,000 real-world vulnerability cases from the Chinese bug bounty platform WooYun (2010 to 2016). This is the supply side of the same market. Skill packs are tooling. Tooling gets distributed. The economic logic for adversarial skill packs is identical to the economic logic for legitimate ones. Any platform hosting them inherits a familiar problem. App stores and package registries have been working through it for two decades. Making trust decisions at distribution scale about code from parties you cannot directly inspect.&lt;/p&gt;
&lt;h2&gt;Both sides are running on the same substrate&lt;/h2&gt;
&lt;p&gt;On the defensive side, Google is using &lt;a href=&quot;https://blog.google/innovation-and-ai/technology/safety-security/cybersecurity-updates-summer-2025/&quot;&gt;Big Sleep&lt;/a&gt; to find vulnerabilities and &lt;a href=&quot;https://deepmind.google/blog/introducing-codemender-an-ai-agent-for-code-security/&quot;&gt;CodeMender&lt;/a&gt; (Gemini-driven) to fix them automatically. The criminals are pulling from a model class indistinguishable from the one Google is running its defensive tooling on. Both sides have access to the same substrate. The differential collapses to data quality, harness sophistication, and discipline around permissions.&lt;/p&gt;
&lt;p&gt;That last one is the part the 90s HIDS conversation did not anticipate. It is also the part that should be the least surprising. The controls discipline did not get easier because the platform got more capable. If anything the gradient got worse. A confused regex IDS in 1999 had a bounded action space. The rule set was enumerable. You could write down what it would do wrong. A confused agent in 2026 has whatever action space its credentials grant it, which in most deployments is more than it should. The fluency that made it easy to give the agent broad permissions in the first place is exactly the property that makes its failures look reasonable in the moment.&lt;/p&gt;
&lt;p&gt;The race Hultquist refers to is real, and it has started. The race is not about model capability. Both sides are running models from the same vendors, often the same model. The race is about who has better-curated data feeding their harnesses. Who has stricter discipline around what their automation can touch. Who has the institutional memory of what happens when you delegate authority to a system whose judgment you cannot audit in advance.&lt;/p&gt;
&lt;p&gt;The HIDS debate from the mid-90s got an answer. It came from the other side of the wire. Not because defenders learned how to trust autonomous judgment, but because attackers learned they did not need to. They could delegate broadly, externalize the blast radius, and let volume compensate for judgment. The defensive answer cannot be more vibes, broader credentials, and better prompts. It has to be the inverse. Narrower authority. Better harnesses. Replayable decisions. And institutional memory about what happens when fluent systems get mistaken for trustworthy ones.&lt;/p&gt;
</content:encoded><category>ai</category><category>technology</category><category>thoughts</category></item><item><title>AI Is Not Why They Are Cutting (Yet)</title><link>https://unmitigatedrisk.com/2026/05/ai-is-not-why-they-are-cutting-yet/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/05/ai-is-not-why-they-are-cutting-yet/</guid><description>Back in 2000, the rule of thumb at Microsoft was that each employee needed to average roughly \$600K in top-line revenue. Inflation adjusted, that is about \$1.1M to \$1.2M today. Microsoft was a high-margin software…</description><pubDate>Fri, 08 May 2026 18:38:35 GMT</pubDate><content:encoded>&lt;p&gt;Back in 2000, the rule of thumb at Microsoft was that each employee needed to average roughly $600K in top-line revenue. Inflation adjusted, that is about $1.1M to $1.2M today. Microsoft was a high-margin software monopoly at peak, so it is not a universal benchmark, but it gives a sense of what disciplined operating leverage looked like even at a company printing money.&lt;/p&gt;
&lt;p&gt;Over the last decade, and especially during the COVID-era zero-rate and QE environment, many companies responded to dysfunction by hiring around it instead of fixing it. Cheap capital reduced the pressure to make hard operating decisions. Necessity is the mother of invention, but cheap money suppressed that necessity for a long time.&lt;/p&gt;
&lt;p&gt;Then two things changed at roughly the same time. Rates went from zero to five, and Section 174 of the tax code stopped letting companies expense software developer salaries in the year incurred. The R&amp;amp;D amortization rule from TCJA kicked in for the 2022 tax year, forcing five-year amortization domestically and fifteen years for work done offshore. At the exact moment capital got expensive, a major software-company cost center became less friendly from a cash-tax and after-tax economics perspective.&lt;/p&gt;
&lt;p&gt;Now AI has added a new pressure. Companies are adopting AI quickly, but we are still early. Much of what is happening inside enterprises is still R&amp;amp;D, experimentation, platform buildout, workflow redesign, and internal tooling. That work is not free. It comes with token costs, infrastructure commitments, GPU capacity, vendor contracts, and a lot of expensive trial and error.&lt;/p&gt;
&lt;p&gt;Jensen Huang has made the point, in characteristically aggressive form, that if he pays someone $500K, he expects them to use a meaningful amount of compute to become more productive. Whether or not you take the specific numbers literally, and you probably should not since Nvidia sells the machines that consume those tokens, the economic point matters. AI spend has to come from somewhere.&lt;/p&gt;
&lt;p&gt;That is the part many layoff narratives miss. Companies are not simply replacing workers with AI. They are also reallocating budget toward AI. Token budgets, model access, inference costs, internal AI platforms, data infrastructure, and R&amp;amp;D commitments are becoming real line items. To fund them, companies are looking at the headcount they accumulated under different interest-rate assumptions, different tax assumptions, and a different view of software demand.&lt;/p&gt;
&lt;p&gt;There is also a demand-side story. COVID pulled years of enterprise software adoption into eighteen months, and a lot of what gets reported as growth now is ARR rotating through M&amp;amp;A rather than new logos landing. In parts of the market, revenue is moving around as much as it is expanding.&lt;/p&gt;
&lt;p&gt;That is the real backdrop for the wave of layoffs. AI is the story being told on earnings calls. The reality is accumulated management debt finally meeting a cost of capital that punishes it. Layers of process. Unclear ownership. Duplicated work. Headcount that grew faster than execution improved. And now, on top of that, companies need to make room for a new class of AI-related spend.&lt;/p&gt;
&lt;p&gt;The pressure also lands hard on old farts like me. We are expensive. And to be honest, some of us (not all) do not want to change how we work or keep up with how the technology is evolving. That makes us easy targets when finance needs to hit a cost number. AI gives the story a forward-looking sheen, but the underlying move is simpler: reduce expensive headcount, flatten layers, correct years of operational laziness, and redirect budget toward the new thing everyone believes they must fund.&lt;/p&gt;
&lt;p&gt;AI is real. The layoff narrative around it usually is not. When you read a layoff announcement blaming AI, you are mostly reading a press release about cost of capital, tax policy, demand pull-forward, AI infrastructure spend, and an org chart that finally got too expensive to defend.&lt;/p&gt;
&lt;p&gt;Read the 10-Qs, not the blog posts.&lt;/p&gt;
</content:encoded><category>thoughts</category></item><item><title>Smaller, Provable, and on Hardware You Own and Operate</title><link>https://unmitigatedrisk.com/2026/05/smaller-provable-and-on-hardware-you-own-and-operate/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/05/smaller-provable-and-on-hardware-you-own-and-operate/</guid><description>Dino Dai Zovi made an argument recently that I want to build on.</description><pubDate>Fri, 08 May 2026 17:49:58 GMT</pubDate><content:encoded>&lt;p&gt;&lt;a href=&quot;https://x.com/dinodaizovi/status/2052379225961709719&quot;&gt;Dino Dai Zovi made an argument&lt;/a&gt; recently that I want to build on.&lt;/p&gt;
&lt;blockquote&gt;
&lt;p&gt;&lt;em&gt;&quot;If you agree that AI will help attackers discover and exploit vulnerabilities 10-100x more easily, then your excess attack surface has also just become 10-100x more of a liability. The right defensive strategy is to prioritize reducing attack surface and trusted computing bases.&quot;&lt;/em&gt;&lt;/p&gt;
&lt;/blockquote&gt;
&lt;p&gt;The argument is right. It is also not new.&lt;/p&gt;
&lt;h2&gt;We have been working on this problem for fifty years&lt;/h2&gt;
&lt;p&gt;Operating system designers gave this set of principles a name in 1975. Saltzer and Schroeder published &lt;a href=&quot;https://www.cs.virginia.edu/~evans/cs551/saltzer/&quot;&gt;&lt;em&gt;The Protection of Information in Computer Systems&lt;/em&gt;&lt;/a&gt; and laid out economy of mechanism, least privilege, separation of privilege, complete mediation, fail-safe defaults, and open design. The Orange Book formalized &quot;trusted computing base&quot; a few years later, with the central observation that the security of a system depends on what is &lt;em&gt;inside&lt;/em&gt; the TCB, and that smaller TCBs are easier to make trustworthy than stronger ones. The microkernel debate that ran from Mach through L4 was an argument about how aggressively to apply these principles to commodity systems. &lt;a href=&quot;https://sel4.systems/&quot;&gt;seL4&lt;/a&gt; went further and produced a formally verified microkernel in 2009, demonstrating that the principles could be pushed all the way to mathematical proof.&lt;/p&gt;
&lt;p&gt;The same ideas show up everywhere once you look. &lt;a href=&quot;https://www.chromium.org/Home/chromium-security/site-isolation/&quot;&gt;Chrome&apos;s site isolation&lt;/a&gt; is privilege separation applied to the browser. OpenBSD &lt;a href=&quot;https://man.openbsd.org/pledge.2&quot;&gt;pledge&lt;/a&gt; and &lt;a href=&quot;https://man.openbsd.org/unveil.2&quot;&gt;unveil&lt;/a&gt; are least privilege applied to userland. Linux namespaces, capabilities, and seccomp are mediation primitives. &lt;a href=&quot;https://www.cl.cam.ac.uk/research/security/ctsrd/cheri/&quot;&gt;CHERI&lt;/a&gt; takes the same intuitions down into the instruction set. GlobalPlatform Security Domains are the smart-card-world version of compartmentalized trust, with separate keysets, separate trust roots, and isolation between issuers, verifiers, and applications on the same chip.&lt;/p&gt;
&lt;p&gt;None of this is new vocabulary. Security domains. Privilege separation. Attack surface reduction. Trusted computing bases. We have known the names of these things for decades, and we have known what to do about them.&lt;/p&gt;
&lt;p&gt;What AI changes is the math, not the principles. Excess privilege has always been a liability. The probability of it mattering on any given day was low enough, and the timescale on which it mattered was long enough, that organizations could carry oversized TCBs and broad blast radii in the backlog as &quot;things we should clean up someday.&quot; AI compresses the timescale and raises the probability. The slack that was tolerable on a five-year cleanup horizon is not tolerable on a six-month one. Dai Zovi&apos;s 10-100x is a multiplier on the cost of carrying slack, not a discovery about whether slack should be carried.&lt;/p&gt;
&lt;h2&gt;The OS tradition assumed you owned the layer below the boundary&lt;/h2&gt;
&lt;p&gt;There is one place where the classical OS framework needs an extension before it covers the world we are actually deploying into.&lt;/p&gt;
&lt;p&gt;The kernel could enforce process isolation because the kernel was below the processes. The hypervisor could enforce VM isolation because the hypervisor was below the VMs. The trust property was &quot;I control the layer below the boundary, so the boundary is meaningful to me.&quot; Every classical OS-level guarantee depends on that.&lt;/p&gt;
&lt;p&gt;Cloud broke that assumption. AI workloads, which run on cloud GPUs and orchestration infrastructure that almost nobody owns, intensify the break. The layer below your workload is operated by someone else. Their hypervisor, their firmware, their physical facility, their scheduling. The classical principles still apply, but their enforcement mechanism is gone.&lt;/p&gt;
&lt;p&gt;Reduction is necessary. Reduction is not sufficient. Once you have shrunk the attack surface and the TCB to something defensible, you still have to prove that the small thing you reduced to is the small thing actually running, and that what it just did is what you said it would do. Without that proof, the small thing is functionally indistinguishable from the large thing. An attacker who replaces your tiny attested signing service with a tiny lookalike has bought themselves all the same access at a lower cost.&lt;/p&gt;
&lt;p&gt;The defensive posture in an AI-leverage world is not just smaller. It is smaller and provable.&lt;/p&gt;
&lt;h2&gt;Law #3 did not go away&lt;/h2&gt;
&lt;p&gt;There is also one law older than the OS-design principles that the cloud security pitch of the last decade has spent a lot of energy pretending to repeal.&lt;/p&gt;
&lt;p&gt;Microsoft&apos;s &lt;a href=&quot;https://learn.microsoft.com/en-us/security/zero-trust/ten-laws-of-security&quot;&gt;Ten Immutable Laws of Security&lt;/a&gt; were published by Scott Culp in 2000. Law #3 is the relevant one here. &lt;em&gt;If a bad actor has unrestricted physical access to your computer, it&apos;s not your computer anymore.&lt;/em&gt; The marketing for confidential computing has, in effect, been an extended argument that hardware-encrypted memory and remote attestation make Law #3 obsolete on cloud infrastructure. They do not, and the research record is clear that they will not.&lt;/p&gt;
&lt;p&gt;Cloud TEEs share microarchitectural resources with the hypervisor and with co-tenants. That is what produces the side-channel catalog. Cloud providers have physical access to every server they operate. That is what produced &lt;a href=&quot;https://tee.fail/&quot;&gt;TEE.Fail&lt;/a&gt;. Hardware roots of trust have a shelf life because they live on the same silicon as everything else, and that silicon is in the operator&apos;s possession. None of these properties are bugs. They are what &quot;running on hardware somebody else owns&quot; means.&lt;/p&gt;
&lt;p&gt;Server-side cloud TEEs are useful for narrow, bounded properties. They are not useful for repealing Law #3 against a determined operator, and they will not meaningfully defeat multi-tenant side channels at the scale at which they are deployed. Selling them as if they would is what produces the gap between marketing and engineering that I have been writing about for the last year in &lt;a href=&quot;https://unmitigatedrisk.com/2026/04/confidential-computings-inconvenient-truth/&quot;&gt;Confidential Computing&apos;s Inconvenient Truth&lt;/a&gt;, &lt;a href=&quot;https://unmitigatedrisk.com/2026/04/confidential-computing-what-it-is-what-it-isnt-and-how-to-think-about-it/&quot;&gt;What Is Confidential Computing, What It Isn&apos;t, and How to Think About It&lt;/a&gt;, and &lt;a href=&quot;https://unmitigatedrisk.com/2025/03/tpms-tees-and-everything-in-between-what-you-actually-need-to-know/&quot;&gt;TPMs, TEEs, and Everything In Between&lt;/a&gt;.&lt;/p&gt;
&lt;p&gt;The criticism in those pieces is specific. It is about the gap between what cloud TEEs are sold as doing (defeating the operator) and what they actually do (making narrow verifiable claims to relying parties about specific operations). The criticism is not that the underlying assurance technology is useless. The technology delivers exactly what it was originally designed to deliver, in the contexts where the original threat model holds. The marketing has been run over those contexts.&lt;/p&gt;
&lt;h2&gt;Where the assurance property actually delivers&lt;/h2&gt;
&lt;p&gt;The assurance property does deliver, where the model fits. The model fits when the hardware is in the &lt;em&gt;user&apos;s&lt;/em&gt; possession, when the device is discrete and tamper-resistant, and when attestation is used to prove &quot;the key in this request lives on this specific device and has never left it&quot; rather than to prove &quot;the operator of the rack cannot read your memory.&quot; That is the threat model the technology was designed for, and it has been working in production for a long time.&lt;/p&gt;
&lt;p&gt;A few examples of the pattern done honestly.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;YubiKey PIV attestation.&lt;/strong&gt; The YubiKey can produce an attestation certificate, signed by Yubico&apos;s manufacturer key, asserting that a private key was generated on this YubiKey, has the slot and policy attributes you expect, and is non-exportable. &lt;a href=&quot;https://docs.yubico.com/yesdk/users-manual/application-piv/attestation.html&quot;&gt;Yubico documents the protocol clearly&lt;/a&gt;. The trust property is sharp because the device is sharp. Discrete silicon, tamper-resistant package, manufacturer chain you can pin against. Law #3 still applies, and it cuts the right way: the user has unrestricted physical access to the YubiKey, and the YubiKey is the user&apos;s computer.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Apple Secure Enclave for SSH agents.&lt;/strong&gt; &lt;a href=&quot;https://github.com/klobucar/paprika&quot;&gt;Paprika&lt;/a&gt; and &lt;a href=&quot;https://secretive.dev/&quot;&gt;Secretive&lt;/a&gt; are SSH agents that store the private key in the Mac&apos;s &lt;a href=&quot;https://support.apple.com/guide/security/secure-enclave-sec59b0b31ff/web&quot;&gt;Secure Enclave Processor&lt;/a&gt;. The application processor never sees the key, and even root on the Mac cannot extract the key material. Root can still cause the key to be used through the legitimate signing API, modulo whatever consent prompts apply, but extraction itself is what the SEP boundary is built to defeat. The user owns the laptop, the key is on a physically separated processor on the same SoC, and the threat model (other applications on the same device, or malware that compromises the application processor) matches what the SEP was built for.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Smart cards and HSMs.&lt;/strong&gt; GlobalPlatform Security Domains, the Yubico PIV applet, hardware-backed PKCS#11 tokens, FIPS 140-3 Level 3 modules. Discrete silicon, tamper-resistant packaging, attestation chains rooted in manufacturer keys. The model that worked in the late 1990s and that still works today, because the threat model has not drifted.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://github.com/PeculiarVentures/attestation&quot;&gt;&lt;code&gt;PeculiarVentures/attestation&lt;/code&gt;&lt;/a&gt; is the verification side of all of this. Parsing, validating, and reasoning about attestation evidence from these various sources. Attestation without a verifier is a claim. Attestation with a verifier is something the relying party can act on.&lt;/p&gt;
&lt;p&gt;The common shape across all of these is that the user owns the hardware, the boundary is physical, and the attestation chain anchors in a manufacturer key whose threat model the user can actually evaluate. Law #3 is honored rather than denied.&lt;/p&gt;
&lt;h2&gt;Transparency is the other cross-machine extension&lt;/h2&gt;
&lt;p&gt;There is a second extension of the classical OS-design tradition that matters for the AI-leverage world, and that composes with attestation in important ways.&lt;/p&gt;
&lt;p&gt;Saltzer and Schroeder&apos;s &lt;em&gt;open design&lt;/em&gt; principle says the security of a system should not depend on the secrecy of its mechanism. The cryptography community has applied this rule to algorithms for decades. The systems community has been slower to apply it to operations. &lt;em&gt;What is the rack actually doing right now?&lt;/em&gt; and &lt;em&gt;what has it done in the past?&lt;/em&gt; are operational questions, and historically the answer was &quot;trust the operator&apos;s audit logs.&quot;&lt;/p&gt;
&lt;p&gt;Transparency logs are the operational extension of open design. The idea is to publish what a system is doing to an append-only public log, with cryptographic proofs that the log cannot be retroactively modified, and to design the relying party to require evidence from the log before trusting any operation. Multiple independent witnesses cosign the log so that no single party can serve different views of reality to different relying parties.&lt;/p&gt;
&lt;p&gt;The pattern is in production at scale. Certificate Transparency requires every WebPKI certificate to be logged publicly before browsers will trust it, which converts CA misissuance from &quot;discovered by accident, sometimes&quot; into &quot;discovered by anyone watching the log.&quot; &lt;a href=&quot;https://www.sigstore.dev/&quot;&gt;Sigstore&lt;/a&gt; applies the same model to software signing, with every signature published to Rekor and consumers able to require log inclusion before accepting a binary. Google DeepMind&apos;s &lt;a href=&quot;https://www.wired.com/2017/03/google-deepminds-untrendy-blockchain-play-make-actually-useful/&quot;&gt;Verifiable Data Audit&lt;/a&gt; was an early attempt to apply the same model to data access in healthcare. The infrastructure is consolidating at &lt;a href=&quot;https://transparency.dev/&quot;&gt;transparency.dev&lt;/a&gt;, and &lt;a href=&quot;https://github.com/C2SP/C2SP&quot;&gt;C2SP&lt;/a&gt; standardizes the interoperability primitives: tlog-tiles, the witness and cosignature protocols, signed-note, and static-ct-api.&lt;/p&gt;
&lt;p&gt;Attestation tells a relying party &quot;this code is running right now.&quot; Transparency tells a relying party &quot;this code has been published, reproduced, and witnessed by parties whose collusion would be visible.&quot; The two compose. &lt;a href=&quot;https://security.apple.com/blog/private-cloud-compute/&quot;&gt;Apple&apos;s Private Cloud Compute&lt;/a&gt; is the most prominent recent example. Every production build is published to a transparency log, user devices will only communicate with nodes whose attested measurement matches the log, and Apple released a virtual research environment so anyone can verify the build claims independently. Google&apos;s &lt;a href=&quot;https://github.com/project-oak/oak&quot;&gt;Project Oak&lt;/a&gt; was an earlier expression of the same combination, building remote attestation against publicly-published binaries as the foundation of trust. The &lt;a href=&quot;https://datatracker.ietf.org/doc/draft-ietf-plants-merkle-tree-certs/&quot;&gt;Merkle Tree Certificates draft&lt;/a&gt;, now a working group document in the IETF&apos;s new PLANTS working group, extends the same logic to TLS at scale, replacing traditional X.509 issuance with batched, transparency-native cert formats designed for the shorter lifetimes the WebPKI is moving toward.&lt;/p&gt;
&lt;p&gt;The relevant property for the AI conversation is that transparency reduces the number of parties you have to trust to one less than would otherwise be required. With attestation alone, you trust the manufacturer of the silicon. With transparency, you trust &lt;em&gt;any&lt;/em&gt; of the witnesses to be honest, plus the manufacturer of the silicon. That asymmetry is what makes transparency the right tool for environments where the operator might be the adversary.&lt;/p&gt;
&lt;h2&gt;What this leaves for server-side TEEs&lt;/h2&gt;
&lt;p&gt;Bounded usefulness, designed honestly.&lt;/p&gt;
&lt;p&gt;Server-side cloud TEEs do not defeat the operator. They produce narrow verifiable claims that a relying party can check against their own trust anchors. &lt;em&gt;This signing service ran this image at this measurement. This certificate was produced by this enclave for this RA. This policy was applied. This key was attested as non-exportable by the HSM that signed.&lt;/em&gt; Each of those is a useful property. None of them is &quot;the operator cannot see your data.&quot; Building an architecture that pretends otherwise is how organizations end up with a single point of failure they did not know they had.&lt;/p&gt;
&lt;p&gt;I have been building &lt;a href=&quot;https://peculiarventures.github.io/goodkey-ca/&quot;&gt;GoodKey CA&lt;/a&gt; as a worked example of the bounded-usefulness pattern. A certificate authority is a useful test case for this kind of architecture, because the trust property is sharp and the threat model is well understood. The shape of the answer is mostly classical OS design pulled across machine boundaries, with hardware-anchored trust at the endpoints and a deliberately bounded intermediary in the middle.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Each enclave is a security domain.&lt;/strong&gt; RA, CA, and HSM are independent compartments. Each has its own measured image, its own keys, and its own attested boundary. Compromising one does not compromise the others. Privilege is separated by design rather than by policy.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;The TCB inside each domain is small enough to characterize.&lt;/strong&gt; Each enclave runs a single-purpose deterministic image. The measurement is one number. The image is reproducible from source. There is no general-purpose runtime to subvert and no orchestration sidecar to gain a foothold from. &lt;a href=&quot;https://aws.amazon.com/ec2/nitro/nitro-enclaves/&quot;&gt;AWS Nitro Enclaves&lt;/a&gt; were the deliberate choice over SGX or TDX. The architecture uses VM-level isolation with dedicated CPU and memory rather than carving enclaves out of shared-cache, shared-core silicon, which reduces a large class of the microarchitectural side-channel exposure that the SGX and TDX families have to grapple with. Dedicated resources, minimal hypervisor, deterministic measurement.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Mediation is complete and inside the boundary.&lt;/strong&gt; Every signing operation goes through the policy evaluator (&lt;a href=&quot;https://www.cedarpolicy.com/&quot;&gt;Cedar&lt;/a&gt;) inside the enclave. Authorization is part of what is attested, not external to it. A compromised RA cannot lie about what policy was applied, because the policy evaluation was inside the measurement.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Trust is not transitive.&lt;/strong&gt; When the RA tells the CA that a client attestation passed, the CA does not believe it. The CA re-runs the verification itself, against its own registered verifier, before signing anything. This is the cross-machine version of &quot;the kernel does not trust userland&apos;s claim that a syscall is authorized.&quot; The CA does the check itself, every time.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Per-operation attestation, not per-boot attestation.&lt;/strong&gt; The CA produces a fresh Nitro attestation for every certificate it signs, with &lt;code&gt;user_data&lt;/code&gt; set to &lt;code&gt;SHA-256(certDER || raKeyFingerprint)&lt;/code&gt;. That binds &lt;em&gt;this specific certificate&lt;/em&gt; to &lt;em&gt;this specific enclave&lt;/em&gt; with &lt;em&gt;this specific RA&lt;/em&gt; on the other end of the conversation. A boot-time attestation tells you the box looked right when it started. A per-operation attestation tells you the box looked right when it did the thing you actually care about.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Hardware-anchored trust at the endpoints.&lt;/strong&gt; The signing keys themselves live in a hardware HSM with discrete-silicon attestation rooted in the &lt;a href=&quot;https://www.marvell.com/products/security-solutions/liquidsecurity2.html&quot;&gt;Marvell&lt;/a&gt; manufacturer chain. The clients prove they hold hardware-protected keys via TPM or device attestation. The Nitro layer in the middle does not have to defeat AWS to be useful, because the actual key material is protected by a different boundary that AWS does not own, and the evidence on the wire is anchored in trust roots the relying party already trusts.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Operations published to a transparency log.&lt;/strong&gt; The CA&apos;s attested measurements, policy versions, and issuance records get logged to an append-only structure with multi-witness cosigning. The operator still chooses what to submit. What the operator does not get is the ability to retract entries after the fact, modify history, or serve a different version of the log to a different relying party without those parties detecting the divergence. A relying party&apos;s confidence that the system has been running honestly over time stops being a function of trust in the operator&apos;s audit logs and starts being a function of properties that hold against the operator. This is the same shape Certificate Transparency gives the WebPKI, applied to the CA&apos;s own operational claims about itself.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Failure modes are bounded by design.&lt;/strong&gt; Certificates are seven days. &lt;a href=&quot;https://www.rfc-editor.org/rfc/rfc9773&quot;&gt;ACME Renewal Information&lt;/a&gt; lets the CA shorten renewal windows targeted at specific machines or specific profiles, and &lt;code&gt;goodenroll&lt;/code&gt; polls for those signals on its own schedule. The fleet rotates without an emergency window and without anyone touching a machine. The exposure window becomes a configuration choice rather than a function of certificate lifetime, and revocation infrastructure stays out of the critical path of the threat model.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Post-quantum where it counts.&lt;/strong&gt; &lt;a href=&quot;https://csrc.nist.gov/pubs/fips/204/final&quot;&gt;ML-DSA-65&lt;/a&gt; (FIPS 204) for certificate signing, &lt;a href=&quot;https://csrc.nist.gov/pubs/fips/203/final&quot;&gt;ML-KEM-768&lt;/a&gt; (FIPS 203) as the subject key for TLS key-exchange certificates. ARI is what makes the migration tractable on the deployed fleet, because you do not have to wait for natural expiry to do the work.&lt;/p&gt;
&lt;p&gt;Nitro is a bounded-trust intermediary. AWS still owns the silicon it runs on. What the architecture buys you is that the property the relying party has to verify is narrow and concrete, and that the actual long-lived secrets are protected by hardware that AWS does not own. Against an AWS-internal threat with full physical access and unbounded effort, Law #3 still applies. Against the attacks the architecture is actually defending against (software compromise of the CA pipeline, a rogue admin pulling secrets through the management plane, a tampered build reaching production), the bounded property is exactly the property you need.&lt;/p&gt;
&lt;h2&gt;The substrate&lt;/h2&gt;
&lt;p&gt;An architecture like this only works if the underlying primitives are right. Three pieces of infrastructure I have been spending time on are upstream of GoodKey CA.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://github.com/PeculiarVentures/scp&quot;&gt;&lt;code&gt;PeculiarVentures/scp&lt;/code&gt;&lt;/a&gt; is GlobalPlatform Security Domain key management in Go. The name is not a coincidence. Smart cards and HSMs have been doing security domains in hardware for two decades, with separate keysets, separate trust roots, and isolation between issuer, verifier, and application code on the same chip. The library implements SCP03 and SCP11 and a typed Security Domain management layer for key lifecycle, certificate provisioning, and trust validation, against verified profiles with byte-exact validation against independent reference implementations. This is the unglamorous work of &quot;make sure the keys you are putting on hardware are actually being put on hardware in the way you think they are.&quot; If the key on the device is not where you think it is, every downstream signature is asserting something false.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://datatracker.ietf.org/doc/draft-ietf-acme-device-attest/&quot;&gt;&lt;code&gt;draft-ietf-acme-device-attest&lt;/code&gt;&lt;/a&gt;, which I am a co-author on, is the cross-machine extension on the client side. It standardizes how a device proves to an ACME server that the key in a certificate request lives in attested hardware on a specific device. The recent revisions resolved several interoperability gaps that had blocked broad implementation, including the Apple-specific &lt;code&gt;attToBeSigned&lt;/code&gt; semantics around &lt;code&gt;sha256(token)&lt;/code&gt; versus &lt;code&gt;sha256(keyAuth)&lt;/code&gt;, an explicit identifier-verification step, the &lt;code&gt;badAttestationStatement&lt;/code&gt; error type, and a hardware-module identifier type. The point of the work is to make the &lt;em&gt;client&lt;/em&gt; side of the trust chain as verifiable as the CA side. An attested signing service that issues credentials to anyone who asks is not solving the problem, it is moving it.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://github.com/PeculiarVentures/attestation&quot;&gt;&lt;code&gt;PeculiarVentures/attestation&lt;/code&gt;&lt;/a&gt; closes the loop. It is the verifier side that consumes attestation evidence from these various sources (TPMs, YubiKeys, Apple devices, Nitro Enclaves) and reduces it to claims a relying party can act on. Without a verifier, attestation is marketing. With a verifier, it is engineering.&lt;/p&gt;
&lt;p&gt;These are not separate efforts. They are what makes hardware-anchored cross-machine trust mean anything in the wild. The transparency-log side of the same problem is being standardized in parallel through &lt;a href=&quot;https://transparency.dev/&quot;&gt;transparency.dev&lt;/a&gt;, &lt;a href=&quot;https://github.com/C2SP/C2SP&quot;&gt;C2SP&lt;/a&gt;, and the &lt;a href=&quot;https://datatracker.ietf.org/doc/draft-ietf-plants-merkle-tree-certs/&quot;&gt;Merkle Tree Certificates draft&lt;/a&gt;, which together extend the same model to issuance auditability at WebPKI scale.&lt;/p&gt;
&lt;h2&gt;What this asks builders to do&lt;/h2&gt;
&lt;p&gt;The Dai Zovi prescription is operating-systems hygiene applied to the whole stack. The verifiability corollary is the same hygiene extended across machines you do not own. Both are old. AI is what is making them mandatory.&lt;/p&gt;
&lt;p&gt;Pick small. Compartmentalize. Strip privilege to what each component genuinely needs. Make each component&apos;s TCB small enough that one person can characterize it in a sitting. Single-purpose services, deterministic builds, dedicated resources rather than shared microarchitectural state, single-image enclaves rather than orchestrated runtimes.&lt;/p&gt;
&lt;p&gt;Make it provable across machines. Per-operation attestation rather than per-boot. Independent re-verification at every hop, not transitive trust. Authorization decisions inside the attested boundary. Evidence bundles the relying party can run a verifier against, with their own trust anchors. Short lifetimes with active rotation rather than long-lived credentials backstopped by revocation. And publish the operations themselves to a transparency log with independent witnesses, so the proofs survive disagreement about who saw what when, and so a single dishonest operator cannot serve different versions of reality to different relying parties.&lt;/p&gt;
&lt;p&gt;Anchor trust in hardware whose threat model you can actually evaluate. Where you can put the long-lived secret on hardware the user owns, do that. YubiKey, Apple Secure Enclave, TPM in the laptop on the engineer&apos;s desk, smart card in the operator&apos;s pocket. Where you cannot, use a cloud TEE as a bounded-trust intermediary that produces narrow verifiable claims, and design the architecture so the long-lived material lives in a different boundary that the cloud operator does not own.&lt;/p&gt;
&lt;p&gt;And know what your assurance is buying you. Cloud TEEs are not how you defeat the operator. They are how you make narrow operations verifiable to relying parties while accepting that absolute properties against the operator are not on offer. The places where attestation delivers what it advertises are the places where the user owns the silicon. Law #3 has not been repealed, and AI has only raised the cost of pretending otherwise.&lt;/p&gt;
&lt;p&gt;Smaller is the easy half. Provable is most of the engineering. On hardware you own is where the property actually holds.&lt;/p&gt;
</content:encoded><category>ai</category><category>security</category><category>thoughts</category></item><item><title>The Illusion of Constant Acceleration</title><link>https://unmitigatedrisk.com/2026/04/the-illusion-of-constant-acceleration/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/04/the-illusion-of-constant-acceleration/</guid><description>Spend enough time around AI right now and you start to get the feeling that everything is speeding up, all the time.</description><pubDate>Mon, 06 Apr 2026 03:37:35 GMT</pubDate><content:encoded>&lt;p&gt;Spend enough time around AI right now and you start to get the feeling that everything is speeding up, all the time.&lt;/p&gt;
&lt;p&gt;Every week there is a new model, a new capability, a new claim that some industry is about to be remade. It starts to feel like rapid change is just the new baseline. Like history has bent into a permanently steeper slope.&lt;/p&gt;
&lt;p&gt;I do not think that is right.&lt;/p&gt;
&lt;p&gt;What I think is closer to the truth is that we have gotten used to confusing motion with progress, and delay with inevitability. Some things are moving very quickly. Others are barely moving at all. We treat the former as inevitable and the latter as unavoidable.&lt;/p&gt;
&lt;p&gt;Neither is true.&lt;/p&gt;
&lt;p&gt;My father was born in 1942. That is not ancient history. When he was born, there was still a lot of basic infrastructure left to build.&lt;/p&gt;
&lt;p&gt;Within a little more than a decade, nonstop transcontinental passenger air service became viable. Less than eight years after that, a human entered space. Eight years later, people were walking on the Moon.&lt;/p&gt;
&lt;p&gt;That is a staggering amount of change in a very short period of time.&lt;/p&gt;
&lt;p&gt;In one person’s early life, we went from making coast-to-coast air travel practical to landing human beings on another celestial body. Not as a thought experiment. Not as a roadmap. We just did it.&lt;/p&gt;
&lt;p&gt;And it was not only aerospace. The Golden Gate Bridge was built in about four years. The first transcontinental railroad was completed in about six. These were massive physical undertakings that reshaped how people moved and how economies functioned, delivered on timelines that would feel almost implausible now.&lt;/p&gt;
&lt;p&gt;The easy way to dismiss this is to say that software is fast and physical infrastructure is slow. That if AI looks fast and transit looks slow, that is just how the world works.&lt;/p&gt;
&lt;p&gt;But that does not really hold up.&lt;/p&gt;
&lt;p&gt;Ukraine did not build its drone ecosystem on leisurely timelines. Tesla compressed what many assumed would be a slow industrial transition into something the rest of the auto industry had to react to. When something actually matters, physical systems move. Supply chains get reorganized. Tradeoffs get made. Bureaucracies get bent. Talent concentrates. People stop explaining why something is hard and start figuring out how to get it done.&lt;/p&gt;
&lt;p&gt;That is part of what makes Artemis interesting.&lt;/p&gt;
&lt;p&gt;This is not a criticism of Artemis. It is an ambitious and serious effort. But it is also a reminder that progress is not self-sustaining. Apollo is often remembered as a triumph of technology, but it was just as much a triumph of focus, alignment, and urgency. Artemis reminds us that those things matter just as much as the rockets do.&lt;/p&gt;
&lt;p&gt;There is another force that shows up in systems like this.&lt;/p&gt;
&lt;p&gt;At Google, there was a name for it: slime mold.&lt;/p&gt;
&lt;p&gt;It is what happens when layers of process, approvals, coordination costs, and local incentives build up over time until forward motion gets harder even when nobody involved is being unreasonable. Everything makes sense on its own. The system just moves more slowly.&lt;/p&gt;
&lt;p&gt;Technology policy has its own versions of slime mold.&lt;/p&gt;
&lt;p&gt;We saw it in the crypto wars, when policymakers convinced themselves that math could be slowed down with policy, as if cryptographic reality were open to negotiation. It was not. What that produced was not real control. It produced friction, workarounds, and the illusion of governance.&lt;/p&gt;
&lt;p&gt;You can see the same instinct showing up again in parts of the conversation around AI. When institutions feel outpaced, they respond with process. That instinct is understandable, but it rarely solves the problem. You do not make systems safer by pretending inevitabilities are optional. You make them safer by building the infrastructure, incentives, and accountability needed to deal with what is actually happening.&lt;/p&gt;
&lt;p&gt;But that is not how we tend to think about progress.&lt;/p&gt;
&lt;p&gt;We talk about technological achievement as if it were mostly about invention, as if once something has been demonstrated it remains latent in society, ready to be called back into service whenever we need it.&lt;/p&gt;
&lt;p&gt;That is not how any of this works.&lt;/p&gt;
&lt;p&gt;The ability to do ambitious things quickly depends on organizational memory, industrial capacity, political alignment, tolerance for risk, and a culture that still expects big things to happen on human timescales.&lt;/p&gt;
&lt;p&gt;Lose enough of that, and even getting back to where you once were becomes hard.&lt;/p&gt;
&lt;p&gt;You can see it in infrastructure. Projects that once would have been treated as urgent now take decades, often in fragments so small that earlier generations would have treated them as preliminary milestones. Over time, that changes expectations. Slowness starts to look like responsibility. Ambition starts to sound naive.&lt;/p&gt;
&lt;p&gt;That is the trap.&lt;/p&gt;
&lt;p&gt;The problem is not just that progress slows. It is that people get used to it. What would once have looked like drift starts to look like process. What would once have sounded like an excuse starts to sound like maturity.&lt;/p&gt;
&lt;p&gt;Meanwhile, in domains where urgency and incentives line up, things still move very quickly. ChatGPT was released publicly in late 2022. In a few years, AI went from something most people associated with research labs to something embedded in everyday workflows, products, and policy debates.&lt;/p&gt;
&lt;p&gt;AI did not prove that everything is accelerating.&lt;/p&gt;
&lt;p&gt;It proved that when enough capability, capital, and attention line up, rapid change is still possible.&lt;/p&gt;
&lt;p&gt;That is the point.&lt;/p&gt;
&lt;p&gt;The world is not uniformly speeding up. Some parts of it are. Others are not. And the difference has less to do with atoms versus bits than with whether we have decided something actually matters.&lt;/p&gt;
&lt;p&gt;That ought to make us a little less complacent.&lt;/p&gt;
&lt;p&gt;People like to tell themselves that once a technology is important enough, the rest somehow sorts itself out. The problems get solved. The risks get managed. The surrounding systems catch up.&lt;/p&gt;
&lt;p&gt;History does not really support that.&lt;/p&gt;
&lt;p&gt;Things were only all right in the past because people worked very hard to make them all right. The systems that made aviation safe, that made infrastructure dependable, that made computing usable in high-trust environments, none of that appeared on its own.&lt;/p&gt;
&lt;p&gt;The same will be true here.&lt;/p&gt;
&lt;p&gt;If we want AI to be safe, trustworthy, and broadly useful, that will not happen as a side effect of capability gains. Security will not emerge on its own. Governance will not emerge on its own. The infrastructure needed to make these systems worthy of dependence will not emerge on its own.&lt;/p&gt;
&lt;p&gt;Those things only happen when people decide they matter.&lt;/p&gt;
&lt;p&gt;That is the real problem with the idea that everything is accelerating. It makes it easy to believe that progress takes care of itself.&lt;/p&gt;
&lt;p&gt;It does not.&lt;/p&gt;
&lt;p&gt;Progress happens when people decide it needs to, and then do the work.&lt;/p&gt;
</content:encoded><category>ai</category><category>technology</category><category>thoughts</category></item><item><title>Confidential Computing&apos;s Inconvenient Truth</title><link>https://unmitigatedrisk.com/2026/04/confidential-computings-inconvenient-truth/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/04/confidential-computings-inconvenient-truth/</guid><description>This is part of a series on confidential computing. See also: Confidential Computing: What It Is, What It Isn&apos;t, and How to Think About It for practical deployment guidance, and Why Nobody Can Verify What Booted Your…</description><pubDate>Fri, 03 Apr 2026 19:35:42 GMT</pubDate><content:encoded>&lt;p&gt;&lt;em&gt;This is part of a series on confidential computing. See also: &lt;a href=&quot;https://unmitigatedrisk.com/2026/04/confidential-computing-what-it-is-what-it-isnt-and-how-to-think-about-it/&quot;&gt;Confidential Computing: What It Is, What It Isn&apos;t, and How to Think About It&lt;/a&gt; for practical deployment guidance, and &lt;a href=&quot;https://unmitigatedrisk.com/2026/04/why-nobody-can-verify-what-booted-your-server/&quot;&gt;Why Nobody Can Verify What Booted Your Server&lt;/a&gt; for the attestation infrastructure gap. Two companion reference documents provide the evidence base: the &lt;a href=&quot;https://docs.google.com/document/d/1vlkwCJPEFyC2vIt9PgTkf-SuUvsELaFDH50GcTdd-bA/&quot;&gt;TEE Vulnerability Taxonomy&lt;/a&gt; and TPM Attestation and PCR Verification: The Infrastructure Gap.&lt;/em&gt;&lt;/p&gt;
&lt;p&gt;Confidential computing has a vulnerability record that grows every year, an attestation infrastructure that does not work at scale, and a hardware root of trust with a demonstrated shelf life. This piece explains why.&lt;/p&gt;
&lt;p&gt;I want to be clear about where I stand before cataloging problems. I believe in this technology. What Signal has done with &lt;a href=&quot;https://signal.org/blog/private-contact-discovery/&quot;&gt;Private Contact Discovery&lt;/a&gt; and &lt;a href=&quot;https://signal.org/blog/sealed-sender/&quot;&gt;Sealed Sender&lt;/a&gt; using SGX enclaves, building systems where even Signal&apos;s own servers cannot see who is contacting whom, is exactly the kind of architecture that confidential computing makes possible. Apple&apos;s &lt;a href=&quot;https://security.apple.com/blog/private-cloud-compute/&quot;&gt;Private Cloud Compute&lt;/a&gt; takes the model further. Every production build is published to a transparency log, user devices will only communicate with nodes whose attested measurements match the log, and Apple released a virtual research environment so anyone can verify the claims independently. Moxie Marlinspike&apos;s &lt;a href=&quot;https://techcrunch.com/2026/01/18/moxie-marlinspike-has-a-privacy-conscious-alternative-to-chatgpt/&quot;&gt;Confer&lt;/a&gt; applies the same idea to AI inference, with all processing inside a TEE and remote attestation so the service provider never has access to your conversations. These are real systems delivering real privacy guarantees that would be hard to achieve any other way.&lt;/p&gt;
&lt;p&gt;More broadly, TEEs make systems more verifiable. Instead of asking users to take on faith that a service handles their data correctly, the service can prove it through attestation. I wrote earlier about &lt;a href=&quot;https://unmitigatedrisk.com/2025/01/why-its-time-to-rethink-machine-and-workload-identity-lessons-from-user-security/#:~:text=Attestation%3A%20The%20MFA%20for%20Machines%20and%20Workloads&quot;&gt;attestation as the MFA for machines and workloads&lt;/a&gt;, and I explored the same idea in 2022 in the context of &lt;a href=&quot;https://unmitigatedrisk.com/2022/08/what-would-it-look-like-to-go-back-to-first-principles-when-it-comes-to-root-store-management-in-2022/&quot;&gt;certificate authorities&lt;/a&gt;. If the CA runs open-source software on attesting hardware with reproducible builds, you can verify its behavior rather than trusting an annual audit. That shift, from asserted trust to verifiable trust, is genuinely important, and confidential computing is what makes it possible.&lt;/p&gt;
&lt;p&gt;But &quot;the direction is right&quot; is not the same as &quot;the current state is adequate.&quot; We should not make perfection the enemy of good. This technology delivers real value today. But we also cannot afford to mistake the current state for the desired end state. Getting to where this technology needs to be requires seeing clearly where it actually is. That is what this piece is about.&lt;/p&gt;
&lt;p&gt;The answer is not &quot;the implementations are buggy.&quot; The answer is structural. These technologies were designed for threat models that do not match how they are being deployed. Smart cards and HSMs were physically discrete devices with clear trust boundaries. TPMs were designed for boot integrity on enterprise desktops. Intel SGX was designed for desktop DRM. Each was repurposed for the cloud because the technology existed and the market needed something now. The repurposing created systematic security gaps that the research community has spent a decade documenting and the market has spent a decade deploying through.&lt;/p&gt;
&lt;p&gt;In March 2025, I published a &lt;a href=&quot;https://unmitigatedrisk.com/2025/03/tpms-tees-and-everything-in-between-what-you-actually-need-to-know/&quot;&gt;technical reference on security hardware&lt;/a&gt; and an &lt;a href=&quot;https://docs.google.com/document/d/1dhCRIks4kjounzuPAEtllBtxCtJGa4adAZ0ok8DNigs/&quot;&gt;in-depth companion document&lt;/a&gt; that categorized how these technologies fail. One of those failure categories was &quot;Misuse Issues&quot;: vulnerabilities that occur when security technology is adopted beyond its original design. A year later, with TDXRay reconstructing LLM prompts from inside encrypted VMs, TEE.Fail extracting attestation keys with a $1,000 device, and the SGX Global Wrapping Key extracted from hardware fuses, that observation warrants a much fuller treatment.&lt;/p&gt;
&lt;h2&gt;Timeline&lt;/h2&gt;
&lt;table&gt;
&lt;thead&gt;
&lt;tr&gt;
&lt;th&gt;Year&lt;/th&gt;
&lt;th&gt;Event&lt;/th&gt;
&lt;th&gt;Category&lt;/th&gt;
&lt;/tr&gt;
&lt;/thead&gt;
&lt;tbody&gt;
&lt;tr&gt;
&lt;td&gt;1968&lt;/td&gt;
&lt;td&gt;Smart card patents (Dethloff, Moreno). Special-purpose computers in tamper-resistant packages. The original TEE.&lt;/td&gt;
&lt;td&gt;Hardware TEE&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;1980s&lt;/td&gt;
&lt;td&gt;IBM secure coprocessors for banking. US government funds kernelized secure OS research.&lt;/td&gt;
&lt;td&gt;Hardware TEE&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;1996&lt;/td&gt;
&lt;td&gt;nCipher founded. nShield HSMs with CodeSafe: custom application code inside tamper-resistant hardware.&lt;/td&gt;
&lt;td&gt;Hardware TEE&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;1998&lt;/td&gt;
&lt;td&gt;IBM 4758 commercially available. Arbitrary code execution inside tamper-responding enclosure. FIPS 140-1 Level 4.&lt;/td&gt;
&lt;td&gt;Hardware TEE&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2003&lt;/td&gt;
&lt;td&gt;TCG founded, TPM standardized. Designed for boot integrity from ring -x. Hardware root of trust, measurement chains, attestation concepts established.&lt;/td&gt;
&lt;td&gt;Institutional&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2006&lt;/td&gt;
&lt;td&gt;AWS launches EC2. Public cloud computing begins. Workloads move to shared infrastructure owned by someone else.&lt;/td&gt;
&lt;td&gt;Cloud&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2006&lt;/td&gt;
&lt;td&gt;BitLocker ships with TPM support. TPMs reach millions of enterprise devices. Reference value infrastructure never materializes.&lt;/td&gt;
&lt;td&gt;Hardware TEE&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2008-2010&lt;/td&gt;
&lt;td&gt;Cloud goes mainstream. Azure (2010), GCP (2008), OpenStack (2010). Multi-tenant shared infrastructure becomes the default enterprise compute model.&lt;/td&gt;
&lt;td&gt;Cloud&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2012&lt;/td&gt;
&lt;td&gt;AlexNet wins ImageNet. Deep learning proven at scale on GPUs. AI workloads begin moving to cloud GPU infrastructure.&lt;/td&gt;
&lt;td&gt;AI&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2013&lt;/td&gt;
&lt;td&gt;Apple Secure Enclave Processor (iPhone 5s). Physically separate processor on SoC. First mass-market TEE. Invisible to users.&lt;/td&gt;
&lt;td&gt;Hardware TEE&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2015&lt;/td&gt;
&lt;td&gt;Intel SGX (Skylake). Enclaves inside the CPU. Designed for desktop DRM: single-tenant threat model. Cloud providers begin evaluating for multi-tenant use.&lt;/td&gt;
&lt;td&gt;CPU TEE&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2016&lt;/td&gt;
&lt;td&gt;AMD SEV. VM-level memory encryption. First CPU TEE designed with virtualization in mind.&lt;/td&gt;
&lt;td&gt;CPU TEE&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2017&lt;/td&gt;
&lt;td&gt;Transformer architecture published (&quot;Attention Is All You Need&quot;). Foundation for the model scale that will drive confidential computing demand.&lt;/td&gt;
&lt;td&gt;AI&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2017&lt;/td&gt;
&lt;td&gt;First SGX side-channel attacks. Cache-timing, Spectre adaptation. Desktop design meets multi-tenant reality.&lt;/td&gt;
&lt;td&gt;Vulnerability&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2018&lt;/td&gt;
&lt;td&gt;Foreshadow (L1TF) reads arbitrary SGX memory. SEVered remaps SEV guest pages. Desktop-to-cloud threat model gap exploited.&lt;/td&gt;
&lt;td&gt;Vulnerability&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2019&lt;/td&gt;
&lt;td&gt;Confidential Computing Consortium founded (Google, Microsoft, IBM, Intel, Linux Foundation). Repurposing becomes official strategy.&lt;/td&gt;
&lt;td&gt;Institutional&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2019&lt;/td&gt;
&lt;td&gt;Plundervolt, ZombieLoad, RIDL. Three distinct attack classes against SGX in one year.&lt;/td&gt;
&lt;td&gt;Vulnerability&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2020&lt;/td&gt;
&lt;td&gt;GPT-3 (175B parameters). Model weights become billion-dollar assets. Protecting weights on shared infrastructure becomes a business requirement.&lt;/td&gt;
&lt;td&gt;AI&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2020&lt;/td&gt;
&lt;td&gt;AWS Nitro Enclaves. Purpose-built for cloud, not repurposed from desktop. The exception to the pattern.&lt;/td&gt;
&lt;td&gt;Cloud&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2020&lt;/td&gt;
&lt;td&gt;AMD SEV-SNP, Intel TDX announced. VM-level TEEs designed for cloud but still sharing microarchitectural resources. Azure/GCP ship confidential VMs with vTPMs.&lt;/td&gt;
&lt;td&gt;Cloud&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2021&lt;/td&gt;
&lt;td&gt;Intel deprecates SGX on consumer CPUs (11th/12th gen Core). Desktop DRM cannot sustain the technology alone.&lt;/td&gt;
&lt;td&gt;CPU TEE&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2022&lt;/td&gt;
&lt;td&gt;ChatGPT launches (Nov). AI goes mainstream. Every enterprise begins evaluating LLM deployment on cloud infrastructure.&lt;/td&gt;
&lt;td&gt;AI&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2022&lt;/td&gt;
&lt;td&gt;ÆPIC Leak, SGX.Fail. Vulnerable platforms remain in TRUSTED attestation state months after disclosure.&lt;/td&gt;
&lt;td&gt;Vulnerability&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2023&lt;/td&gt;
&lt;td&gt;GPT-4, Llama 2, Claude 2. Foundation model race accelerates. EU AI Act passed.&lt;/td&gt;
&lt;td&gt;AI&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2023&lt;/td&gt;
&lt;td&gt;Downfall (SGX), CacheWarp (SEV-SNP). CacheWarp is first software-based attack defeating SEV-SNP integrity. NVIDIA H100 confidential GPU ships.&lt;/td&gt;
&lt;td&gt;Vulnerability&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2024&lt;/td&gt;
&lt;td&gt;Confidential AI goes mainstream. Azure, GCP, AWS all position confidential computing for AI. TDXdown and Heckler attacks hit TDX. HyperTheft extracts model weights via ciphertext side channels.&lt;/td&gt;
&lt;td&gt;AI / Vulnerability&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2025 Feb&lt;/td&gt;
&lt;td&gt;Google finds insecure hash in AMD microcode signature validation (&lt;a href=&quot;https://www.amd.com/en/resources/product-security/bulletin/amd-sb-3019.html&quot;&gt;CVE-2024-56161&lt;/a&gt;). Malicious microcode loadable under SEV-SNP.&lt;/td&gt;
&lt;td&gt;Vulnerability&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2025 May&lt;/td&gt;
&lt;td&gt;Google announces confidential GKE nodes with NVIDIA H100 GPUs. Confidential AI training and inference on GPU clusters.&lt;/td&gt;
&lt;td&gt;AI&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2025 Oct&lt;/td&gt;
&lt;td&gt;TEE.Fail. $1K DDR5 bus interposer extracts attestation keys from Intel TDX and AMD SEV-SNP. Attestation forgery demonstrated.&lt;/td&gt;
&lt;td&gt;Vulnerability&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2025 Dec&lt;/td&gt;
&lt;td&gt;IDC survey: 75% of organizations adopting confidential computing, 84% cite attestation validation as top challenge. Gartner predicts 75% of untrusted-infra processing uses CC by 2029.&lt;/td&gt;
&lt;td&gt;Institutional&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2025 Dec&lt;/td&gt;
&lt;td&gt;IETF RATS CoRIM reaches draft-09. Reference value format standards mature. Vendor adoption of publishing measurements remains minimal.&lt;/td&gt;
&lt;td&gt;Institutional&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2026 Jan&lt;/td&gt;
&lt;td&gt;StackWarp (CVE-2025-29943). Stack Engine synchronization bug enables deterministic stack pointer manipulation inside SEV-SNP guest via MSR toggling. Affects AMD Zen 1 through Zen 5. USENIX Security 2026.&lt;/td&gt;
&lt;td&gt;Vulnerability&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2026&lt;/td&gt;
&lt;td&gt;TDXRay (IEEE S&amp;amp;P 2026). Reconstructs LLM user prompts word-for-word from encrypted TDX VMs by monitoring tokenizer cache access patterns. No crypto broken. UC San Diego, CISPA, Google.&lt;/td&gt;
&lt;td&gt;AI / Vulnerability&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2026 Mar&lt;/td&gt;
&lt;td&gt;NVIDIA publishes zero-trust AI factory reference architecture. CPU TEE + confidential GPU + CoCo + KBS. Model weights encrypted until attestation passes.&lt;/td&gt;
&lt;td&gt;AI&lt;/td&gt;
&lt;/tr&gt;
&lt;tr&gt;
&lt;td&gt;2026 Mar 31&lt;/td&gt;
&lt;td&gt;Ermolov extracts SGX Global Wrapping Key from Intel Gemini Lake. Root key extraction via arbitrary microcode. Unpatchable (hardware fuses).&lt;/td&gt;
&lt;td&gt;Vulnerability&lt;/td&gt;
&lt;/tr&gt;
&lt;/tbody&gt;
&lt;/table&gt;
&lt;h2&gt;Trusted Platform Modules: Boot Integrity and System State&lt;/h2&gt;
&lt;p&gt;The idea that hardware should measure and attest to software integrity goes back to the late 1990s. The Trusted Computing Group, formed in 2003, standardized the Trusted Platform Module, a discrete chip that stores cryptographic keys and maintains Platform Configuration Registers recording the boot chain as a sequence of hash measurements.&lt;/p&gt;
&lt;p&gt;The TPM was designed to solve a specific problem: bootloader-level attacks. Rootkits and bootkits that compromised the system before the OS loaded were invisible to any software-based security tool. The TPM sat below the OS, measuring each boot stage before execution. It could answer a question that no operating system could answer about itself: did this machine boot the software it was supposed to boot?&lt;/p&gt;
&lt;p&gt;Each boot stage measures the next before handing off execution. The measurements are extended into PCRs using a one-way hash chain: &lt;code&gt;PCR_new = Hash(PCR_old || measurement)&lt;/code&gt;. The TPM can produce a signed quote of its PCR values, and a remote verifier can check whether the system booted the expected software stack.&lt;/p&gt;
&lt;p&gt;TPMs shipped in millions of enterprise laptops and servers. BitLocker used TPM-sealed keys for disk encryption. Linux distributions added measured boot support. But TPMs never achieved the broad security impact their designers envisioned. The problem was practical: to verify a TPM quote, you need to know what the correct PCR values should be, and &lt;a href=&quot;https://unmitigatedrisk.com/2026/04/why-nobody-can-verify-what-booted-your-server/&quot;&gt;nobody built the infrastructure to distribute and maintain those reference values at scale&lt;/a&gt;.&lt;/p&gt;
&lt;p&gt;The TPM could tell you what booted. It could not tell you whether what booted was good.&lt;/p&gt;
&lt;p&gt;What TPMs did accomplish was laying the conceptual groundwork for everything that followed. Hardware root of trust, measurement chains, remote attestation, platform state quotes. All of this vocabulary originated in the TPM ecosystem. Modern CPU TEEs inherited these concepts even as their architectures diverged significantly from the TPM model.&lt;/p&gt;
&lt;h2&gt;Hardware-Isolated Execution: Older Than You Think&lt;/h2&gt;
&lt;p&gt;Running code inside a tamper-resistant hardware boundary did not start with Intel or Apple. It started with smart cards.&lt;/p&gt;
&lt;p&gt;Smart cards emerged in the late 1960s as special-purpose computers embedded in plastic cards. By the 1980s, they were executing cryptographic operations in banking, telecommunications, and government ID. A smart card is a tiny computer with its own processor, memory, and operating system, running inside a tamper-resistant package. That is a trusted execution environment by any reasonable definition, even if nobody called it that at the time.&lt;/p&gt;
&lt;p&gt;HSMs extended the same concept to server-class computing. IBM&apos;s 4758, commercially available in the late 1990s, provided a tamper-responding enclosure with its own processor, battery-backed memory, and secure boot chain. If someone tried to open the case, drill through it, or expose it to extreme temperatures, the device would zeroize its keys. The 4758 ran arbitrary code inside the boundary.&lt;/p&gt;
&lt;p&gt;nCipher (founded 1996, later acquired by Thales) took this further with CodeSafe on the nShield HSM line, a development framework for deploying custom applications inside the HSM. This was general-purpose computation inside a hardware trust boundary, exactly the model that SGX would later attempt to replicate in silicon without a separate physical device. I spent years working with these HSMs. They ran custom signing logic, policy engines, tokenization routines, and key derivation functions, all inside the tamper-resistant module where the host OS could not observe or interfere.&lt;/p&gt;
&lt;p&gt;The difference between these earlier systems and modern confidential computing is not the concept. It is the integration point. Smart cards and HSMs are discrete devices with well-defined physical boundaries. You can see the trust boundary. You can hold it in your hand. SGX, TDX, and SEV moved the trust boundary inside the CPU itself, eliminating the separate device but also eliminating the physical clarity. When the trust boundary is a set of microarchitectural state bits inside a processor with billions of transistors and a microcode layer updated quarterly, the attack surface becomes much larger.&lt;/p&gt;
&lt;p&gt;Apple&apos;s Secure Enclave Processor, introduced with the iPhone 5s in 2013, sat between these two models. It was a physically separate processor on the SoC with its own encrypted memory, dedicated to protecting biometric data and cryptographic keys. Even a fully compromised application processor with root privileges could not reach the Secure Enclave&apos;s memory.&lt;/p&gt;
&lt;p&gt;The SEP succeeded where HSMs had stayed confined to data centers for two reasons. It was invisible to users. Nobody configured it or provisioned it. And it protected something users cared about: their fingerprints and their money. The security was a means to a consumer feature, not a product in itself.&lt;/p&gt;
&lt;h2&gt;Intel SGX: Designed for the Desktop&lt;/h2&gt;
&lt;p&gt;Intel SGX, introduced with Skylake processors in 2015, brought the enclave concept to general-purpose computing. Instead of a separate processor, SGX created isolated memory regions within the main CPU. Code and data inside an enclave are encrypted in memory and protected from all other software on the system. The enclave&apos;s measurement (MRENCLAVE) is a hash of exactly what was loaded, making attestation straightforward. One binary, one deterministic hash.&lt;/p&gt;
&lt;p&gt;SGX was designed for the desktop. Its primary use cases were single-tenant scenarios like content protection, DRM key management, and Ultra HD Blu-ray playback. The threat model is clear. One machine, one user, and the enclave protects the content owner&apos;s code from that user.&lt;/p&gt;
&lt;p&gt;This is a single-tenant threat model. The attacker is the machine owner. There is no hypervisor. There are no co-tenant workloads competing for shared microarchitectural resources. The side-channel attack surface exists, but the economic incentive is limited. The attacker gains access to one DRM key or one media stream.&lt;/p&gt;
&lt;p&gt;Enterprise adoption beyond DRM was limited. SGX enclaves had severe memory constraints (initially 128MB). Programming for SGX required partitioning applications into trusted and untrusted components. Intel deprecated SGX from consumer processors in 2021. The desktop DRM use case was not enough to sustain the technology.&lt;/p&gt;
&lt;h2&gt;Cloud Adoption and the Threat Model Mismatch&lt;/h2&gt;
&lt;p&gt;The cloud introduced a fundamentally different threat model, and this is where the problems began.&lt;/p&gt;
&lt;p&gt;In the desktop DRM model, you protect your code from one user on one machine. In the cloud, you protect your code and data from the infrastructure provider, co-tenant workloads, the hypervisor, firmware, and anyone with physical access to a shared data center. The provider controls the hardware, the hypervisor, the firmware, the physical facility, and the scheduling of workloads across shared CPU cores.&lt;/p&gt;
&lt;p&gt;The industry took technologies designed for the desktop single-tenant model and applied them to this multi-tenant cloud model. The architectural mismatch opened attack surfaces that the original designs did not anticipate.&lt;/p&gt;
&lt;p&gt;SGX on a desktop shares caches, branch predictors, execution ports, and power delivery with the enclave owner&apos;s own code. On a cloud server, those same resources are shared with co-tenant workloads controlled by different parties, each potentially adversarial. Cache-timing attacks that were theoretical on a desktop became practical in the cloud because the attacker could run arbitrary code on the same physical core. The side-channel catalog that accumulated against SGX from 2017 onward was not a series of implementation bugs. It was a consequence of deploying a single-tenant design in a multi-tenant environment.&lt;/p&gt;
&lt;p&gt;AMD SEV and Intel TDX were designed with the cloud threat model more explicitly in mind, protecting entire virtual machines rather than individual enclaves. But they still share fundamental hardware resources with the hypervisor and co-tenants. CPU caches, memory buses, power delivery, and microarchitectural scheduling state. CacheWarp, StackWarp, WeSee, and Heckler all exploit the interfaces between the confidential VM and the hypervisor that manages it.&lt;/p&gt;
&lt;p&gt;Virtual TPMs are another instance of the same pattern. Physical TPMs provide hardware-rooted trust because they are discrete chips with their own silicon. A vTPM is software running inside the hypervisor or a confidential VM. Cloud providers adopted vTPMs because provisioning hardware TPMs per VM is impractical at scale. The vTPM&apos;s trust root is the software stack that hosts it. If the hypervisor is compromised, the vTPM is compromised.&lt;/p&gt;
&lt;h2&gt;The Repurposing Pattern&lt;/h2&gt;
&lt;p&gt;This is a recurring pattern in security technology, and it is one I have watched play out multiple times in my career. Build X for threat model Y, then repurpose X for threat model Z because X already exists and deploying it is cheaper than building something new.&lt;/p&gt;
&lt;p&gt;SMS was designed for person-to-person messaging. It was repurposed for two-factor authentication because every phone could receive an SMS. The threat model assumed the cellular network was trusted. SIM swapping, SS7 interception, and malware-based SMS capture exploited the gap between &quot;messaging channel&quot; and &quot;authentication channel.&quot; NIST deprecated SMS-based 2FA. SMS OTP is still everywhere because deployment inertia exceeds the security community&apos;s ability to move the market.&lt;/p&gt;
&lt;p&gt;SSL was designed for securing web browsing sessions. It was repurposed for API authentication, IoT device communication, email encryption, and VPN tunneling. Each repurposing exposed assumptions in the original design that did not hold in the new context. The ecosystem spent two decades fixing the gaps through Certificate Transparency, HSTS, and progressively stricter CA/Browser Forum requirements. I was part of that ecosystem. The fixes were not inevitable. They required sustained institutional effort.&lt;/p&gt;
&lt;p&gt;TPMs were designed for boot integrity on enterprise desktops. They were repurposed as vTPMs for cloud VM attestation, trading hardware isolation for scalability. SGX was designed for desktop DRM. It was repurposed for cloud confidential computing, trading single-tenant simplicity for multi-tenant attack surface. Each repurposing followed the same logic. The technology existed, the market needed something, and &quot;available now with known limitations&quot; beat &quot;purpose-built but years away.&quot;&lt;/p&gt;
&lt;p&gt;The repurposed technology works well enough to create adoption. The adoption creates dependency. The dependency makes it difficult to replace even after the threat model gap is well understood. And the security research community spends years documenting the consequences while the market continues deploying.&lt;/p&gt;
&lt;p&gt;AWS took a different path with Nitro Enclaves. Rather than building on CPU instruction extensions designed for desktops, Nitro Enclaves are isolated virtual machines on a purpose-built hypervisor with no persistent storage, no network access, and no access from the host. The Nitro model sidestepped many of the shared-resource problems because the hypervisor is minimal and the enclave has dedicated resources. The measurement model is clean. One image, one deterministic measurement.&lt;/p&gt;
&lt;p&gt;Azure and GCP followed with confidential VM offerings on AMD SEV-SNP and Intel TDX. Google has positioned confidential computing as foundational to AI, expanding support across Confidential VMs, Confidential GKE Nodes, and Confidential Space with Intel TDX and NVIDIA H100 GPUs.&lt;/p&gt;
&lt;p&gt;NVIDIA entered with confidential GPU support on H100 and Blackwell architectures. Their reference architecture for &quot;zero-trust AI factories&quot; combines CPU TEEs with confidential GPUs, Confidential Containers via Kata, and a Key Broker Service that releases model decryption keys only after remote attestation succeeds. Model weights remain encrypted until the hardware proves the enclave is genuine. This positions confidential computing as IP protection for model owners deploying on infrastructure they do not control.&lt;/p&gt;
&lt;p&gt;Intel launched Trust Authority as a SaaS attestation service independent of the cloud provider. If the cloud provider both runs your TEE and verifies its attestation, you are still trusting the provider. An independent verifier breaks that circularity.&lt;/p&gt;
&lt;p&gt;By 2025, every major hardware vendor and every major cloud provider had a confidential computing offering. The question was no longer whether the technology existed. It was whether anyone could make it work at scale.&lt;/p&gt;
&lt;h2&gt;Why It Never Hit Mass Adoption&lt;/h2&gt;
&lt;p&gt;Despite the investment, confidential computing did not achieve mass adoption through the SGX era or the first wave of confidential VMs. Several problems compounded.&lt;/p&gt;
&lt;p&gt;Attestation is hard to operationalize. The verification step requires infrastructure that most organizations do not have and that the ecosystem has not built. I wrote about this problem in detail in &lt;a href=&quot;https://unmitigatedrisk.com/2026/04/why-nobody-can-verify-what-booted-your-server/&quot;&gt;Why Nobody Can Verify What Booted Your Server&lt;/a&gt;. The short version: 84% of IT leaders cite attestation validation as their top adoption challenge.&lt;/p&gt;
&lt;p&gt;The performance overhead was non-trivial in early implementations. SGX had significant costs from enclave transitions and limited memory. Confidential VMs with SEV-SNP and TDX reduced this to single-digit percentage overhead for most workloads, but the perception of &quot;secure means slow&quot; persisted.&lt;/p&gt;
&lt;p&gt;The developer experience was poor. SGX required application partitioning and a specialized SDK. Confidential VMs improved this by running unmodified applications, but attestation integration, key management, and secret provisioning still required specialized knowledge. As of early 2026, deploying a confidential workload still requires expertise that most teams do not have.&lt;/p&gt;
&lt;p&gt;The vulnerability narrative undermined confidence. The side-channel attacks against SGX were not random bugs. They were a predictable consequence of deploying a single-tenant design in a multi-tenant environment. Each new attack generated press coverage and reinforced the perception that the technology could not deliver. Security teams found a long list of CVEs, academic attacks, and &quot;known limitations&quot; that made the risk-benefit calculus uncertain.&lt;/p&gt;
&lt;p&gt;And without AI, the use cases were niche. DRM, financial services MPC, healthcare analytics, sovereign cloud compliance. Real markets, but not mass markets. Not enough volume to drive the ecosystem maturity needed for broad adoption.&lt;/p&gt;
&lt;h2&gt;The Vulnerability Record&lt;/h2&gt;
&lt;p&gt;The side-channel attacks did not stop with SGX&apos;s partial deprecation. They followed the technology into the cloud.&lt;/p&gt;
&lt;p&gt;Intel TDX still shares microarchitectural resources with the hypervisor. TDXdown demonstrated single-stepping and instruction counting against TDX trust domains. PortPrint showed that CPU port contention reveals distinctive execution signatures across SGX, TDX, and SEV alike, and because it exploits instruction-level parallelism rather than thread-level parallelism, disabling SMT does not help.&lt;/p&gt;
&lt;p&gt;The attack that most directly undermines the &quot;Private AI&quot; narrative is TDXRay (IEEE S&amp;amp;P 2026, UC San Diego, CISPA, Google). TDXRay produces cache-line-granular memory access traces of unmodified, encrypted TDX VMs. The researchers reconstructed user prompts word-for-word from a confidential LLM inference session. No cryptography was broken. The attack works because standard LLM tokenizers traverse a hash map to find token IDs, and that traversal creates a memory access pattern observable at 64-byte cache-line resolution. The host watches which hash map nodes the tokenizer visits and stitches the prompt back together. The encryption protects the data in memory. The computation pattern leaks it through the cache.&lt;/p&gt;
&lt;p&gt;TEE.Fail (ACM CCS 2025) is the most dramatic recent finding. Researchers built a $1,000 physical interposer that monitors the DDR5 memory bus and extracted ECDSA attestation keys from Intel&apos;s Provisioning Certification Enclave, the keys that underpin the entire SGX and TDX attestation chain. Attestation can be forged. The attack requires physical access, which limits applicability. But cloud providers have physical access to every server they operate.&lt;/p&gt;
&lt;p&gt;On March 31, 2026, Mark Ermolov announced the extraction of the SGX Global Wrapping Key from Intel Gemini Lake. This is not a side-channel leak. It is extraction of the root cryptographic key that protects SGX sealing operations. The key wraps Fuse Key 0, which means the entire key hierarchy rooted in hardware fuses is compromised for that platform generation. No microcode update can change fuses. Ermolov&apos;s assessment: &quot;its fundamental break means that the HW Root of Trust approach is not unshakable.&quot;&lt;/p&gt;
&lt;p&gt;Gemini Lake is a low-power consumer chip, not a Xeon server processor. The same attack has not been demonstrated on current server-class implementations. But the research trajectory is clear. Each generation of hardware trust primitives has been broken by the next generation of hardware security research.&lt;/p&gt;
&lt;h2&gt;Why the Pattern Persists: Five Broken Design Assumptions&lt;/h2&gt;
&lt;p&gt;The vulnerability record is not a collection of unrelated bugs. It is the predictable result of specific design assumptions that held in the original use cases but fail in the cloud and AI contexts where the technology is now deployed.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;The attacker does not share physical hardware with the victim.&lt;/strong&gt; SGX was designed for a desktop where one user runs one workload. In the cloud, co-tenants share CPU cores, caches, branch predictors, TLBs, execution ports, memory controllers, and power delivery. CacheWarp, StackWarp, and TDXRay all exploit resources that remain shared because complete resource partitioning would make the hardware unusable for general-purpose computing.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;The platform owner is not the adversary.&lt;/strong&gt; TPMs and early SGX assumed the platform owner was the user or a trusted IT department. In the cloud, the provider controls the hypervisor, firmware, BMC, physical facility, and scheduling. The interfaces between the TEE and the provider-controlled environment become the attack surface. WeSee, Heckler, and SEVered exploit these interfaces. TEE.Fail exploits the provider&apos;s physical access to the memory bus.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;The hardware root of trust is immutable.&lt;/strong&gt; The attestation model depends on root keys being beyond the reach of software attacks. This assumption has been violated repeatedly. Ermolov reached fuse-based keys through microcode. Google&apos;s CVE-2024-56161 found an insecure hash in AMD&apos;s microcode signature validation. Sinkclose provided universal Ring-2 escalation on AMD CPUs back to 2006.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Attestation verification is someone else&apos;s problem.&lt;/strong&gt; The specifications define how to produce attestation evidence but not how to verify it at scale. In the desktop DRM case, one binary produced one hash. In the cloud, PCR values are &lt;a href=&quot;https://unmitigatedrisk.com/2026/04/why-nobody-can-verify-what-booted-your-server/&quot;&gt;combinatorial across firmware, bootloader, kernel, and boot configuration&lt;/a&gt;.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Performance and security tradeoffs are invisible.&lt;/strong&gt; On a desktop running DRM playback, a 5% performance hit is imperceptible. On a cloud server running AI inference at scale, every percentage point is cost. Disabling SMT, applying Downfall mitigations, and enabling inline encryption all have measurable overhead. Organizations are pressured to disable countermeasures for performance, reopening the attack surface.&lt;/p&gt;
&lt;p&gt;These assumptions compound. The attacker shares hardware with a platform owner who is the adversary, exploiting a hardware root of trust that has a shelf life, verified through attestation infrastructure that does not exist at scale, with mitigations that carry performance costs the deployment context cannot absorb. No single patch addresses the compound effect. The assumptions are architectural, not implementational, which is why the vulnerability catalog grows despite continuous investment in mitigations.&lt;/p&gt;
&lt;p&gt;The full root cause analysis with specific attack mappings for each assumption is in the companion &lt;a href=&quot;https://docs.google.com/document/d/1vlkwCJPEFyC2vIt9PgTkf-SuUvsELaFDH50GcTdd-bA/&quot;&gt;TEE Vulnerability Taxonomy&lt;/a&gt;.&lt;/p&gt;
&lt;h2&gt;AI Changes the Calculus&lt;/h2&gt;
&lt;p&gt;All of the problems described above are real and unresolved. None of them are stopping adoption, because AI changed the calculus.&lt;/p&gt;
&lt;p&gt;Model weights represent billions of dollars in training investment. A leaked foundation model is a competitive catastrophe. Running inference on shared cloud infrastructure means trusting the cloud provider not to inspect memory, which is the exact problem TEEs solve.&lt;/p&gt;
&lt;p&gt;Training data includes regulated information across healthcare, financial services, and government. The EU AI Act, DORA, CCPA, and evolving federal privacy frameworks create compliance pressure that confidential computing directly addresses.&lt;/p&gt;
&lt;p&gt;Multi-party AI scenarios (federated learning, collaborative training, secure inference on third-party data) require environments where no single party sees the complete dataset. TEEs provide the isolation boundary. This is why every major hyperscaler is building on confidential computing despite its known limitations.&lt;/p&gt;
&lt;p&gt;But AI workloads amplify every weakness. GPU TEEs are new and their attestation models are immature. The attestation chain now spans CPU TEE, GPU TEE, and potentially TPM, each with different measurement schemes. AI workloads run on heterogeneous infrastructure across multiple cloud providers. And AI workloads are the most valuable targets for the attacks TEEs are vulnerable to. An attacker who extracts model weights via a side channel gets a multi-billion-dollar asset.&lt;/p&gt;
&lt;p&gt;The market treats the different TEE designs (SGX, SEV, TDX, Nitro, NVIDIA confidential GPU) as interchangeable. They are not. Each has different properties and different security guarantees. Pretending otherwise is how organizations end up deploying against a threat model their chosen TEE was not designed to address.&lt;/p&gt;
&lt;h2&gt;The Trust Model Gap&lt;/h2&gt;
&lt;p&gt;The deeper issue is the gap between what is marketed and what is engineered.&lt;/p&gt;
&lt;p&gt;Confidential computing marketing says &quot;even the infrastructure provider cannot access your data.&quot;&lt;/p&gt;
&lt;p&gt;The engineering reality is different. The infrastructure provider cannot access your data through the software stack, but the hardware has known side-channel leakages that a sufficiently motivated attacker with privileged access can exploit. The attestation infrastructure that proves the TEE is genuine has structural limitations that make verification at scale dependent on each organization building its own reference value databases. And the hardware root of trust that anchors the entire system has a demonstrated shelf life.&lt;/p&gt;
&lt;p&gt;This is a reasonable tradeoff for many threat models. Most organizations are defending against curious administrators, software-level compromise, and regulatory compliance requirements. Side-channel attacks require significant expertise and often physical access. But the market does not present it as a tradeoff.&lt;/p&gt;
&lt;h2&gt;What Needs to Happen&lt;/h2&gt;
&lt;p&gt;Closing the gap between the market narrative and the engineering reality requires work that is less exciting than launching new AI services.&lt;/p&gt;
&lt;p&gt;Firmware and OS vendors need to publish reference measurements. The standards exist. &lt;a href=&quot;https://datatracker.ietf.org/doc/draft-ietf-rats-corim/&quot;&gt;CoRIM&lt;/a&gt; provides the format. &lt;a href=&quot;https://www.rfc-editor.org/rfc/rfc9683&quot;&gt;RFC 9683&lt;/a&gt; provides the framework. What is missing is the operational commitment to publish signed measurement values for every release. I wrote about the &lt;a href=&quot;https://unmitigatedrisk.com/2026/04/why-nobody-can-verify-what-booted-your-server/&quot;&gt;infrastructure that would need to exist&lt;/a&gt; and why none of it does yet.&lt;/p&gt;
&lt;p&gt;The industry needs honest threat modeling that acknowledges what TEEs protect against and what they do not. TEE.Fail requires physical access, but cloud providers have physical access to every server. TDXdown requires a malicious hypervisor, which is precisely the threat TDX is designed to defend against. These are not edge cases. They are the threat model.&lt;/p&gt;
&lt;p&gt;Attestation verification needs to become a commodity. Organizations should not need to build their own reference value databases, write their own event log parsers, and maintain their own golden image registries. This infrastructure should be as standardized and available as &lt;a href=&quot;https://certificate.transparency.dev/&quot;&gt;Certificate Transparency&lt;/a&gt; logs are for the web PKI.&lt;/p&gt;
&lt;p&gt;And the security research community&apos;s findings need to be incorporated into the market narrative rather than treated as exceptions. The pattern of continuous vulnerability discovery and mitigation is the normal state of the technology, not an aberration.&lt;/p&gt;
&lt;p&gt;Confidential computing is directionally correct. The ability to verify what code is running on hardware you do not control, rather than simply trusting the operator, is a fundamental improvement in how we build systems. Signal proved the model works. The challenge is closing the gap between that promise and the current engineering reality.&lt;/p&gt;
&lt;p&gt;The organizations deploying confidential computing for AI workloads today should understand what they are buying. Against the threats they are most likely to face, curious administrators, software-level compromise, regulatory compliance gaps, and unauthorized data access by the infrastructure operator, confidential computing is a significant improvement. Against a well-resourced attacker with physical access to the hardware, side-channel expertise, or the ability to exploit a hardware root-of-trust vulnerability, it is a partial mitigation, not an absolute guarantee.&lt;/p&gt;
&lt;p&gt;That is a defensible position. It is just not the one being marketed.&lt;/p&gt;
&lt;hr /&gt;
&lt;p&gt;For practical guidance on deployment, see &lt;a href=&quot;https://unmitigatedrisk.com/2026/04/confidential-computing-what-it-is-what-it-isnt-and-how-to-think-about-it/&quot;&gt;Confidential Computing: What It Is, What It Isn&apos;t, and How to Think About It&lt;/a&gt;.&lt;/p&gt;
&lt;p&gt;For the full vulnerability catalog and root cause framework, see the &lt;a href=&quot;https://docs.google.com/document/d/1vlkwCJPEFyC2vIt9PgTkf-SuUvsELaFDH50GcTdd-bA/&quot;&gt;TEE Vulnerability Taxonomy&lt;/a&gt; and &lt;em&gt;&lt;a href=&quot;https://docs.google.com/document/d/18eNZrZ1ujiv6pEU84ogLe5YE3G1fcdVoaiFrd_6FsHw/&quot;&gt;TPM Attestation and PCR Verification&lt;/a&gt;&lt;/em&gt; .&lt;/p&gt;
&lt;p&gt;&lt;em&gt;Previously: &lt;a href=&quot;https://unmitigatedrisk.com/2025/03/tpms-tees-and-everything-in-between-what-you-actually-need-to-know/&quot;&gt;TPMs, TEEs, and Everything In Between&lt;/a&gt; (March 2025). See also: &lt;a href=&quot;https://unmitigatedrisk.com/2026/04/why-nobody-can-verify-what-booted-your-server/&quot;&gt;Why Nobody Can Verify What Booted Your Server&lt;/a&gt;.&lt;/em&gt;&lt;/p&gt;
</content:encoded><category>ai</category><category>security</category><category>technology</category><category>thoughts</category></item><item><title>What Is Confidential Computing, What It Isn&apos;t, and How to Think About It</title><link>https://unmitigatedrisk.com/2026/04/confidential-computing-what-it-is-what-it-isnt-and-how-to-think-about-it/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/04/confidential-computing-what-it-is-what-it-isnt-and-how-to-think-about-it/</guid><description>Confidential computing is the most important security technology that most organizations deploying it do not fully understand.</description><pubDate>Fri, 03 Apr 2026 19:03:52 GMT</pubDate><content:encoded>&lt;p&gt;Confidential computing is the most important security technology that most organizations deploying it do not fully understand.&lt;/p&gt;
&lt;p&gt;Last March, I wrote about the &lt;a href=&quot;https://unmitigatedrisk.com/2025/03/tpms-tees-and-everything-in-between-what-you-actually-need-to-know/&quot;&gt;terminology confusion in security hardware&lt;/a&gt; — how terms like TEE, TPM, secure enclave, and confidential computing get used interchangeably in ways that obscure what these technologies actually do. The &lt;a href=&quot;https://docs.google.com/document/d/1dhCRIks4kjounzuPAEtllBtxCtJGa4adAZ0ok8DNigs/&quot;&gt;accompanying technical reference&lt;/a&gt; laid out the foundational concepts and the ways these technologies fail.&lt;/p&gt;
&lt;p&gt;A year later, confidential computing is no longer a niche technology. AI has made it urgent. When you run inference on a model worth hundreds of millions in training compute, on hardware you don&apos;t own, in a data center you&apos;ve never visited, the question of what the infrastructure operator can see becomes a business-critical concern. Confidential computing is the industry&apos;s answer.&lt;/p&gt;
&lt;p&gt;It is also a technology whose security properties are routinely overstated by the vendors selling it and the cloud providers deploying it. Marketing language like &quot;even the infrastructure provider cannot access your data&quot; appears in product pages from every major hyperscaler. The engineering reality is more constrained than that, and the gap between the marketing and the engineering is where organizations get hurt. None of that means you shouldn&apos;t use it. I use it extensively. It means you need to understand what it actually gives you so you can build architectures that account for what it doesn&apos;t.&lt;/p&gt;
&lt;h2&gt;What Confidential Computing Actually Does&lt;/h2&gt;
&lt;p&gt;Confidential computing protects data while it is being processed. Traditional encryption covers data at rest and data in transit. Confidential computing addresses the third state: data in use, the window when data must be decrypted for computation and is therefore exposed in memory.&lt;/p&gt;
&lt;p&gt;The mechanism is hardware-based isolation. The CPU (or GPU, in newer implementations) creates an environment where code and data are encrypted in memory and protected from all other software on the system, including the operating system and hypervisor. The cloud provider&apos;s administrators cannot read your data even though it is running on their hardware.&lt;/p&gt;
&lt;p&gt;The technology comes in several forms. AMD SEV-SNP and Intel TDX protect entire virtual machines. AWS Nitro Enclaves provide isolated execution environments on Amazon&apos;s custom hardware. NVIDIA&apos;s H100 and Blackwell GPUs add hardware-encrypted GPU memory with GPU-specific attestation. Apple&apos;s Secure Enclave protects biometric data and cryptographic keys on a physically separate processor. The implementations differ significantly, but they share a common principle: hardware-enforced boundaries that the software stack cannot cross.&lt;/p&gt;
&lt;h2&gt;What It Does Not Do&lt;/h2&gt;
&lt;p&gt;Confidential computing does not make your workload invulnerable. It changes the threat model. Understanding what it does not protect against matters as much as understanding what it does.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Side-channel attacks remain viable.&lt;/strong&gt; The CPU still shares caches, branch predictors, execution ports, and power delivery with other workloads. Researchers have demonstrated attacks that extract data from inside TEEs without breaking any cryptography. The TDXRay attack (IEEE S&amp;amp;P 2026) reconstructed user prompts word-for-word from an encrypted Intel TDX VM by watching which cache lines the LLM tokenizer accessed. The data was encrypted in memory. The computation pattern leaked it through the cache.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Physical access defeats memory encryption.&lt;/strong&gt; The TEE.Fail attack (ACM CCS 2025) used a $1,000 device soldered to the DDR5 memory bus to extract attestation keys from Intel TDX and AMD SEV-SNP. Cloud providers have physical access to every server they operate. That is the threat model confidential computing claims to address.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Attestation depends on hardware roots of trust that have a shelf life.&lt;/strong&gt; Attestation is how a TEE proves to a remote party that it is running expected code on genuine hardware. The proof depends on cryptographic keys embedded in the processor. Those keys have been extracted. The March 2026 extraction of the SGX Global Wrapping Key from Intel Gemini Lake reached root keys burned into hardware fuses. Google&apos;s discovery of an insecure hash in AMD&apos;s microcode signature validation (&lt;a href=&quot;https://www.amd.com/en/resources/product-security/bulletin/amd-sb-3019.html&quot;&gt;CVE-2024-56161&lt;/a&gt;) allowed loading malicious microcode that could subvert SEV-SNP. When root keys are compromised, attestation can be forged.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Attestation verification infrastructure barely exists.&lt;/strong&gt; Even if the TEE hardware is sound, verifying attestation at scale requires knowing what the correct measurements should be. For TPM-based attestation, this means maintaining reference values for every combination of firmware, bootloader, kernel, and boot configuration across a heterogeneous fleet. That infrastructure &lt;a href=&quot;https://unmitigatedrisk.com/2026/04/why-nobody-can-verify-what-booted-your-server/&quot;&gt;largely does not exist&lt;/a&gt;. An IDC survey found that 84% of IT leaders cite attestation validation as their top adoption challenge.&lt;/p&gt;
&lt;h2&gt;The Vulnerability Record in Context&lt;/h2&gt;
&lt;p&gt;The security research community has published over 50 distinct attacks against TEE platforms since 2017. The companion TEE Vulnerability Taxonomy catalogs these in detail.&lt;/p&gt;
&lt;p&gt;The number is large. It does not mean confidential computing is broken. It means the technology has been subjected to intense scrutiny by some of the best hardware security researchers in the world, and they have found weaknesses. The question is whether the risk after deploying the technology is lower than the risk without it.&lt;/p&gt;
&lt;p&gt;For most deployments, the answer is yes. Confidential computing raises the bar significantly. An attacker who could previously read VM memory through a compromised hypervisor now needs a side-channel attack, a physical interposition device, or a root-of-trust compromise. Each of these is substantially harder than the baseline attack.&lt;/p&gt;
&lt;p&gt;The vulnerability record matters most when the attacker is well-resourced and has privileged access to the infrastructure — which is exactly the cloud provider threat model that confidential computing is designed to address. The threat model it targets is the one where its limitations are most relevant. That tension is real, and pretending it does not exist does not help anyone making deployment decisions.&lt;/p&gt;
&lt;p&gt;The Gartner prediction that 75% of processing in untrusted infrastructure will use confidential computing by 2029 assumes a maturity the technology has not achieved. Treating a bounded isolation primitive as a general trust solution is how organizations end up surprised.&lt;/p&gt;
&lt;h2&gt;How to Think About Deployment&lt;/h2&gt;
&lt;p&gt;Confidential computing is one layer in a defense-in-depth architecture. It is not a substitute for the other layers. I have deployed confidential computing in production and these are the principles I have found matter most.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Use it, but don&apos;t rely on it alone.&lt;/strong&gt; Encrypt data at rest and in transit independently of the TEE. Use application-level encryption for the most sensitive data so that even a TEE compromise does not expose plaintext. The TEE is a defense-in-depth layer, not your sole protection.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Verify attestation, and understand what verification actually proves.&lt;/strong&gt; A TPM quote or attestation report proves the state of the machine at the time the quote was generated. It does not prove the machine is still in that state five minutes later. It does not prove the machine&apos;s physical location or who has physical access. Build your verification flow with these limitations in mind.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Know your TEE&apos;s specific threat model.&lt;/strong&gt; AMD SEV-SNP, Intel TDX, AWS Nitro Enclaves, and NVIDIA GPU CC have different architectures, different shared resource boundaries, and different attestation mechanisms. They are not interchangeable. A TDX trust domain sharing microarchitectural state with a hypervisor has a different side-channel surface than a Nitro Enclave running on a purpose-built hypervisor with dedicated resources.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Plan for the hardware root of trust to eventually fail.&lt;/strong&gt; The research trajectory is clear: each generation of hardware trust primitives has been broken by the next generation of hardware security research. Build your key management and secret rotation so that a root-of-trust compromise on one platform generation does not expose secrets that have already been rotated.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Ask whether your workload actually needs multi-tenant cloud TEEs.&lt;/strong&gt; For some use cases, a physically discrete device — an HSM, a USB Armory, a Nitro Enclave with dedicated resources — provides stronger isolation than a confidential VM sharing silicon with co-tenants. The multi-tenancy problem is where most of the vulnerability surface lives. If your workload does not require multi-tenant shared infrastructure, you can sidestep the largest attack class entirely.&lt;/p&gt;
&lt;h2&gt;What a Practical Architecture Looks Like&lt;/h2&gt;
&lt;p&gt;Consider a Certificate Authority that runs its signing operations inside AWS Nitro Enclaves. The enclave has no persistent storage, no network access, and no access from the host instance. The signing key never leaves the enclave. Attestation is verified through the Nitro Attestation PKI, which produces deterministic measurements of the enclave image.&lt;/p&gt;
&lt;p&gt;Nitro Enclaves were chosen because their architecture sidesteps the shared-resource side-channel problems that affect SGX and TDX. The Nitro hypervisor is purpose-built and minimal. The enclave gets dedicated resources. The measurement model is clean: one image, one deterministic measurement, no combinatorial PCR explosion.&lt;/p&gt;
&lt;p&gt;But the enclave is not the only security layer. The signing keys are backed by a hardware root of trust. The enclave image is built from reproducible builds so the expected measurements are verifiable from source. Access to the host instance is controlled through IAM policies that are themselves audited. The architecture is designed so that compromising any single layer does not compromise the signing keys.&lt;/p&gt;
&lt;p&gt;Use confidential computing as a meaningful security improvement, understand its specific limitations, and build the rest of your architecture so that the limitations do not become single points of failure.&lt;/p&gt;
&lt;h2&gt;Where This Is Heading&lt;/h2&gt;
&lt;p&gt;Confidential computing is not going away. The economic pressure to deploy AI workloads on shared infrastructure guarantees continued investment. NVIDIA&apos;s Blackwell architecture extends confidential GPU support. ARM CCA adds Realm World isolation. The Confidential Computing Consortium continues to drive standardization.&lt;/p&gt;
&lt;p&gt;The technology will improve. Side-channel mitigations will get better. Attestation infrastructure will mature — the IETF RATS standards are ready, and what is missing is vendor adoption of publishing reference values. Performance overhead will continue to decrease.&lt;/p&gt;
&lt;p&gt;But the fundamental constraints — shared microarchitectural resources, physically accessible memory buses, the shelf life of hardware roots of trust — are properties of how CPUs and memory work. They will not be eliminated by the next generation of silicon. They will be reduced, mitigated, and worked around.&lt;/p&gt;
&lt;p&gt;Confidential computing is a significant improvement in security posture. It is not an absolute guarantee. That is a defensible position to sell. It is just not the one being sold.&lt;/p&gt;
&lt;hr /&gt;
&lt;p&gt;For the deeper analysis of why the vulnerability record looks the way it does, see &lt;a href=&quot;https://unmitigatedrisk.com/2026/04/confidential-computings-inconvenient-truth/&quot;&gt;Confidential Computing&apos;s Inconvenient Truth&lt;/a&gt;.&lt;/p&gt;
&lt;p&gt;For the full vulnerability catalog, attestation gap analysis, and root cause framework, see the &lt;a href=&quot;https://docs.google.com/document/d/1vlkwCJPEFyC2vIt9PgTkf-SuUvsELaFDH50GcTdd-bA/&quot;&gt;TEE Vulnerability Taxonomy&lt;/a&gt; and &lt;em&gt;&lt;a href=&quot;https://docs.google.com/document/d/18eNZrZ1ujiv6pEU84ogLe5YE3G1fcdVoaiFrd_6FsHw/&quot;&gt;TPM Attestation and PCR Verification&lt;/a&gt;&lt;/em&gt; .&lt;/p&gt;
&lt;p&gt;&lt;em&gt;Previously: &lt;a href=&quot;https://unmitigatedrisk.com/2025/03/tpms-tees-and-everything-in-between-what-you-actually-need-to-know/&quot;&gt;TPMs, TEEs, and Everything In Between: What You Actually Need to Know&lt;/a&gt; (March 2025). See also: &lt;a href=&quot;https://unmitigatedrisk.com/2026/04/why-nobody-can-verify-what-booted-your-server/&quot;&gt;Why Nobody Can Verify What Booted Your Server&lt;/a&gt;.&lt;/em&gt;&lt;/p&gt;
</content:encoded><category>security</category><category>technology</category><category>thoughts</category></item><item><title>Why Nobody Can Verify What Booted Your Server</title><link>https://unmitigatedrisk.com/2026/04/why-nobody-can-verify-what-booted-your-server/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/04/why-nobody-can-verify-what-booted-your-server/</guid><description>There is no public database of known-good TPM measurements. There never has been.</description><pubDate>Fri, 03 Apr 2026 18:29:28 GMT</pubDate><content:encoded>&lt;p&gt;There is no public database of known-good TPM measurements. There never has been.&lt;/p&gt;
&lt;p&gt;The Trusted Platform Module, a security chip that measures and attests to system integrity, has been a standard for twenty years. TPMs ship in virtually every enterprise laptop and server. Software-emulated versions are provisioned for every cloud VM on Azure, GCP, and AWS. Measured boot is a checkbox in every compliance framework that touches system integrity. The hardware that produces platform measurements is everywhere. The infrastructure to verify those measurements is not.&lt;/p&gt;
&lt;p&gt;If you have deployed measured boot at scale, you have hit this wall. I have, more than once. If you haven&apos;t yet, you will.&lt;/p&gt;
&lt;p&gt;I wrote about the &lt;a href=&quot;https://unmitigatedrisk.com/2025/03/tpms-tees-and-everything-in-between-what-you-actually-need-to-know/&quot;&gt;foundational concepts behind these technologies&lt;/a&gt; last year, covering how TPMs, TEEs, HSMs, and secure enclaves differ and where they fail. This post goes deeper on one specific problem that anyone deploying measured boot or confidential VMs hits immediately: the verification gap for PCR values.&lt;/p&gt;
&lt;h2&gt;What PCRs Are and Why They Exist&lt;/h2&gt;
&lt;p&gt;A TPM contains a set of Platform Configuration Registers, special-purpose storage locations that record the boot chain as a sequence of cryptographic measurements. Each boot stage measures the next before handing off execution. The measurements are extended into PCRs using a one-way hash chain: the old value is concatenated with the new measurement and hashed to produce the new value. This is irreversible. Given a final PCR value, you cannot determine the individual measurements without replaying the full sequence.&lt;/p&gt;
&lt;p&gt;A TPM quote is a signed snapshot of these PCR values, which lets a remote verifier assess what software actually booted on the machine. This is remote attestation, and it answers a question no operating system can answer about itself: did this machine boot what it was supposed to boot?&lt;/p&gt;
&lt;p&gt;This works fine for a single machine. The problem is fleets.&lt;/p&gt;
&lt;h2&gt;Why There Is No PCR Registry&lt;/h2&gt;
&lt;p&gt;You would think someone would have built a public database of known-good PCR values by now, something like &lt;a href=&quot;https://www.ccadb.org/&quot;&gt;CCADB&lt;/a&gt; for certificate trust or &lt;a href=&quot;https://www.virustotal.com/&quot;&gt;VirusTotal&lt;/a&gt; for malware hashes. Nobody has, and it is not because nobody thought of it. The reasons are structural.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;PCR values are combinatorial.&lt;/strong&gt; A single PCR accumulates measurements from multiple software components. PCR 0 reflects the firmware version, CPU microcode patches, and the UEFI configuration that controls early boot behavior. PCR 4 reflects the bootloader and the shim that validates Secure Boot signatures. On modern Linux distributions using Unified Kernel Images, which bundle the kernel and initial RAM disk into a single signed binary, measurements fragment across PCRs 8, 9, 11, and 12 depending on the distribution and boot configuration. This is messier than the traditional GRUB boot path, and it was already messy.&lt;/p&gt;
&lt;p&gt;Any component update produces a completely different PCR value for the affected register. A fleet with 3 firmware versions, 2 bootloaders, 4 kernels, and 3 initrd configurations has 72 valid PCR value combinations for a single hardware model. Five hardware models is 360. Add boot parameters and the number becomes effectively unbounded.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Measurement ordering matters.&lt;/strong&gt; The hash chain is order-dependent. Extending measurement A then B produces a different result than B then A. Boot is not fully deterministic. Driver initialization order, ACPI table enumeration, and peripheral probe sequences can vary between boots of identical software on identical hardware. The TCG&apos;s own specification acknowledges this directly: operating system boot code is &quot;usually non-deterministic, meaning that there may never be a single &apos;known good&apos; PCR value.&quot;&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Firmware measurements are opaque.&lt;/strong&gt; The UEFI event log is the detailed record behind those PCR values, and in practice it is often more useful than the final values themselves. But the event data for firmware blobs is often just a physical memory address and size. No indication of format or purpose. Intel Boot Guard measurements use methods that are under NDA. Dell extends proprietary configuration data into PCR 6 in undocumented formats. A verifier cannot independently reconstruct many of these measurements without vendor-specific knowledge that is not publicly available.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Nobody is obligated to publish reference values.&lt;/strong&gt; The standards for publishing expected measurements exist. The TCG &lt;a href=&quot;https://trustedcomputinggroup.org/resource/tcg-reference-integrity-manifest-rim-information-model/&quot;&gt;Reference Integrity Manifest&lt;/a&gt; specification defines the formats. The IETF RATS working group developed &lt;a href=&quot;https://datatracker.ietf.org/doc/draft-ietf-rats-corim/&quot;&gt;CoRIM&lt;/a&gt;, a compact machine-readable format for publishing reference measurements. &lt;a href=&quot;https://www.rfc-editor.org/rfc/rfc9683&quot;&gt;RFC 9683&lt;/a&gt;, which covers remote integrity verification of network devices containing TPMs, specifies that software suppliers MUST make reference values available as signed tags. The standards are there. Manufacturers are not obligated to follow through, and most do not.&lt;/p&gt;
&lt;h2&gt;What Everyone Actually Does Instead&lt;/h2&gt;
&lt;p&gt;PCR value matching fails at scale, so the industry has quietly converged on something else: event log verification.&lt;/p&gt;
&lt;p&gt;The TPM does not just produce final PCR values. It also maintains an event log, a sequential record of every individual measurement extended into each PCR during boot. Each entry contains the PCR index, the hash of what was measured, and a description of the event — &quot;loaded bootloader from partition 1&quot; or &quot;Secure Boot certificate db contained these entries.&quot;&lt;/p&gt;
&lt;p&gt;The event log is what makes attestation workable in practice. The verifier replays the log by re-computing the hash chain from the individual entries. If the replayed chain produces the same PCR values that the TPM signed in its quote, the log has not been tampered with. The events it describes are the actual events that produced those values. The verifier then evaluates individual events against a policy: is this firmware version on the approved list? Is Secure Boot enabled? Is the kernel signed by a trusted key? Was anything unexpected loaded?&lt;/p&gt;
&lt;p&gt;This is more flexible than PCR matching. A firmware update changes one event in the log, not the entire composite hash, so the policy absorbs the change without requiring new reference values.&lt;/p&gt;
&lt;p&gt;But event log verification has its own problems. Event data is often insufficient for independent verification. Vendor-specific formats are undocumented. Event types and descriptions are not part of the hash, so they can be manipulated without affecting the signed PCR value. Intel&apos;s CSME subsystem extends measurements that verifiers cannot evaluate without access to Intel&apos;s proprietary documentation.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://keylime.readthedocs.io/&quot;&gt;Keylime&lt;/a&gt;, the most mature open-source attestation framework, says it plainly: direct PCR value matching is &quot;only useful when the boot chain does not change often.&quot; &lt;a href=&quot;https://docs.trustauthority.intel.com/&quot;&gt;Intel Trust Authority&lt;/a&gt;, Google Cloud Attestation, and Azure Attestation all verify event log properties rather than matching literal PCR values.&lt;/p&gt;
&lt;p&gt;So every organization deploying TPM attestation at scale ends up building their own reference values by capturing measurements from known-good environments. The &quot;registry&quot; is whatever you build from your own golden images. This is not a sustainable state of affairs, but it is the state of affairs.&lt;/p&gt;
&lt;h2&gt;vTPMs Add Another Layer&lt;/h2&gt;
&lt;p&gt;Virtual TPMs make the verification problem worse. A physical TPM&apos;s trust comes from being a discrete chip with its own silicon. A vTPM is software running inside the hypervisor or a confidential VM. Cloud providers adopted vTPMs because provisioning physical TPMs per VM is impractical at cloud scale.&lt;/p&gt;
&lt;p&gt;The vTPM&apos;s trust root is the software and hardware stack that hosts it. If the hypervisor is compromised, the vTPM is compromised. If the CPU&apos;s hardware isolation (the TEE that protects the confidential VM) has a side-channel vulnerability, the vTPM&apos;s keys are exposed through that side channel. Verifying vTPM evidence requires also verifying the TEE evidence, because the trust chains through.&lt;/p&gt;
&lt;p&gt;Each layer&apos;s trust depends on the layer below, and the bottom layer has a demonstrated shelf life. The March 2026 extraction of the SGX Global Wrapping Key from Intel Gemini Lake and Google&apos;s discovery of an insecure hash in AMD&apos;s microcode signature validation (&lt;a href=&quot;https://www.amd.com/en/resources/product-security/bulletin/amd-sb-3019.html&quot;&gt;CVE-2024-56161&lt;/a&gt;) are the latest demonstrations that hardware roots of trust are not permanent.&lt;/p&gt;
&lt;h2&gt;A Practical Approach&lt;/h2&gt;
&lt;p&gt;The reference value infrastructure does not exist. So what do you actually do?&lt;/p&gt;
&lt;p&gt;Pick the verification approach that matches what your deployment can support, and accept the tradeoff. I have listed these from strongest assurance to weakest, which is also from highest operational cost to lowest.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Exact PCR match&lt;/strong&gt; compares values against a fixed allowlist. Strongest when reference values are correct. Breaks on any component update. Only practical for enclave-style deployments like AWS Nitro Enclaves or Intel SGX, where one image produces one deterministic measurement. If you control the entire image and the measurement is deterministic, this is the easy case.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Event log policy&lt;/strong&gt; replays the event log and evaluates individual events against policy. Flexible to component updates. Requires an event log parser and per-vendor knowledge of event formats.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Signed baseline&lt;/strong&gt; accepts any PCR values covered by a signature from a trusted key. The signing key becomes the trust anchor rather than a registry of literal values. When software updates change PCR values, the security team signs a new baseline. This is the PolicyAuthorize pattern that &lt;a href=&quot;https://docs.system-transparency.org/&quot;&gt;System Transparency&lt;/a&gt; documents and &lt;a href=&quot;https://github.com/okirch/pcr-oracle&quot;&gt;pcr-oracle&lt;/a&gt; supports: seal secrets to a signing key rather than to specific PCR values, so that software updates do not lock you out of your own data.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Node identity only&lt;/strong&gt; verifies the TPM&apos;s Endorsement Key identity without PCR verification. Proves hardware identity, not software state. Weakest assurance, lowest operational cost.&lt;/p&gt;
&lt;p&gt;Most real-world deployments will use different approaches for different parts of their architecture. Exact match for the most sensitive operations. Event log policy for managed servers. Signed baselines for fleet environments where the security team controls the update cycle. The right answer is almost never one approach for everything.&lt;/p&gt;
&lt;h2&gt;What Would Need to Exist, and Why It Matters&lt;/h2&gt;
&lt;p&gt;The gap between what TPM attestation promises and what it delivers at scale comes down to five missing pieces of infrastructure. None of them are technically novel. All of them require cross-vendor coordination, which is the hard part.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Firmware vendors publishing signed reference measurements for every release.&lt;/strong&gt; If Dell, HP, Lenovo, Supermicro, and Intel published signed &lt;a href=&quot;https://datatracker.ietf.org/doc/draft-ietf-rats-corim/&quot;&gt;CoRIM&lt;/a&gt; measurement bundles alongside firmware updates, verifiers could check boot measurements against vendor-provided values instead of building golden image databases. The thousands of organizations currently maintaining their own reference values stop doing that redundant, error-prone work. A firmware update becomes verifiable by any attestation service, not just by organizations that happened to capture the right measurements before deploying. This is the single highest-impact change.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;OS vendors publishing signed reference measurements for kernels, bootloaders, and initrd images.&lt;/strong&gt; Red Hat, Canonical, and SUSE would publish expected measurement values for each package version. The cost of operating measured boot drops from &quot;dedicated team&quot; to &quot;configuration.&quot;&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;A transparency log for reference measurements.&lt;/strong&gt; Analogous to &lt;a href=&quot;https://certificate.transparency.dev/&quot;&gt;Certificate Transparency&lt;/a&gt; for the web PKI. Reference value providers submit signed measurements to a log. Verifiers check the log. Monitors detect inconsistencies. The incentive structure shifts from &quot;trust the vendor&quot; to &quot;verify the vendor,&quot; which is the entire point of attestation in the first place.&lt;/p&gt;
&lt;p&gt;This is not hypothetical. I worked on firmware transparency at Google, including work with Andrea Barisani to integrate it into the &lt;a href=&quot;https://github.com/transparency-dev/armored-witness-boot&quot;&gt;Armored Witness&lt;/a&gt;, a tamper-evident signing device built on TamaGo and the USB Armory platform. Google publishes a &lt;a href=&quot;https://developers.google.com/android/binary_transparency/pixel_overview&quot;&gt;transparency log for Pixel factory images&lt;/a&gt;. The broader &lt;a href=&quot;https://binary.transparency.dev/&quot;&gt;Binary Transparency&lt;/a&gt; framework has production deployments across Go modules, sigstore, and firmware update pipelines. Researchers are extending the approach to &lt;a href=&quot;https://ieeexplore.ieee.org/document/11130100&quot;&gt;server firmware signing&lt;/a&gt;. The pattern works. What is missing is adoption by the server firmware vendors whose measurements actually need verifying.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Cross-vendor event log normalization.&lt;/strong&gt; A library that translates vendor-specific event log formats into a common representation, abstracting away the differences between Dell, HP, Lenovo, and Intel firmware event structures.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Attestation verification as a commodity service.&lt;/strong&gt; Not vendor-specific, not requiring deep expertise, but as simple as an OCSP responder for certificate revocation: send a TPM quote and event log, get back a signed attestation result.&lt;/p&gt;
&lt;p&gt;None of these exist at scale as of April 2026. The standards are ready. The hardware is deployed. The market is adopting confidential computing at a pace that assumes this infrastructure is coming. It is not here yet.&lt;/p&gt;
&lt;p&gt;None of this fixes the side-channel vulnerabilities in the TEE hardware itself. None of it extends the shelf life of hardware roots of trust. Those are silicon problems that require silicon solutions. But the attestation infrastructure gap is not a silicon problem. It is a coordination and incentive problem, and those are solvable.&lt;/p&gt;
&lt;p&gt;The web PKI went through a similar transition, and I watched it happen from the inside. Certificate mis-issuance was undetectable until Certificate Transparency made it visible. Certificate authorities operated without enforceable standards until the CA/Browser Forum Baseline Requirements created them. There was no shared database of trusted roots until CCADB built one. Each of those required cross-vendor coordination that looked unlikely right up until it shipped. The result is an ecosystem that is not perfect but is dramatically more trustworthy than it was fifteen years ago.&lt;/p&gt;
&lt;p&gt;The attestation infrastructure could follow the same path. The standards work is done. What remains is the operational commitment from the vendors who manufacture the hardware and the organizations that rely on it.&lt;/p&gt;
&lt;p&gt;Every organization deploying measured boot today is independently solving the same problem with their own golden images, their own event log parsers, and their own reference value databases. I have built some of these myself. The standards are ready, the hardware is deployed, and the economic incentive is growing. What is missing is the willingness to coordinate. That is a solvable problem.&lt;/p&gt;
&lt;hr /&gt;
&lt;p&gt;&lt;em&gt;This post is the first in a series on confidential computing. The next two posts, &lt;a href=&quot;https://unmitigatedrisk.com/2026/04/confidential-computing-what-it-is-what-it-isnt-and-how-to-think-about-it/&quot;&gt;What Is Confidential Computing, What It Isn’t, and How to Think About It&lt;/a&gt;, and &lt;a href=&quot;https://unmitigatedrisk.com/2026/04/confidential-computings-inconvenient-truth/&quot;&gt;Confidential Computing&apos;s Inconvenient Truth&lt;/a&gt;. Two companion reference documents provide the full evidence base: the &lt;a href=&quot;https://docs.google.com/document/d/1vlkwCJPEFyC2vIt9PgTkf-SuUvsELaFDH50GcTdd-bA/&quot;&gt;TEE Vulnerability Taxonomy&lt;/a&gt; and &lt;a href=&quot;https://docs.google.com/document/d/18eNZrZ1ujiv6pEU84ogLe5YE3G1fcdVoaiFrd_6FsHw/&quot;&gt;TPM Attestation and PCR Verification&lt;/a&gt;&lt;/em&gt;&lt;/p&gt;
&lt;p&gt;&lt;em&gt;Previously: &lt;a href=&quot;https://unmitigatedrisk.com/2025/03/tpms-tees-and-everything-in-between-what-you-actually-need-to-know/&quot;&gt;TPMs, TEEs, and Everything In Between: What You Actually Need to Know&lt;/a&gt; (March 2025)&lt;/em&gt;&lt;/p&gt;
</content:encoded><category>security</category><category>standards</category><category>technology</category><category>thoughts</category></item><item><title>We Built It With Slide Rules. Then We Forgot How.</title><link>https://unmitigatedrisk.com/2026/03/we-built-it-with-slide-rules-then-we-forgot-how/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/03/we-built-it-with-slide-rules-then-we-forgot-how/</guid><description>My father grew up on a subsistence farm, the kind that raised chickens and grew just enough to get by. Farmers were the original hackers. You couldn&apos;t wait for the right tool or the right expert. You fixed what was…</description><pubDate>Sun, 29 Mar 2026 23:39:10 GMT</pubDate><content:encoded>&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/03/image.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/03/image.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;My father grew up on a subsistence farm, the kind that raised chickens and grew just enough to get by. Farmers were the original hackers. You couldn&apos;t wait for the right tool or the right expert. You fixed what was broken with what you had, because the alternative was worse.&lt;/p&gt;
&lt;p&gt;As a kid he taught himself rocket chemistry. Not from a kit. From whatever he could source locally. He was trying to make things burn hotter and fly farther, adjusting mixtures through trial and error long before he had words like specific impulse or oxidizer ratio for what he was doing.&lt;/p&gt;
&lt;p&gt;The materials weren&apos;t exotic. Potassium nitrate sold as stump remover. Sulfur and charcoal. Mix them correctly and you have black powder, the same oxidizer-fuel logic underlying every solid rocket motor ever built. More ambitious builders used potassium perchlorate from chemical suppliers, mixed with aluminum powder or sugar to control burn rate and energy density. All of it over the counter. All of it accessible to someone willing to read carefully and try things until they worked.&lt;/p&gt;
&lt;p&gt;He wasn&apos;t following a plan. He was just that kind of person.&lt;/p&gt;
&lt;p&gt;Most people have forgotten that the Air Force had its own space program before NASA existed. NASA was carved out of &lt;a href=&quot;https://en.wikipedia.org/wiki/National_Advisory_Committee_for_Aeronautics&quot;&gt;NACA&lt;/a&gt; in 1958, but the Air Force had been running parallel efforts since the mid-1950s. That generation had grown up on science fiction and wanted to see it happen. When Sputnik launched in October 1957 the country went into a low-grade panic about whether it understood physics well enough to survive, and suddenly the kids who had been dreaming about space since they could read had somewhere to go with it. What followed was one of the rare moments in American history when technical aptitude was a genuine class elevator. The government needed people who understood this stuff badly enough to find them wherever they were.&lt;/p&gt;
&lt;p&gt;He enlisted in his early twenties, aerospace degree in hand. The Air Force space program was what he was aiming at. He ended up working on attitude control thrusters for reconnaissance satellites, the kind that could resolve fine surface detail on Earth from hundreds of miles up. For that mission attitude control wasn&apos;t a secondary problem. It was the central one. A camera that can&apos;t hold still is useless. The thrusters are what made the intelligence possible. The underlying engineering was the same problem he had been teaching himself: oxidizer, fuel, combustion geometry, now controlled to tolerances that left no margin.&lt;/p&gt;
&lt;p&gt;I remember him watching a satellite reenter on the cable news when I was young. I don&apos;t know which one or exactly what year. What I remember is that he cried. He told me later there was a plate on that satellite with his name engraved on it. Work he had done, hardware he had touched, in orbit for years and now gone. Grief with no adequate audience, because the context was secret and the people who would have understood were scattered across programs that didn&apos;t officially exist.&lt;/p&gt;
&lt;p&gt;Years later my father was excited watching Iridium launch, Motorola&apos;s commercial satellite constellation, first launches 1997. The same fundamental technology, now accessible to anyone with a phone. His generation had figured out how to do this, quietly, under classification, and here it finally was in the open. The knowledge had propagated. Just not through the channels that were supposed to carry it.&lt;/p&gt;
&lt;p&gt;He kept a green chalkboard in the garage. He would pull out his slide rule and work through things with me. Orbital decay, thrust, specific impulse, delta-v, the rocket equation and why it makes everything harder than it looks. He had a worry he came back to often - society had forgotten how to go to the moon. The knowledge existed in aging engineers and partially classified documents and it was not being transmitted. The chalkboard was what he could do about that.&lt;/p&gt;
&lt;p&gt;Last year Destin Sandlin, an aerospace engineer who describes himself as a redneck from Alabama, &lt;a href=&quot;https://www.youtube.com/watch?v=OoJsPvmFixU&quot;&gt;walked into a room&lt;/a&gt; full of the most senior people in American space policy and did something worth an hour of your time to watch. He asked questions that people inside the institutional food chain had stopped asking. Starting with the most basic one: how many rockets does it take to fuel the Artemis lunar lander?&lt;/p&gt;
&lt;p&gt;The room went quiet. Nervous laughter. EPublic estimates have varied, but all point to a strikingly high number of launches and on-orbit refueling operations before a landing attempt depending on assumptions about boil-off and reuse, and nobody in the room had a confident answer.&lt;/p&gt;
&lt;p&gt;These are not uninformed people. &lt;strong&gt;A core operational parameter of their own mission architecture was not common knowledge among the people running it.&lt;/strong&gt;&lt;/p&gt;
&lt;p&gt;Then Destin asked the room a simpler question.&lt;/p&gt;
&lt;p&gt;&lt;em&gt;&quot;Is this the simplest solution?&quot;&lt;/em&gt;&lt;/p&gt;
&lt;p&gt;Silence.&lt;/p&gt;
&lt;p&gt;Destin pointed them at NASA SP-287, a document the Apollo engineers wrote and left behind specifically so the next generation wouldn&apos;t have to rediscover everything from scratch. The title is &quot;What Made Apollo a Success.&quot; It has been sitting there, public, for decades. Most of the people in that room had not read it.&lt;/p&gt;
&lt;p&gt;The principle at the center of that document is blunt:&lt;/p&gt;
&lt;blockquote&gt;
&lt;p&gt;&quot;Build it simple and then double up on as many components or systems so that if one fails, the other will take over.&quot;&lt;/p&gt;
&lt;/blockquote&gt;
&lt;p&gt;Simple first. Then redundant. Not complex and hoping.&lt;/p&gt;
&lt;p&gt;Simple isn&apos;t just aesthetic preference. &lt;strong&gt;Simple is how you keep the system inside your head.&lt;/strong&gt; Simple is how you build procedures all the way down to bolt cutters and still know what comes next. When a system gets complex enough that a room full of its leaders can&apos;t answer a basic operational question about it, it has exceeded the boundary of what they actually understand. They are &lt;a href=&quot;https://unmitigatedrisk.com/2026/02/youre-not-outsourcing-infrastructure-youre-outsourcing-capability/&quot;&gt;renting the complexity along with the capability&lt;/a&gt;.&lt;/p&gt;
&lt;p&gt;The Apollo engineers meant it literally. When designing the ascent stage separation, the mechanism that gets astronauts off the lunar surface, they didn&apos;t stop at one solution or two. They built redundancy on top of redundancy. Flip the switch. If that fails, go outside and trip the manual release. If that fails, depressurize, suit up, go to the bottom of the spacecraft with bolt cutters, and cut the straps holding the stages together. Harrison Schmitt said there was one more procedure after the bolt cutters. Nobody would say what it was.&lt;/p&gt;
&lt;p&gt;That&apos;s not genius. That&apos;s a chicken farmer&apos;s epistemology applied to the hardest engineering problem humans had ever attempted. You don&apos;t wait for perfect conditions or perfect knowledge. You start simple, you build every fallback you can think of, and then you think of one more.&lt;/p&gt;
&lt;p&gt;Destin argues that Artemis didn&apos;t follow that logic. The NRHO/Gateway architecture was publicly justified in part on communications, surface access, stability, and operational grounds, but Destin argues that it also reflects deeper architectural constraints that accumulated into a more complex solution. Destin&apos;s read, and he makes a detailed case for it, is that it&apos;s an architectural constraint dressed up as a design choice, complexity that accumulated because the real constraints couldn&apos;t be named publicly. A room full of program leaders who couldn&apos;t tell you the basic parameters of the system they were running.&lt;/p&gt;
&lt;p&gt;That&apos;s what happens when you lose the thread.&lt;/p&gt;
&lt;p&gt;Destin also interviewed an engineer who had worked on the lunar landing training vehicle, the machine that taught Apollo astronauts to land in one-sixth gravity by actually putting them in a vehicle where their life depended on getting it right. Destin asked whether the Apollo engineers were smarter than engineers today. The answer was no. What they had wasn&apos;t superior intelligence. It was a bias toward doing, toward simplicity, toward keeping the system inside human heads rather than delegating it to complexity they couldn&apos;t fully reason about.&lt;/p&gt;
&lt;p&gt;NASA SP-287 exists because those engineers understood something important. &lt;strong&gt;Capability doesn&apos;t survive on its own. Knowledge doesn&apos;t transmit automatically.&lt;/strong&gt; You have to codify it deliberately or it dies with the people who held it. It is ownership made explicit. Here is what we understood. Here is why it worked. Here is the playbook so the next generation doesn&apos;t have to rediscover it at the cost of lives.&lt;/p&gt;
&lt;p&gt;The space race created a machine for turning hands-on knowledge into national capability. It found people like my father wherever they were because it needed what they had already taught themselves. It was the on-ramp, the forcing function that pulled curiosity into programs that mattered and gave it somewhere to go. That same forcing function generated SP-287, the discipline to write it down, the institutional pressure to transmit it. When the race ended the machine stopped. The &lt;a href=&quot;https://unmitigatedrisk.com/2025/11/the-vanishing-on-ramp/&quot;&gt;on-ramp closed&lt;/a&gt;. The knowledge didn&apos;t vanish immediately. It aged out, program by program, engineer by engineer, panel by panel. What remained was credentials and institutional memory of having once known how, which is a different thing entirely from knowing how.&lt;/p&gt;
&lt;p&gt;We took that gift and built a lunar return architecture that, at least in its public form, often looks more operationally intricate than the Apollo playbook would have preferred. More complex architecture. Estimates ranging from eight to fifteen or more rockets just to fuel the lander. A room full of its leaders who hadn&apos;t read the playbook.&lt;/p&gt;
&lt;p&gt;&lt;em&gt;&quot;Is this the simplest solution?&quot;&lt;/em&gt;&lt;/p&gt;
&lt;p&gt;Silence.&lt;/p&gt;
&lt;p&gt;That&apos;s not an aerospace problem. That&apos;s the pattern. The knowledge transmission problem is older than aerospace. I&apos;ve been writing about it in other contexts for a while, starting &lt;a href=&quot;https://unmitigatedrisk.com/2025/10/llms-are-the-new-printing-press-why-im-optimistic-about-my-kids-future/&quot;&gt;here&lt;/a&gt;.&lt;/p&gt;
&lt;p&gt;My father spent my childhood pointing at this from a chalkboard in a garage. I didn&apos;t become an astronaut. That was his hope, not my path. The chalkboard worked anyway. The knowledge moved. The Iridium launches proved it. The knowledge his generation developed under classification eventually became infrastructure anyone could hold in their pocket. You can&apos;t fully control where it lands. You can only decide whether to try.&lt;/p&gt;
&lt;p&gt;Now AI is doing to software what the end of the space race did to aerospace. It is consuming the early career tasks that used to serve as scaffolding for building judgment. The debugging, the boilerplate, the routine iteration that taught tradeoffs and edge cases before anyone trusted you with the hard problems. The visible work disappears first. The tacit knowledge becomes unreachable just as it becomes most important. The &lt;a href=&quot;https://unmitigatedrisk.com/2025/11/the-vanishing-on-ramp/&quot;&gt;on-ramp closes&lt;/a&gt;. And at some point a room full of senior people goes quiet when someone asks a basic operational question, not because they&apos;re uninformed, but because the complexity was delegated before the understanding had time to form.&lt;/p&gt;
&lt;p&gt;That is the cautionary tale. Not that AI is bad. That capability outsourced before it is understood leaves you &lt;a href=&quot;https://unmitigatedrisk.com/2026/02/youre-not-outsourcing-infrastructure-youre-outsourcing-capability/&quot;&gt;renting decisions you don&apos;t control while keeping consequences you can&apos;t transfer&lt;/a&gt;. The room goes quiet. And eventually nobody even thinks to ask whether this is the simplest solution.&lt;/p&gt;
&lt;p&gt;My father saw it coming. That&apos;s what the chalkboard was for.&lt;/p&gt;
&lt;p&gt;The question isn&apos;t whether you work in aerospace or software. It&apos;s whether you&apos;ve stopped asking basic questions about the system you&apos;re running. Whether it has exceeded the boundary of what you actually understand. Whether you&apos;re renting complexity along with capability and calling it progress.&lt;/p&gt;
&lt;p&gt;You don&apos;t wait for perfect knowledge. You read every playbook you can find. You build redundancy all the way down to bolt cutters. And then you think of one more thing.&lt;/p&gt;
&lt;p&gt;The chemicals are still on the shelves. &lt;a href=&quot;https://ntrs.nasa.gov/api/citations/19720005243/downloads/19720005243.pdf&quot;&gt;SP-287&lt;/a&gt; is still public. The &lt;a href=&quot;https://www.youtube.com/watch?v=OoJsPvmFixU&quot;&gt;Destin talk&lt;/a&gt; is an hour of your time and worth every minute.&lt;/p&gt;
&lt;p&gt;Read the playbook.&lt;/p&gt;
</content:encoded><category>ai</category><category>technology</category><category>thoughts</category></item><item><title>The WebPKI and Client Authentication Are at a Crossroads</title><link>https://unmitigatedrisk.com/2026/03/the-webpki-and-client-authentication-are-at-a-crossroads/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/03/the-webpki-and-client-authentication-are-at-a-crossroads/</guid><description>The CA/Browser Forum is having its first serious conversation about whether publicly trusted client authentication certificates deserve their own Baseline Requirements. Nick France kicked off the discussion on the public…</description><pubDate>Sat, 21 Mar 2026 20:41:51 GMT</pubDate><content:encoded>&lt;p&gt;The CA/Browser Forum is having its first serious conversation about whether publicly trusted client authentication certificates deserve their own Baseline Requirements. Nick France kicked off the &lt;a href=&quot;https://groups.google.com/a/groups.cabforum.org/g/public/c/Kna_osq-6F8/m/d6CHaWjvAwAJ&quot;&gt;discussion on the public list&lt;/a&gt; last week, asking for concrete use cases, and the responses so far have been a useful window into how the industry thinks about this problem. Or rather, how it doesn&apos;t.&lt;/p&gt;
&lt;p&gt;The timing isn&apos;t accidental. Chrome Root Program Policy v1.6 is forcing a structural realignment of the WebPKI, and client authentication is caught in the middle. All PKI hierarchies in the Chrome Root Store must now be dedicated solely to TLS server authentication. Chrome stopped accepting new intermediate CA applications with mixed EKUs in June 2025, and by June 15, 2026, Chrome will distrust any newly issued leaf certificate containing clientAuth EKU from a Chrome Root Store hierarchy. Multi-purpose roots get phased out entirely. Mozilla, Apple, and Microsoft are all aligning with this direction. Every major public CA has published a sunset schedule. Sectigo stopped including clientAuth by default in September 2025, DigiCert followed in October, and Let&apos;s Encrypt is phasing it out through ACME profiles. By mid-2026, you will not be able to get a publicly trusted TLS certificate that also works for client authentication.&lt;/p&gt;
&lt;p&gt;This is the right call. The historical practice of stuffing both serverAuth and clientAuth into the same certificate, from the same hierarchy, created exactly the kind of entanglement that makes the WebPKI brittle. The SHA-1 migration is the canonical example. Payment terminals that relied on client auth from the same roots as server certs couldn&apos;t upgrade, holding back the entire transition for years. Today, Cisco Expressway is the poster child for the same problem, using a single certificate for both server and client auth in SIP mTLS connections and scrambling to decouple them before the deadline. Dedicated hierarchies for dedicated purposes. It&apos;s a principle the WebPKI should have enforced from the start.&lt;/p&gt;
&lt;h2&gt;What to do about it&lt;/h2&gt;
&lt;p&gt;What&apos;s emerging is a clearer, more honest WebPKI, but one with a gap that nobody is cleanly addressing. If you&apos;re currently relying on publicly trusted certificates for client authentication, the path forward depends on your use case.&lt;/p&gt;
&lt;p&gt;If the client auth is internal to your organization, VPN access, Wi-Fi onboarding, device authentication, mTLS between your own services, you should be moving to private PKI. This was always the right answer for internal use cases, and modern private CA solutions have made it far more practical than it used to be. You get full control over certificate profiles, lifetimes, and revocation without being subject to external root program policy changes. The blast radius of a private CA is contained to your organization, which is exactly what you want for internal trust.&lt;/p&gt;
&lt;p&gt;If the client auth is between your organization and a small number of known partners, like B2B API integrations or supply chain connections, private PKI still works well. You exchange trust anchors with your partners and configure your systems to trust their specific CA. This is how most of these integrations should have been built in the first place. The &quot;convenience&quot; of using publicly trusted certs for this was always a false economy, because you were accidentally opening your trust boundary to every entity that could buy a cert from the same CA.&lt;/p&gt;
&lt;p&gt;But if the client auth needs to work across organizational boundaries at scale, meaning you can&apos;t reasonably pre-configure trust anchors for every potential counterparty, this is where it gets interesting and where the current alternatives fall short. Private PKI doesn&apos;t solve this. You need some form of shared trust anchor, which is what public PKI provides for server authentication today. The question is whether a similar model can work for client authentication with properly scoped identifiers and validation methods.&lt;/p&gt;
&lt;h2&gt;The human identity case is the relatively easy part&lt;/h2&gt;
&lt;p&gt;On the CA/B Forum list, Sebastian Nielsen argued that public CAs shouldn&apos;t issue client auth certificates at all, pointing to the name collision problem. He makes a fair point, but the conclusion is too broad. I&apos;m Ryan Hurst the security practitioner, and there&apos;s also Ryan Hurst the actor (Remember the Titans, Sons of Anarchy). A public CA asserting &quot;Ryan Hurst&quot; in a DN doesn&apos;t help a relying party figure out which one of us is authenticating. The DN is a vestige of the X.500 global directory that never materialized. There is no global directory. Even local directories that correspond to DN structures don&apos;t exist in any meaningful density. Identity in the WebPKI belongs in the SAN, where we have identifiers that are both globally unique and reachable.&lt;/p&gt;
&lt;p&gt;S/MIME already handles the human case correctly. The rfc822Name in the SAN is at least unique at the time of issuance. More importantly, it&apos;s reachable. You can send a challenge to an email address and get a response. You can&apos;t send a challenge to a social security number. You can&apos;t send a challenge to &quot;Ryan Hurst, US.&quot; &lt;strong&gt;The broad intent of the WebPKI is to make things reachable in an authenticated way.&lt;/strong&gt; DNS names and email addresses fit that model. DNs do not.&lt;/p&gt;
&lt;p&gt;Even with email, there&apos;s a temporal problem. Addresses get reassigned, domains lapse, providers recycle accounts, and throwaway addresses exist by design. CAs can&apos;t monitor for reassignment, so these are inherently short-lived assertions. The certificate lifetime is the outer bound of your trust in that binding. Broader questions around PII and auditability are really about how &lt;a href=&quot;https://datatracker.ietf.org/doc/draft-ietf-keytrans-protocol/&quot;&gt;Key Transparency&lt;/a&gt; can be bolted into the ecosystem. I wrote about that &lt;a href=&quot;https://unmitigatedrisk.com/2023/12/the-rise-of-key-transparency-and-its-future-in-email-security/&quot;&gt;previously&lt;/a&gt;.&lt;/p&gt;
&lt;p&gt;There is valuable work happening in this space. Ballot SMC015v2 enabling mDLs and EU digital identity wallets for S/MIME identity proofing shows this evolving in a meaningful direction. Client authentication and signed email under S/MIME belong together. Apple has argued that emailProtection EKU should mean mandatory S/MIME BR compliance, closing the loophole where CAs omit email addresses from emailProtection certificates to avoid the BRs. I think that&apos;s the right direction. One nuance worth calling out though. S/MIME bundles signing, authentication, and encryption, and I think that&apos;s right for the first two but not the third. Signing and authentication are real-time assertions that work well as short-lived credentials. Encryption is different. The key is bound to an identifier that may not be durable, and without frequent rotation you risk &lt;a href=&quot;https://insecure.design/&quot;&gt;bygone-SSL style attacks&lt;/a&gt; where a new holder of an email address could access messages intended for the previous one. The encryption case deserves its own careful treatment around key lifecycle and rotation.&lt;/p&gt;
&lt;p&gt;Browsers are actively looking to remove client auth from TLS certificates, and I don&apos;t disagree given how poorly specified and unconstrained it has been. That signals whatever comes next needs to be much more tightly defined. The human client auth case is covered by S/MIME, browser-based client auth is on its way out for good reason, and a new working group doesn&apos;t need to revisit the human case.&lt;/p&gt;
&lt;h2&gt;The machine identity gap&lt;/h2&gt;
&lt;p&gt;Where it gets interesting is cross-organizational service-to-service authentication on the public internet. Today this is mostly handled with API keys, OAuth client credentials, or IP allowlisting, all with well-known limitations. mTLS with publicly trusted client certs could fill a real gap, but only if the identity model is built correctly.&lt;/p&gt;
&lt;p&gt;Many current uses of mTLS with publicly trusted client certs are misplaced. Organizations are often assuming a level of assurance they don&apos;t actually get when they accidentally cross security domains by relying on the public WebPKI for what is fundamentally a private trust relationship. A publicly trusted cert for &lt;code&gt;payments.example.com&lt;/code&gt; tells you that the entity controlling that domain authenticated, nothing more. It does not mean they are your trusted partner, your approved vendor, or anyone you intended to grant access to. &lt;strong&gt;Public trust gives you authenticated identity, not authorization.&lt;/strong&gt; Organizations that conflate the two will accidentally open up access based solely on someone having obtained a client cert. The examples collected on the list so far, Cisco Expressway and EPP, are mostly legacy compatibility problems being fixed. A working group built on those foundations would produce weak Baseline Requirements.&lt;/p&gt;
&lt;p&gt;The better foundation is the emerging need for authenticated service-to-service communication across organizational boundaries. Consider SMTP. Mail servers already authenticate to each other over the public internet using TLS, and MTA-STS is pushing that toward authenticated connections. The logical next step is mutual authentication, where the receiving mail server can cryptographically verify the sending server&apos;s identity, not just the other direction. SMTP and mTLS go together like peanut butter and jelly, but there&apos;s no clean way to do it with publicly trusted client certs today. Or consider vendor supply chains. If a manufacturer&apos;s procurement system needs to query a supplier&apos;s inventory API, or a logistics provider needs to authenticate to a retailer&apos;s fulfillment service, the options today are API keys, OAuth flows, or standing up an industry-specific trust framework just so machines can talk to each other. mTLS with publicly trusted client certs would let these systems authenticate directly, without building bespoke trust infrastructure for every partnership.&lt;/p&gt;
&lt;p&gt;And this need is accelerating beyond any single industry. As AI agents increasingly act as user agents on the open internet, calling APIs, negotiating with services, and transacting across organizational boundaries on behalf of users, mutual authentication between machines that have no pre-established trust relationship is becoming a practical necessity, not a theoretical concern. You can&apos;t pre-configure trust anchors for every service an agent might need to interact with any more than you can pre-configure them for every website a browser might visit. I &lt;a href=&quot;https://unmitigatedrisk.com/2026/02/agents-are-more-like-humans-than-workloads-heres-why-that-matters-for-identity/&quot;&gt;wrote about this dynamic previously&lt;/a&gt;, and the trajectory is clear. &lt;strong&gt;The machine-to-machine authentication problem on the open internet is starting to look a lot like the server authentication problem that the WebPKI was built to solve, just in both directions.&lt;/strong&gt;&lt;/p&gt;
&lt;p&gt;For machines, the name collision problem largely disappears. DNS names are globally unique by design. A client cert with a dNSName SAN of &lt;code&gt;payments-api.example.com&lt;/code&gt; or &lt;code&gt;registry-client.registrar.example.net&lt;/code&gt; doesn&apos;t have an ambiguity problem. The relying party knows exactly what organization controls that name. Nick&apos;s original question on the list asked about what parts of the DN the relying party verifies. I&apos;d argue that&apos;s almost the wrong framing. There is no global X.500 directory. The question should be, what SAN types are needed, and what validation methods can we define for them?&lt;/p&gt;
&lt;p&gt;For straightforward service identification, dNSName works today with no new validation methods needed.&lt;/p&gt;
&lt;ul&gt;
&lt;li&gt;&lt;code&gt;payments-api.example.com&lt;/code&gt;&lt;/li&gt;
&lt;li&gt;&lt;code&gt;erp-connector.supplier.example.net&lt;/code&gt;&lt;/li&gt;
&lt;li&gt;&lt;code&gt;registry-client.registrar.example.com&lt;/code&gt;&lt;/li&gt;
&lt;/ul&gt;
&lt;p&gt;For more expressive service identification, uniformResourceIdentifier SANs encode not just the organization but the specific service.&lt;/p&gt;
&lt;ul&gt;
&lt;li&gt;&lt;code&gt;https://example.com/services/payments&lt;/code&gt;&lt;/li&gt;
&lt;li&gt;&lt;code&gt;urn:example:service:billing:v2&lt;/code&gt;&lt;/li&gt;
&lt;/ul&gt;
&lt;p&gt;This URI-based approach isn&apos;t speculative. SPIFFE already uses URI SANs (&lt;code&gt;spiffe://cluster.local/ns/production/sa/checkout&lt;/code&gt;) to represent service identities in Kubernetes mTLS contexts. The pattern is proven and widely deployed within private PKI. Extending it to public trust for cross-organizational federation is a natural evolution of an approach the industry has already validated. URI SANs can be validated through &lt;code&gt;.well-known&lt;/code&gt; challenge methods (like ACME HTTP-01 scoped to a URI path) and ALPN-based methods, extending battle-tested ACME-era infrastructure rather than building from X.500-era assumptions.&lt;/p&gt;
&lt;h2&gt;What the industry is doing instead&lt;/h2&gt;
&lt;p&gt;Almost all the CA and vendor messaging right now says &quot;move to private PKI.&quot; That&apos;s the right answer for internal use cases, but it doesn&apos;t address cross-organizational trust. The most interesting alternative emerging is the DigiCert X9 PKI, launched in partnership with ASC X9, the financial standards body. X9 PKI is a completely independent trust framework, governed by X9&apos;s policy committee rather than the CA/Browser Forum or browser root programs. It supports both clientAuth and serverAuth EKUs, uses a common root of trust for cross-organizational interoperability, and is WebTrust audited. It&apos;s specifically designed for the financial sector&apos;s mTLS needs, though they&apos;re expanding to other sectors.&lt;/p&gt;
&lt;p&gt;X9 PKI is essentially a &quot;public PKI that isn&apos;t the WebPKI&quot; for service-to-service auth. It validates the premise that there&apos;s a real need for cross-organizational client authentication with a shared trust anchor. But it&apos;s sector-specific and governed outside the CA/Browser Forum, which means it doesn&apos;t solve the general case. The EU&apos;s eIDAS QWAC framework is another sector-specific approach. These are workarounds for the absence of a general-purpose, properly scoped public client auth certificate type.&lt;/p&gt;
&lt;h2&gt;If this moves forward&lt;/h2&gt;
&lt;p&gt;I&apos;m not advocating for or against a working group at the CA/Browser Forum. But if the Forum does decide to take this on, the scope needs to be narrow IMHO. Machine and service client auth only, with identity in the SAN using dNSName and uniformResourceIdentifier. DN fields should not be relied upon for authentication decisions. Validation methods should build on existing domain control mechanisms. Human client auth stays in S/MIME where it belongs. The BRs should address the authentication versus authorization distinction explicitly, so relying parties understand that a publicly trusted client cert tells them who is connecting, not whether that entity should be granted access. This is already how server certificates work, and client auth should follow the same model. And the issuing CAs need to be dedicated, separate from server auth hierarchies. The SHA-1 payment terminal debacle, the Cisco Expressway mess. Every time client and server auth are entangled in the same hierarchy, one use case holds back progress on the other. Don&apos;t repeat that.&lt;/p&gt;
&lt;h2&gt;The bigger picture&lt;/h2&gt;
&lt;p&gt;What we&apos;re watching is a structural realignment of the WebPKI&apos;s purpose. The WebPKI is being narrowed to mean &quot;TLS server authentication for web browsers,&quot; full stop. Everything else, client auth, S/MIME, code signing, is being pushed to dedicated hierarchies, private PKI, or alternative trust frameworks. That&apos;s mostly the right direction. But the service-to-service authentication gap is real, growing, and not well served by any of the current alternatives. Private PKI doesn&apos;t solve cross-organizational trust. X9 PKI is sector-specific. The CA/Browser Forum has the institutional knowledge, the validation infrastructure, and the trust framework to define something that works here. Whether they choose to is another question.&lt;/p&gt;
&lt;p&gt;The conversation is happening now on the &lt;a href=&quot;https://groups.google.com/a/groups.cabforum.org/g/public/c/Kna_osq-6F8/m/d6CHaWjvAwAJ&quot;&gt;public list&lt;/a&gt;. If you have concrete use cases for cross-organizational service authentication with publicly trusted client certificates, this is the time to share them. The shape of what comes next depends on whether the use cases justify the effort, and right now the list is thin.&lt;/p&gt;
</content:encoded><category>ai</category><category>certificates</category><category>security</category><category>thoughts</category></item><item><title>Introducing the WebPKI Observatory</title><link>https://unmitigatedrisk.com/2026/03/introducing-the-webpki-observatory/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/03/introducing-the-webpki-observatory/</guid><description>For as long as I have been in this industry, the WebPKI compliance conversation has run on impressions. People with long memories and regular conference attendance have built up a picture of which CAs are well-run, which…</description><pubDate>Sun, 15 Mar 2026 09:34:47 GMT</pubDate><content:encoded>&lt;p&gt;For as long as I have been in this industry, the WebPKI compliance conversation has run on impressions. People with long memories and regular conference attendance have built up a picture of which CAs are well-run, which are struggling, and where the oversight gaps are. That picture has generally been accurate. It has also been almost entirely unmeasured.&lt;/p&gt;
&lt;p&gt;The WebPKI Observatory at &lt;a href=&quot;http://webpki.systematicreasoning.com&quot;&gt;webpki.systematicreasoning.com&lt;/a&gt;, a project from Systematic Reasoning, is an attempt to change that. It&apos;s a public dashboard covering 1,690 compliance incidents drawn from Mozilla Bugzilla between 2014 and 2025, cross-referenced with CCADB membership data, certificate issuance volumes from CT logs, root program trust store compositions, and the complete history of CA distrust events. The goal was simple: replace the shared intuition with actual data, and see what the data shows that intuition missed.&lt;/p&gt;
&lt;p&gt;Some of it confirmed what most people in this space already suspected. Some of it was genuinely surprising.&lt;/p&gt;
&lt;p&gt;The finding that reframes everything else is detection. When a compliance incident occurs, who finds it? Root programs find 52% of incidents. Automated external tools — CT log monitors, certificate linters, community scanning infrastructure — find 14%. CAs find their own problems in 9% of cases.&lt;/p&gt;
&lt;p&gt;That number deserves more attention than it typically gets. One in eleven. CAs have full access to their own issuance systems, their own audits, their own CPSs, their own disclosure obligations, and they are the least effective detection mechanism in the ecosystem. External parties without any privileged access outperform internal CA monitoring by a factor of six or more. &lt;strong&gt;The compliance monitoring function has been effectively outsourced to external parties by default, and mostly without anyone deciding that was the right architecture.&lt;/strong&gt;&lt;/p&gt;
&lt;p&gt;Everything else in the data follows from that.&lt;/p&gt;
&lt;p&gt;The failure classes that have grown are instructive. Technical misissuance has declined as a share of incidents over the past decade. What has grown is the process layer. In 2019, governance failures represented 21% of all incidents. By 2025 that figure was 60%. Policy violations, CPS failures, disclosure deadline misses. These are by definition things internal compliance programs should be catching. The 260 incidents tagged policy-failure or disclosure-failure in the dataset are a direct indictment of internal compliance operations. A CA that violates its own documented policy is not being surprised by an external attacker.&lt;/p&gt;
&lt;p&gt;The oversight picture is also worth examining. In 2017, Mozilla engaged with 79% of Bugzilla compliance bugs. Chrome had no formal root program yet and was near zero. By 2025 the picture had reversed and degraded simultaneously. Chrome now contributes the dominant share of oversight engagement but covers only 18% of incidents. Mozilla covers 8%. The total corpus has roughly doubled since 2017 while combined meaningful oversight coverage has fallen by two-thirds. The Chrome Root Program launched in 2021, and its effect on the governance landscape is visible in the data — Chrome has made 239 substantive oversight comments in recent years versus Mozilla&apos;s 158 over the same period. The center of gravity in CA compliance governance has shifted to the browser with 78% market share. That is structurally significant. Microsoft, which operates the largest trust store by root count at 346 trusted roots, has made zero recorded governance comments across all 1,690 incidents spanning 11 years.&lt;/p&gt;
&lt;p&gt;The distrust history is also clarifying. The common mental model is that CAs get removed for catastrophic technical failures. The data does not support that model. 14 of 16 distrust events involve compliance operations failures. The behavioral taxonomy matters, negligent noncompliance, willful circumvention, demonstrated incompetence, and argumentative noncompliance. In 10 of the 16 cases, the distrust event was preceded by a documented pattern of prior incidents. The median runway from the first incident to distrust is 3.2 years. The failures were not hidden. They were in Bugzilla the whole time. The CA just was not resolving them systematically.&lt;/p&gt;
&lt;p&gt;That means distrust is largely predictable given sufficient data. The indicators show up well before the outcome. That is a sobering observation about past oversight and a useful one for anyone thinking about what the compliance monitoring function should actually do.&lt;/p&gt;
&lt;p&gt;The Observatory is a measurement tool, not a verdict. The dataset has limits — Bugzilla under-represents incidents that never reach public disclosure, CT-derived issuance volumes reflect only unexpired certificates at the time of measurement, and the behavioral taxonomy applied to distrust events involves judgment calls. But the patterns are robust enough to be useful.&lt;/p&gt;
&lt;p&gt;For CA operators, the detection data alone should prompt hard questions about internal monitoring coverage. For root programs, the oversight gap data quantifies a scaling problem that is currently being absorbed by Chrome without anyone having explicitly decided that is the right architecture. For the policy community, the shift from technical to governance failures as the dominant incident class has direct implications for what audit frameworks should actually measure.&lt;/p&gt;
&lt;p&gt;The dashboard is live at &lt;a href=&quot;http://webpki.systematicreasoning.com&quot;&gt;webpki.systematicreasoning.com&lt;/a&gt;, updated daily. The methodology is documented. Pull requests are welcome&lt;/p&gt;
</content:encoded><category>ai</category><category>security</category><category>thoughts</category></item><item><title>Signed, Auditable, Offline-Tolerant, PQ Secure QR Codes</title><link>https://unmitigatedrisk.com/2026/03/signed-auditable-offline-tolerant-pq-secure-qr-codes/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/03/signed-auditable-offline-tolerant-pq-secure-qr-codes/</guid><description>Signed, Auditable, Offline-Tolerant, PQ Secure QR Codes</description><pubDate>Sat, 14 Mar 2026 19:13:24 GMT</pubDate><content:encoded>&lt;p&gt;&lt;strong&gt;Signed, Auditable, Offline-Tolerant, PQ Secure QR Codes&lt;/strong&gt;&lt;/p&gt;
&lt;p&gt;A few months ago I wrote about &lt;a href=&quot;https://unmitigatedrisk.com/2025/01/what-makes-a-qr-code-verifiable/&quot;&gt;what it would take to make a QR code verifiable in a post quantum world&lt;/a&gt;. In this post I wanted to explore what it would look like if we wanted one that is genuinely verifiable, not just signed, but auditable, offline-tolerant, and ready for a post-quantum world. That post was mostly conceptual. A conversation with Bruno Couillard last week nudged me to put down the thoughts I had been carrying about exactly that.&lt;/p&gt;
&lt;p&gt;The design draws heavily on the draft for Merkle Tree Certificates, which is working through the IETF right now. MTC is aimed at TLS, but the core insight is that you can replace per-certificate signatures with compact Merkle inclusion proofs against a periodically updated signed root, and that insight translates directly to QR codes once you think carefully about the offline constraint. If you haven&apos;t read it, the draft is at &lt;a href=&quot;https://datatracker.ietf.org/doc/draft-davidben-tls-merkle-tree-certs&quot;&gt;datatracker.ietf.org/doc/draft-davidben-tls-merkle-tree-certs&lt;/a&gt;.&lt;/p&gt;
&lt;p&gt;The result of applying that idea to the QR problem is MTA-QR, a working implementation of what I&apos;ve been calling Merkle Tree Assertions for QR codes. The demo is live at &lt;a href=&quot;https://mta-qr.peculiarventures.com&quot;&gt;mta-qr.peculiarventures.com&lt;/a&gt;, and the full source is at &lt;a href=&quot;https://github.com/PeculiarVentures/mta-qr-demo&quot;&gt;github.com/PeculiarVentures/mta-qr-demo&lt;/a&gt;. There are Go and TypeScript implementations, a browser-only demo that generates and verifies without any backend, and an interoperability test matrix that exercises all three signing algorithms against both runtimes in every combination.&lt;/p&gt;
&lt;p&gt;To be clear, this isn&apos;t a production-ready library, but building it helped me identify things I had missed while whiteboarding it in my head.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;The size problem is real but solvable&lt;/strong&gt;&lt;/p&gt;
&lt;p&gt;The original post flagged signature size as the central constraint. An ML-DSA-44 signature is 2,420 bytes. A Version 40 QR code at medium ECC holds about 1,273 usable bytes. Those two numbers don&apos;t fit in the same sentence without a solution.&lt;/p&gt;
&lt;p&gt;The solution is separating what goes in the QR from what you need to verify it. The QR carries the assertion content, a Merkle inclusion proof, and coordinates pointing to a signed checkpoint. The checkpoint itself contains the issuer signature, lives outside the QR, and gets cached on the verifier&apos;s device, typically during a charge cycle before the device ever sees a QR code. Once cached, verification is fully offline.&lt;/p&gt;
&lt;p&gt;The proof is the interesting part. A two-level tiled Merkle tree, with an inner batch tree and an outer parent tree, caps the total proof at eight hashes regardless of how large the log grows. Eight hashes is 256 bytes. That&apos;s the ceiling, forever. The QR version stays fixed. The code never gets denser as the issuer accumulates millions of entries.&lt;/p&gt;
&lt;p&gt;In practice, a Mode 1 QR carrying bearer claims and a Merkle inclusion proof fits comfortably within a Version 10 to 15 code at medium ECC, well under 500 bytes total. ML-DSA-44 doesn&apos;t appear in the QR at all. The issuer signature lives in the checkpoint that the verifier fetched during its last charge cycle.&lt;/p&gt;
&lt;p&gt;ML-DSA-44 won&apos;t fit in a single QR in Mode 0, the fully embedded mode where the signature is in the QR itself. Mode 0 is the bootstrap mode: it works on air-gapped verifiers, on paper QR codes printed before any checkpoint infrastructure exists, and for scenarios where prefetch is operationally impractical. It&apos;s not a niche failure case; it&apos;s the starting condition for any new deployment. Mode 0 with PQC will require waiting for NIST to finalize smaller-signature algorithms, or accepting larger QR codes. Mode 1 is the practical path to PQC today.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Offline tolerance is mostly a framing problem&lt;/strong&gt;&lt;/p&gt;
&lt;p&gt;There&apos;s a habit of treating offline verification as binary, either the device has connectivity at scan time, or it doesn&apos;t. That framing creates a false constraint.&lt;/p&gt;
&lt;p&gt;Every verifier with a battery has a window where it is stationary, connected, and idle. That&apos;s when it charges. Fetching a checkpoint during a charge cycle is trivially cheap compared to everything else happening during that window. The relevant question isn&apos;t whether the device has connectivity at scan time. It&apos;s whether the assertion being scanned was issued before the verifier&apos;s last checkpoint fetch.&lt;/p&gt;
&lt;p&gt;For the common case, the answer is yes. A concert ticket issued last week, a prescription filled this morning, a badge issued at enrollment, all of these predate the verifier&apos;s cached checkpoint by hours or days. Verification is fully offline because the relevant checkpoint was already there.&lt;/p&gt;
&lt;p&gt;The narrow failure case is an assertion issued and scanned within the same charge cycle, before any checkpoint fetch. That falls back to a single cache-miss network call, which then covers every subsequent scan of the same batch. One round trip, then fully offline for the rest of the operational period.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Witnessing is where the transparency guarantee actually lives&lt;/strong&gt;&lt;/p&gt;
&lt;p&gt;The issuer&apos;s signature proves the assertion came from a specific key. That&apos;s useful, but it doesn&apos;t prevent a compromised issuer from presenting different views of the log to different verifiers. Split-view attacks are subtle and hard to detect after the fact.&lt;/p&gt;
&lt;p&gt;Witnesses solve this. A witness cosigns a checkpoint only after verifying it extends the previous one they saw, establishing a consistency guarantee across the full history of the log. Once multiple independent witnesses have cosigned a checkpoint, the issuer cannot retroactively rewrite or fork the log without those witnesses catching it.&lt;/p&gt;
&lt;p&gt;The witness protocol comes from &lt;a href=&quot;https://c2sp.org/tlog-cosignature&quot;&gt;c2sp.org/tlog-cosignature&lt;/a&gt;, the same infrastructure underpinning the &lt;a href=&quot;https://transparency.dev&quot;&gt;transparency.dev&lt;/a&gt; witness network. I worked on that witness network during my time at Google, so it was never far from my mind when designing this. Connecting MTA-QR to it means the issuance of every assertion can be monitored by parties with no relationship to the issuer. That&apos;s the difference between a signed QR and an auditable one.&lt;/p&gt;
&lt;p&gt;The implementation uses Ed25519 for witness cosignatures regardless of what algorithm the issuer uses for checkpoints. That&apos;s not a design choice I made, it&apos;s what the spec requires. It means an issuer can use ML-DSA-44 for the checkpoint signature while the witness infrastructure stays on stable, widely deployed Ed25519 keys. The two concerns are separated cleanly, and that separation matters. The quantum threat to the issuer signature and the operational threat to the witness network are different problems on different timelines.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;What I had wrong in the original post&lt;/strong&gt;&lt;/p&gt;
&lt;p&gt;The earlier post mentioned UOV and SQISign as especially promising for QR codes because of their smaller signature sizes. That framing isn&apos;t wrong exactly; smaller signatures do help with the size constraint, and both algorithms are genuinely interesting work. But the NIST competition covering them isn&apos;t finished, which means neither is practical for anything you&apos;d want to deploy or standardize against today. More importantly, once you separate the checkpoint from the payload, signature size matters only for the checkpoint, which isn&apos;t size-constrained anyway. The Merkle structure removes the problem that UOV and SQISign were addressing. They may still have a role in Mode 0 once the standards are settled, but they&apos;re not the lever that makes the design work.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;What&apos;s still missing&lt;/strong&gt;&lt;/p&gt;
&lt;p&gt;The spec has a revocation mechanism based on index ranges that a verifier checks at scan time, but the format for distributing and authenticating those revocation lists isn&apos;t fully defined yet. This is the most operationally significant open item. An unsigned revocation list is vulnerable to a stale-list attack at the network layer. An adversary who can delay or suppress list delivery can extend the validity of a revoked assertion. The natural fix is issuer-signed lists using the same key that signs checkpoints, but that format isn&apos;t written yet. Until it is, revocation is a weak link in any deployment that takes revocation seriously.&lt;/p&gt;
&lt;p&gt;Type 0x02 key assertions, where the QR proves possession of a private key rather than just embedding bearer claims, are defined in the log entry format but the challenge-response protocol isn&apos;t specified. Two implementations can&apos;t interoperate on key assertions without it.&lt;/p&gt;
&lt;p&gt;The &lt;a href=&quot;https://c2sp.org/tlog-checkpoint&quot;&gt;C2SP tlog-checkpoint format&lt;/a&gt; needs registrations for ECDSA and ML-DSA before those algorithms can interoperate with standard tlog-checkpoint parsers. Ed25519 is fully specified today. ECDSA and ML-DSA work in the reference implementation but aren&apos;t interoperable with external tooling yet. This is a practical blocker for adoption by anyone not using the reference implementation, and it&apos;s the right next conversation to have with the C2SP and MTC communities.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Try it&lt;/strong&gt;&lt;/p&gt;
&lt;p&gt;The browser demo runs entirely in-page with no backend. It generates Ed25519 or ML-DSA-44 keys in your browser, issues assertions, builds the Merkle tree, produces QR codes, and runs the full 15-step verification trace. The tamper panel lets you flip proof bytes, corrupt the TBS, zero the proof, or truncate the payload, and watch exactly which verification step catches each failure. It&apos;s a useful way to build intuition for what the protocol is actually checking and why each step is there.&lt;/p&gt;
&lt;p&gt;The repo is at &lt;a href=&quot;https://github.com/PeculiarVentures/mta-qr-demo&quot;&gt;github.com/PeculiarVentures/mta-qr-demo&lt;/a&gt;. Pull requests welcome, especially on the open items.&lt;/p&gt;
</content:encoded><category>security</category><category>technology</category><category>thoughts</category></item><item><title>When Compliance Records Become the Only Honest Signal</title><link>https://unmitigatedrisk.com/2026/03/when-compliance-records-become-the-only-honest-signal/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/03/when-compliance-records-become-the-only-honest-signal/</guid><description>I&apos;ve been spending a lot of time lately building Systematic Reasoning with my long-time friend Vishal. The core premise is straightforward. Organizations reveal their true operational character through how they design to…</description><pubDate>Mon, 09 Mar 2026 06:31:27 GMT</pubDate><content:encoded>&lt;p&gt;I&apos;ve been spending a lot of time lately building &lt;a href=&quot;http://SystematicReasoning.com&quot;&gt;Systematic Reasoning&lt;/a&gt; with my long-time friend Vishal. The core premise is straightforward. Organizations reveal their true operational character through how they design to prevent failure, how they plan to handle it when it happens, and how they actually do. That signal deserves to be tracked, structured, and acted on. We&apos;re building an agentic compliance platform to do exactly that.&lt;/p&gt;
&lt;p&gt;Systematic Reasoning won&apos;t be limited to any single domain, but we decided to start with the Web PKI. The reasoning was simple. It&apos;s high impact in a way that&apos;s hard to overstate. Every internet user depends, whether they know it or not, on a relatively small number of Certificate Authorities getting things right. The margin for error is zero. If that trust layer breaks, it breaks for everyone.&lt;/p&gt;
&lt;p&gt;DigiNotar is the canonical example. A small Dutch CA, compromised so thoroughly that attackers could impersonate any website on the web, and did. That capability was used to spy on Iranian dissidents, intercepting communications that people believed were private and secure. The trust infrastructure that was supposed to protect them was turned into a weapon against them. DigiNotar isn&apos;t an edge case or a cautionary tale from a more naive era; it&apos;s a demonstration of the actual ceiling of what can go wrong. And it isn&apos;t the only one. State-affiliated certificate authorities have been caught performing man-in-the-middle attacks on their own citizens&apos; traffic, something the Baseline Requirements explicitly prohibit, but prohibition only matters if it&apos;s enforced. The web&apos;s trust model works right up until the moment someone decides it&apos;s more useful as surveillance infrastructure.&lt;/p&gt;
&lt;p&gt;At the core of Systematic Reasoning, is a belief I&apos;ve held for a while. Compliance can be a vital sign of organizational security, but only if it&apos;s continuous. The reality today is that it isn&apos;t. Code ships daily. Audits happen annually. The gap between those two rhythms is where things go quietly wrong.&lt;/p&gt;
&lt;p&gt;I&apos;ve written before about why I have limited faith in the current audit regime. Auditors are engaged by the organizations they assess. Their product is a clean seal; their incentive is to keep the client. They operate on point-in-time sampling with auditee-selected scope, and they&apos;re often compliance professionals rather than engineers, which means they&apos;re checking whether a policy exists more than whether the system actually behaves correctly. That&apos;s if you&apos;re lucky. Sometimes the audit is scoped against a version of the Baseline Requirements that was superseded over a year ago.&lt;/p&gt;
&lt;p&gt;The same incentive shapes how certificate authorities write their governance documents. A CP/CPS that relies heavily on incorporation by reference, that omits specifics about what the organization actually does and what constraints it operates under, is easier to audit against than one that makes precise, testable commitments. Vagueness isn&apos;t always carelessness. Sometimes it&apos;s a design choice. The same thing happens in incident reports. A report that attributes a failure to &quot;organic process evolution&quot; or &quot;human error&quot; without describing the actual control gap is easier to close than one that names the broken system and commits to a specific fix. In both cases the document gets the box checked without creating accountability. References establish authority. Commitments establish accountability.&lt;/p&gt;
&lt;p&gt;The audit gap isn&apos;t compensated for by strong internal monitoring either. The majority of significant compliance failures are not caught internally. They are caught by external researchers, root program staff, or community tooling. A broken validation endpoint runs for five years and the organization finds out because someone posted a 404 error in a public issue tracker. A validation race condition exists undetected for seven and a half years not because it was well hidden but because nobody was looking. The absence of an internal alarm is not evidence that the system is healthy. It is often evidence that the monitoring itself is missing.&lt;/p&gt;
&lt;p&gt;So public incident reports and governance documents become some of the most signal-rich material available. Policy documents tell you what an organization claims it will do. Incident reports tell you what happened when reality diverged from that claim. Together they create a longitudinal picture that neither document produces alone.&lt;/p&gt;
&lt;p&gt;Building a system to reason over that data surfaced a problem I didn&apos;t fully anticipate. When you&apos;re working from the outside, with no access to internal systems and no way to verify what actually changed, the public record is almost all you have. The question isn&apos;t whether to treat it with skepticism. It&apos;s how much skepticism to build in by default.&lt;/p&gt;
&lt;p&gt;The temptation is to give the benefit of the doubt. Organizations are required to describe the blast radius of an incident. Not every localized bug is a symptom of something systemic. But accepting minimizing language at face value is its own failure.&lt;/p&gt;
&lt;p&gt;&quot;Only&quot; is doing a lot of work when the bug it&apos;s describing went undetected for seven and a half years. &quot;No compromise of end-entities&quot; is doing a lot of work when what it really means is that nobody found the gap before you did. Framing survival as security isn&apos;t reporting, it&apos;s PR. And if an organization believes an incident is no big deal, you can predict with reasonable confidence that the root cause analysis will be shallow and the remediation will be a band-aid.&lt;/p&gt;
&lt;p&gt;ForgeIQX, our first offering, tracks those signals longitudinally across both policy documents and incident reports. Not to prosecute organizations for their language choices, but to notice when a commitment made in a CP/CPS quietly disappears in the next version, or when a promised fix is nowhere to be found when the same failure mode surfaces years later. That&apos;s commitment decay, the slow evaporation of a promise made under pressure, and it&apos;s only visible if you&apos;re tracking across multiple documents and incidents over time rather than treating each one in isolation.&lt;/p&gt;
&lt;p&gt;The calibration problem is real and doesn&apos;t have a clean answer. Get it wrong in one direction and you build a system that cries wolf. Get it wrong in the other and you build a system that launders PR-speak into clean signals, which is just automating the thing we already do too much of.&lt;/p&gt;
&lt;p&gt;There&apos;s a third failure mode that took me longer to see. A system like this can be gamed. Swap &quot;we got lucky&quot; for &quot;our monitoring detected no active exploitation.&quot; Replace &quot;only thirty certificates&quot; with a more clinical impact scoping statement that says the same thing in language that sounds like engineering rigor. The words change; the institutional posture doesn&apos;t. A system that can be satisfied by better prose isn&apos;t measuring operational maturity, it&apos;s measuring communications sophistication.&lt;/p&gt;
&lt;p&gt;That means the system has to be built with structural pessimism. Not cynicism for its own sake, but a deliberate prior that clean language is not the same as clean operations, and that the absence of red flags is not the same as the presence of green ones. We can&apos;t verify that an organization fixed what it said it would fix. What we can do is watch whether the same failure mode surfaces again and whether the pattern of shallow root cause analyses continues or breaks. The historical record doesn&apos;t tell us what&apos;s true inside these organizations. It tells us what they were willing to say in public, under pressure, over time. Given the alternatives, that may be the most honest signal available.&lt;/p&gt;
&lt;p&gt;A certificate authority with genuine operational maturity should want this kind of scrutiny applied to itself. Not because it will always produce a clean result, but because it surfaces the gaps before an external party does. ForgeIQX gives organizations a way to continuously monitor their own compliance posture, so their practices and code keep pace with their commitments. The same is true for auditors who want their findings to mean something beyond a checkbox. The problem with the current regime isn&apos;t that the people in it are careless. It&apos;s that the incentive structures don&apos;t reward rigor, and the tooling to demonstrate it continuously doesn&apos;t exist. That&apos;s what we&apos;re building.&lt;/p&gt;
&lt;p&gt;The Web PKI is where we started because the stakes are concrete and the public record is unusually rich. But any regulated industry where compliance is measured annually, where governance documents are written to satisfy auditors rather than inform relying parties, and where incident reports are drafted with one eye on legal exposure, has the same gap between what the paper says and what the organization actually does. We started here. We don&apos;t intend to stop here.&lt;/p&gt;
</content:encoded><category>ai</category><category>startups</category><category>thoughts</category></item><item><title>The Signal They Chose to Ignore</title><link>https://unmitigatedrisk.com/2026/02/the-signal-they-chose-to-ignore/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/02/the-signal-they-chose-to-ignore/</guid><description>Two prior posts worked through the statistics of the SB 6346 sign-in data. In the first I established the methodology and the finding. After applying a birthday-corrected collision test to separate organic participation…</description><pubDate>Thu, 26 Feb 2026 00:13:45 GMT</pubDate><content:encoded>&lt;p&gt;Two prior posts worked through the statistics of the &lt;a href=&quot;https://app.leg.wa.gov/BillSummary/?BillNumber=6346&amp;amp;Year=2025&amp;amp;Initiative=false&quot;&gt;SB 6346&lt;/a&gt; sign-in data. In &lt;a href=&quot;https://unmitigatedrisk.com/2026/02/the-data-doesnt-support-the-narrative/&quot;&gt;the first&lt;/a&gt; I established the methodology and the finding. After applying a birthday-corrected collision test to separate organic participation from anomalous windows, roughly 90,000 legitimate CON participants remain against roughly 9,100 legitimate PRO participants. In &lt;a href=&quot;https://unmitigatedrisk.com/2026/02/duplicates-are-not-the-problem/&quot;&gt;the second&lt;/a&gt; I addressed the legislature&apos;s claim that duplicate names make the dataset unreliable. The finding runs the other way. A genuine sample drawn from a real community produces name collisions at a predictable rate. People share surnames, people hit submit twice, households have two people with the same name. The PRO overnight batch produced zero collisions across 934 draws, where the statistical minimum expected is around 30. The anomaly is suspicious precisely because it has too few duplicates, not too many. Real participation is messy. This was not.&lt;/p&gt;
&lt;p&gt;This post is not about those results. It is about what legislators said about them at a &lt;a href=&quot;https://tvw.org/video/legislative-democratic-leaders-media-availability-2026021344/?eventID=2026021344&quot;&gt;February 24 media availability&lt;/a&gt;, and whether their positions are statistically defensible.&lt;/p&gt;
&lt;p&gt;They are not.&lt;/p&gt;
&lt;h2&gt;The Math Problem With &quot;Not Helping Us Make Decisions&quot;&lt;/h2&gt;
&lt;blockquote&gt;
&lt;p&gt;&quot;It&apos;s not like we are making decisions not to pass a bill because of a sign in... they&apos;re not really helping us make decisions in terms of amendments to bills or whether to pass it out of committee or not. We rely on people who actually come and testify in person.&quot;&lt;/p&gt;
&lt;p&gt;— Senator Manka Dhingra, &lt;a href=&quot;https://tvw.org/video/legislative-democratic-leaders-media-availability-2026021344/?eventID=2026021344&quot;&gt;February 24 media availability&lt;/a&gt;&lt;/p&gt;
&lt;/blockquote&gt;
&lt;p&gt;That is a statistical claim. It asserts that the sign-in data has no decision-relevant information. For that to be true, one of two things must hold. Either the signal is too noisy to be meaningful, or legislators have better information that makes it redundant.&lt;/p&gt;
&lt;p&gt;Neither holds.&lt;/p&gt;
&lt;p&gt;The 10:1 ratio across 90,000 legitimate responses is not ambiguous. The margin of error at that sample size is roughly a third of a percentage point. The ratio does not wobble under any standard statistical treatment. Even applying the most aggressive self-selection correction anyone has proposed, assuming CON participants are twice as motivated to engage as PRO participants, the adjusted ratio is still 5:1. The signal does not disappear. Calling it noise is not a statistical judgment. It is a refusal to do the math.&lt;/p&gt;
&lt;p&gt;As for better information, what would that be? Testimony at a two-hour hearing. Phone calls. Letters. The intuitions of members who have held their seats for multiple cycles. None of those are more statistically rigorous than 90,000 data points. Most are orders of magnitude less rigorous. If a senator&apos;s read of the room outweighs a dataset this large at a ratio this clear, that is not superior methodology. That is substituting anecdote for evidence.&lt;/p&gt;
&lt;p&gt;Dhingra&apos;s preferred alternative, people who show up in person, has its own problem. The photo below is from the February 6 Senate hearing. The room is full of people in matching purple shirts and teal sashes. That is coordinated turnout, organized in advance, by people with the resources and flexibility to get to Olympia on a weekday. It is the physical equivalent of a sign-in campaign, except it requires taking a day off work and driving to the state capitol.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-57.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-57-1024x534.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;That standard also systematically excludes the people most affected by legislation. A small business owner in Spokane worried about a new tax on their income cannot easily testify on a Wednesday. A nurse working a shift cannot. A retired teacher in Yakima cannot. The sign-in system exists precisely because geographic and economic barriers make in-person participation inaccessible to most Washingtonians. Dismissing sign-ins in favor of in-person testimony is not a quality upgrade. It is a substitution of one self-selected sample for a smaller, more organizationally filtered one.&lt;/p&gt;
&lt;h2&gt;What Statistically Relevant Engagement Actually Looks Like&lt;/h2&gt;
&lt;p&gt;A standard poll commissioned to gauge public opinion on a major policy question uses around 1,000 respondents. That produces a margin of error of roughly 3.1% at 95% confidence. Those numbers drive legislation, inform campaign strategy, and get cited on the floor. Nobody demands methodology disclosure before a senator cites a Crosscut poll. That is simply the accepted evidentiary standard for constituent sentiment.&lt;/p&gt;
&lt;p&gt;The sign-in dataset, after deduplication, contains roughly 90,000 legitimate CON responses. While strict margin of error calculations require randomized polling rather than opt-in data, the mathematical gravity at this scale is inescapable: a random sample of this size would carry a margin of error of approximately 0.33%. This dataset is ninety times larger than what legislators already treat as a reliable signal, with precision ten times tighter.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-60.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-60.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;Washington has approximately 5.5 million registered voters. Ninety thousand responses represents roughly 1.6% of that population engaging with a single bill in committee. In political science research on constituent contact, engagement rates on individual pieces of legislation are typically measured in fractions of a percent. At 1.6%, this dataset is not a rounding error above that baseline. The prior record for sign-ins on any Washington bill was reportedly around 45,000, itself considered extraordinary. This dataset doubled it, and &lt;a href=&quot;https://www.thecentersquare.com/washington/article_dae6ae72-c2fd-4c9e-a6a2-35262654d3df.html&quot;&gt;the legislative website crashed&lt;/a&gt; under the volume because nothing in the system&apos;s design anticipated engagement at this scale.&lt;/p&gt;
&lt;p&gt;The infrastructure of participation failed because the signal exceeded its design limits. That is not a data quality problem. That is evidence of something real happening in the electorate.&lt;/p&gt;
&lt;p&gt;To put 90,000 in electoral terms: Washington has 49 legislative districts. Distributed statewide, that averages roughly 1,800 CON sign-ins per district. The 2024 state Senate race in the 10th district was decided by 153 votes. The House race in the 17th district was decided by fewer than 200. Several competitive seats turned on margins smaller than the number of people in those districts who showed up to oppose this bill. Legislators are not dismissing a fringe signal. They are dismissing a constituency that is, in several of their districts, larger than their margin of victory.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-58.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-58.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;Consider how the same legislators would respond to a poll of 1,000 Washingtonians showing 10:1 opposition to a bill. That finding would be treated as dispositive. It would be cited in floor speeches, appear in press releases, and be described as a clear signal of constituent sentiment. This dataset shows the same ratio at ninety times the sample size, with a margin of error ten times tighter, with an audit trail, with a reproducible methodology, and after removing anomalous windows on both sides.&lt;/p&gt;
&lt;p&gt;The legislators who called it noise do not apply that standard to anything else they use.&lt;/p&gt;
&lt;h2&gt;You Don&apos;t Need to Read the Bill&lt;/h2&gt;
&lt;blockquote&gt;
&lt;p&gt;&quot;I don&apos;t think everyone who&apos;s signing in in support or opposition is actually reading the bill. So I think you got to take it for what it&apos;s worth.&quot;&lt;/p&gt;
&lt;p&gt;— Senator Yasmin Trudeau, &lt;a href=&quot;https://tvw.org/video/legislative-democratic-leaders-media-availability-2026021344/?eventID=2026021344&quot;&gt;February 24 media availability&lt;/a&gt;&lt;/p&gt;
&lt;/blockquote&gt;
&lt;p&gt;For a technical bill where the title might mislead, that would be a legitimate point. SB 6346 is not that kind of bill. Washington has not had an income tax in nearly a century. Voters have rejected it ten times. For most constituents signing in CON, reading the bill is beside the point. They already know where they stand. The question SB 6346 raises for them is not what the rate structure looks like. It is whether Washington should have an income tax at all, and on that question they have a consistent ninety-year answer. Beyond that settled position, the architects of this legislation documented their strategy in writing years before the bill was introduced.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-59.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-59.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;In April 2018, Senator Jamie Pedersen sent an email to a former Democratic legislator explaining the real value of passing a capital gains tax. The major use of revenue, he wrote, was secondary. The more important benefit was on the legal side. Passing a capital gains tax would give the Supreme Court the opportunity to revisit its decisions that income is property, and would &quot;make it possible to enact a progressive income tax with a simple majority vote.&quot; Those emails were obtained through public records and &lt;a href=&quot;https://www.washingtonpolicy.org/publications/detail/internal-emails-reveal-the-real-plan-for-a-statewide-income-tax&quot;&gt;published by the Washington Policy Center&lt;/a&gt;, which also documented the three-step sequence Pedersen described. Pass the capital gains tax to break the legal seal. Pass a millionaires tax to build the administrative infrastructure. Then lower the threshold to capture the middle class.&lt;/p&gt;
&lt;p&gt;The capital gains excise passed in 2021. Pedersen also promised the revenue would reduce property and sales taxes. The state collected $1.8 billion in capital gains revenue from 2022 to 2024. Not a dollar went to reducing property or sales taxes. New spending absorbed everything. The Supreme Court upheld the excise in Quinn v. State in 2023, doing precisely what Pedersen predicted. A surcharge was added in 2025. SB 6346 arrived in 2026 as the simple majority vote Pedersen described eight years earlier.&lt;/p&gt;
&lt;p&gt;A constituent who signs in CON without reading SB 6346 but who knows this history is not pattern-matching by instinct. They are responding accurately to a documented legislative strategy, now in its final stage, by an architect who wrote down the plan. Trudeau&apos;s concern assumes the sign-in reflects ignorance. The record complicates that assumption.&lt;/p&gt;
&lt;p&gt;The federal income tax was introduced in 1913 as a temporary measure with a top rate of 7% on incomes above $500,000. It has been neither temporary nor limited since. A constituent who has watched Washington&apos;s capital gains excise follow the same arc, introduced with tax relief promises that were never kept and expanded within four years, is not being paranoid. They are reading the pattern correctly.&lt;/p&gt;
&lt;p&gt;A constituent signing in CON on this bill is not evaluating the mechanics of a 9.9% rate on income above one million dollars. They are evaluating a mechanism with a documented history and a stated long-term purpose. That is not noise. That is the signal working as designed.&lt;/p&gt;
&lt;h2&gt;The Participation Double Standard&lt;/h2&gt;
&lt;blockquote&gt;
&lt;p&gt;&quot;As a general rule, I always warn my members, you shouldn&apos;t really pay attention to that kind of dialogue... maybe focus less on numbers and more on quality of engagement.&quot;&lt;/p&gt;
&lt;p&gt;— Speaker Laurie Jinkins, &lt;a href=&quot;https://tvw.org/video/legislative-democratic-leaders-media-availability-2026021344/?eventID=2026021344&quot;&gt;February 24 media availability&lt;/a&gt;&lt;/p&gt;
&lt;/blockquote&gt;
&lt;p&gt;&quot;Quality of engagement&quot; implies that organized participation is lower quality than spontaneous participation. Applied consistently, that standard would disqualify most of what the same legislators celebrate as democratic infrastructure.&lt;/p&gt;
&lt;p&gt;Get out the vote campaigns are organized, at scale, through forwarded links, text banking, social media mobilization, and door knocking. They systematically encourage people to act on issues they may not have independently researched. Nobody argues that a voter who was reminded to register by a campaign text is less legitimate than one who showed up spontaneously. Nobody demands that turnout in heavily canvassed precincts be discounted because the participation was encouraged rather than organic.&lt;/p&gt;
&lt;p&gt;The asymmetry is hard to explain on principled grounds. Get out the vote efforts are explicitly designed to shape electoral outcomes, which directly determines who holds legislative power. Organized sign-in campaigns are designed to inform legislators of constituent sentiment on a specific bill, which Jinkins then warns her members not to pay attention to anyway. If one is legitimate democratic infrastructure and the other warrants skepticism, that distinction requires an explanation nobody has offered.&lt;/p&gt;
&lt;h2&gt;The Self-Selection Argument Does Not Save Them&lt;/h2&gt;
&lt;p&gt;The legitimate version of the dismissal is astroturfing risk. Organized campaigns can mobilize sign-ins that do not reflect organic sentiment. Two problems follow.&lt;/p&gt;
&lt;p&gt;First, the statistical work already addresses it. The anomalies I flagged in those prior posts run against the PRO side, not CON. The CON signal carries the messy collision fingerprint consistent with real people. The organized manipulation concern, applied rigorously and symmetrically, strengthens the CON signal rather than undermining it.&lt;/p&gt;
&lt;p&gt;Second, self-selection disqualifies nothing legislators already use. Every constituent signal they rely on is self-selected. Calls. Letters. Town hall attendance. Donations. None represent a random sample of the electorate. The sign-in system is being held to an evidentiary standard that almost no feedback mechanism in democratic practice has met, and that standard is applied to nothing else.&lt;/p&gt;
&lt;p&gt;What makes the sign-in data different from those signals is not that it is less reliable. It is that it is more systematic. It produces a record. It is auditable. It generated enough volume to run statistical tests on. The methodology applied here would hold up in a peer-reviewed context. The &quot;I talked to my constituents&quot; alternative would not.&lt;/p&gt;
&lt;p&gt;For the underlying sentiment to be actually close to even, CON participants would need to be systematically ten times more motivated to engage through this specific channel than PRO participants. That is not a bias correction. That is a complete reversal of the observed signal. No one has offered a mechanism that produces that result.&lt;/p&gt;
&lt;p&gt;The legislators dismissing this data are not applying a rigorous evidentiary standard. They are applying a selective one.&lt;/p&gt;
&lt;h2&gt;The Broader Pattern&lt;/h2&gt;
&lt;p&gt;In &lt;a href=&quot;https://unmitigatedrisk.com/2026/02/disdain-or-design/&quot;&gt;Disdain or Design?&lt;/a&gt; I wrote about what happens to constituent input in Washington when institutional actors have decided on an outcome. The user interface of democracy still renders. The buttons are there. What that piece examined is whether the backend those buttons connect to has been rewired.&lt;/p&gt;
&lt;p&gt;The sign-in dismissal is that pattern made unusually explicit. When lawmakers assert that sign-in anomalies damage the &apos;democratic process,&apos; the irony is staggering. The legislature already removed the actual democratic process from this bill &lt;strong&gt;by attaching an emergency clause, deliberately blocking the public&apos;s ability to challenge it via referendum&lt;/strong&gt;. They pre-emptively silenced the electoral signal; now legislative leaders are simply stating on camera that the only constituent participation left is not helping them make decisions.&lt;/p&gt;
&lt;p&gt;Washington voters have rejected income taxation ten times through the constitutional amendment process. The legislature is effectively circumventing the initiative process that most recently codified that preference. Dismissing the largest constituent response in state legislative history as something members should not pay attention to is not a data science position.&lt;/p&gt;
&lt;p&gt;It is a tell about whose input actually shapes the outcome.&lt;/p&gt;
&lt;h2&gt;The Question That Deserves an Answer&lt;/h2&gt;
&lt;p&gt;Every signal legislators use to read constituent sentiment is self-selected. Calls. Letters. Town halls. Protests. Donations. Sign-ins are just self-selection at scale, with a paper trail rigorous enough to audit.&lt;/p&gt;
&lt;p&gt;It is a perfectly reasonable position to argue that 90,000 highly motivated people clicking a web form do not flawlessly represent the entire state of Washington. But if the legislature genuinely wanted a higher-fidelity democratic signal, they would not have attached an emergency clause to explicitly bypass the voters. And they would not be ignoring a century of bipartisan ballot results where Washingtonians have rejected this exact policy ten separate times.&lt;/p&gt;
&lt;p&gt;Legislators are free to make that choice, but voters deserve transparency about it, not a smokescreen of statistical skepticism that the data itself dismantles. &lt;strong&gt;When the numbers speak this clearly, ignoring them isn&apos;t methodology; it&apos;s a deliberate unplugging of democracy&apos;s earpiece.&lt;/strong&gt;&lt;/p&gt;
</content:encoded><category>thoughts</category></item><item><title>Duplicates Are Not the Problem</title><link>https://unmitigatedrisk.com/2026/02/duplicates-are-not-the-problem/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/02/duplicates-are-not-the-problem/</guid><description>The Washington House is now arguing that the sign-in dataset for SB 6346 is unreliable because it contains duplicate names. The claim is simple. If the same name appears more than once, you cannot trust the totals.</description><pubDate>Wed, 25 Feb 2026 20:41:46 GMT</pubDate><content:encoded>&lt;p&gt;The Washington House is now arguing that the sign-in dataset for SB 6346 is unreliable because it contains duplicate names. The claim is simple. If the same name appears more than once, you cannot trust the totals.&lt;/p&gt;
&lt;p&gt;They are not wrong that duplicates exist. They are wrong about what duplicates mean and what to do about them.&lt;/p&gt;
&lt;p&gt;Every real-world dataset contains noise. Names entered twice, typos, outliers, junk. This is not a scandal. It is a property of data collected from human beings at scale. The standard response is not to discard the dataset. It is to trim it. A trimmed mean, cutting the head or tail or both, is one of the oldest tools in data science. The presence of junk data is not a reason to abandon analysis. It is the reason analysis exists.&lt;/p&gt;
&lt;p&gt;The birthday-corrected collision test applied in the &lt;a href=&quot;https://unmitigatedrisk.com/2026/02/the-data-doesnt-support-the-narrative/&quot;&gt;previous post&lt;/a&gt; is a more principled version of exactly that. Rather than arbitrarily cutting a fixed percentage off the tail, it uses the population model to identify which specific windows are statistically anomalous and removes only those. The legislature is being offered a choice between principled trimming and throwing the whole dataset away. One of those is data science. The other is a talking point.&lt;/p&gt;
&lt;h2&gt;Why Duplicates Happen&lt;/h2&gt;
&lt;p&gt;Before getting to the test, it is worth being precise about why duplicates appear in the first place, because the innocent explanations are more common than the fraudulent ones.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-48.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-48-1024x578.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;&lt;em&gt;Approximately 800 people named John Smith live in Washington state. These are real, distinct individuals.&lt;/em&gt;&lt;/p&gt;
&lt;p&gt;The first is demographics. According to the U.S. Census Bureau, Smith is the most common surname in America, occurring roughly 828 times per 100,000 people. There are an estimated 32,000 people named John Smith in the United States, approximately 800 in Washington state alone. But national averages miss how name frequency actually works in practice. It clusters by community. Redmond and Bellevue have dense South Asian tech worker populations where Patel and Singh recur at rates far above the state average. Tukwila and south King County have large East African and Somali communities where Mohammed appears with predictable frequency. South Seattle and the Puget Sound corridor have substantial Vietnamese communities where Nguyen, already the most common surname in Vietnam, concentrates heavily. Name frequency is never random. It reflects religion, culture, and family tradition. Mohammed is among the most common names in the world because naming a son after the prophet is an act of Islamic devotion practiced across generations. That is not a data quality problem. The same full name appearing two or three times in 80,000 records is not evidence of anything. It is census math applied to a state that looks nothing like the national average.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-51.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-51-971x1024.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;The second reason duplicates appear is the sign-in form itself. It does not confirm that your submission was received. Anyone who has filled out a web form and stared at the screen knows what comes next. You submit again. Someone might also change their mind and resubmit to correct their position. A household with two people named Michael Johnson might both sign in independently. None of that is fraud. Both causes are real, and a serious analysis accounts for both.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-56.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-56-1024x427.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;Beyond that, even if we removed all of the duplicates, it would not even move the needle on the ultimate message being sent. With that said, it is worth noting that CON has more removals in absolute terms because it has ten times as many submissions, which is what we would expect based on the collision test.&lt;/p&gt;
&lt;h2&gt;On Rapid Submissions&lt;/h2&gt;
&lt;p&gt;A related claim is that submissions arriving within seconds of each other indicate bot activity. The timing observation is real. The interpretation is not supported by the data available.&lt;/p&gt;
&lt;p&gt;Rapid same-name pairs are primarily a function of submission volume. When hundreds of people are submitting per hour, two people who share a name will statistically land within seconds of each other by chance alone. The chart below plots same-name rapid pairs against hourly submission rate for both sides. Both follow the same curve. The PRO overnight Feb 20 hours, at roughly 190 submissions per hour, fall below where the trend predicts they should be, which is consistent with what the collision test found. The timing argument does not add new evidence against PRO. It describes a mathematical property of any high-volume submission window.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-55.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-55-1024x602.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;The public export contains no IP addresses. Without them, rapid sequential submissions cannot be distinguished between three completely different explanations. The first is a single person double-submitting because the form gave no confirmation. The second is two people in the same household on the same connection. The third is two distinct people with different IPs whose submissions happened to land close together during a busy window.&lt;/p&gt;
&lt;p&gt;The tool that would actually resolve this is IP address logs from the server. A same-IP rapid duplicate is strong resubmission evidence. A different-IP rapid duplicate from a residential ISP is two real people. A cluster of submissions from a datacenter or known VPN range is a different finding entirely. None of that analysis is possible from the public CSV, which is the only data anyone outside the AG&apos;s office has seen.&lt;/p&gt;
&lt;p&gt;This matters because the &quot;within seconds&quot; framing is being used to support a conclusion the available data cannot reach. The &lt;a href=&quot;https://unmitigatedrisk.com/2026/02/the-data-doesnt-support-the-narrative/&quot;&gt;previous post&lt;/a&gt; noted that IP logs should be preserved before they age out. That recommendation stands. Until that analysis is done, timing alone is not evidence of anything specific.&lt;/p&gt;
&lt;p&gt;It is also worth noting what the pattern does not look like. It shows zero name collisions and below-trend rapid pairs, the opposite of what cheap automation produces. What that pattern is consistent with is a large list of pre-generated unique names submitted at a controlled rate. CAPTCHA does not stop that. Each submission looks like a distinct human from the name and timing perspective. The fix legislators might reach for does not address the threat model the data actually points to.&lt;/p&gt;
&lt;h2&gt;What the Test Is Measuring&lt;/h2&gt;
&lt;p&gt;The birthday problem tells you that a room of 23 people has a 50% chance of containing a shared birthday. The same math gives you the expected number of name collisions in any random sample drawn from a community of known size. If you have 9,000 PRO supporters and draw 934 names from that pool, some names will repeat by chance. Not because anyone cheated. Because Jennifer Lee exists in multiples, and because some of them hit submit twice when the page did not respond.&lt;/p&gt;
&lt;p&gt;The expected number of collisions for that sample is approximately 60. Not zero. Sixty. The test does not flag duplicates. It asks whether the duplication rate is consistent with what a genuine community would produce.&lt;/p&gt;
&lt;p&gt;For the Senate PRO February 20th overnight window, the observed collisions were zero. Not fewer than expected. Zero. Across 10,000 simulations drawing from the actual PRO participant pool, the minimum produced was around 30. The overnight batch produced none.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-50.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-50-1024x564.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;The CON overnight windows tell the opposite story. More collisions than expected across several nights, consistent with resubmission, common names appearing organically, households submitting together. The kind of messy that real participation produces.&lt;/p&gt;
&lt;h2&gt;What This Means for the Dataset&lt;/h2&gt;
&lt;p&gt;The argument that duplicates make the dataset unreliable cuts in exactly the wrong direction. The PRO overnight batch from February 20th is anomalous precisely because it has too few duplicates, not too many. A genuine sample from a real community, one that includes people named John Smith and people who hit submit twice, does not produce zero collisions in 934 draws. It is statistically impossible.&lt;/p&gt;
&lt;p&gt;Raw duplicate counts, without correcting for population name frequency and sample size, are not a meaningful metric. The legislature is being asked whether these sign-in totals reflect genuine public sentiment, and that is a statistical question with a statistical answer. The answer is not &quot;the dataset has duplicates, therefore we cannot know.&quot; The methodology was built specifically to separate expected duplication from anomalous duplication, and the findings hold.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-52.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-52-1024x472.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;Discarding the dataset because it contains duplicates is not data analysis. It is avoiding data analysis.&lt;/p&gt;
&lt;p&gt;None of this is perfect. IP address analysis would not be definitive because VPNs, shared connections, and mobile carriers complicate attribution. The collision test rests on a population model that is an estimate, not a census. The rapid pairs chart fits a trend to noisy data. Statistical inference is always probabilistic, and anyone who tells you otherwise is selling something.&lt;/p&gt;
&lt;p&gt;But the question legislators are actually asking is not whether this dataset is perfect. It is whether the sign-in totals are a reasonable signal of public sentiment, and whether the anomalies identified are significant enough to warrant skepticism about specific windows. For that question, the methodology does not need to be perfect. It needs to be fit for purpose.&lt;/p&gt;
&lt;p&gt;A 10:1 ratio that survives deduplication, symmetrical trimming, and a collision test that was explicitly designed to tolerate legitimate duplication is a robust signal. The PRO overnight Feb 20 anomaly does not need to be proven beyond a reasonable doubt to be disqualifying for that window. The standard here is not a criminal conviction. It is whether legislators can treat the aggregate numbers as a directional guide to constituent sentiment. On that standard, the analysis is more than sufficient.&lt;/p&gt;
&lt;h2&gt;On Impersonation&lt;/h2&gt;
&lt;p&gt;Named officials discovering their identities appeared in the dataset without their consent is a real incident worth investigating. But the sign-in system was never designed to verify identity or attribute positions to specific individuals. Names are collected not to create a record of who voted, but because a completely anonymous system would be trivially manipulable. A name field is the minimal friction that makes aggregate analysis possible at all.&lt;/p&gt;
&lt;p&gt;The relevant question for legislators is not &quot;did John Smith actually sign this?&quot; but &quot;does the distribution of sign-ins reflect genuine public sentiment.&quot; This is a survey mechanism, not a ballot. Washington has 7.8 million residents. Even a perfectly clean dataset with 100,000 CON sign-ins represents a small fraction of the population. Legislators have always understood these numbers as a directional signal, not a binding count. Treating impersonation as the central finding, rather than asking whether the aggregate signal survived manipulation, mistakes the instrument for the measurement.&lt;/p&gt;
&lt;p&gt;The numbers behind the impersonation claim deserve scrutiny. Invest in Washington Now reported roughly 100-200 confirmed cases across 123,289 records, less than 0.2% of the dataset. Even tripling that estimate to account for unreported cases, it does not move a 10:1 ratio in any meaningful direction. And if you apply their own deduplication logic symmetrically: remove every name that appears more than once from both sides. CON drops from roughly 110,000 to 91,000 and PRO drops from roughly 10,000 to 9,000. The ratio is still 10:1. Their argument, applied consistently to both sides, does not change the conclusion.&lt;/p&gt;
&lt;p&gt;Those confirmed cases were identified because victims self-reported. Public officials monitor mentions of their names, noticed the discrepancy, and came forward. That is the easiest fraud to find. It tells you nothing about what the rest of the dataset contains. Self-reported impersonation is the floor of what happened, not the ceiling, which is precisely why aggregate statistical analysis exists.&lt;/p&gt;
&lt;p&gt;It is also worth considering what those confirmed cases likely represent. Some are probably legitimate resubmissions. Someone signed in, was not sure it worked, signed in again, and now appears twice. Some are probably trolling. Actual coordinated impersonation may be in there too, but the self-report mechanism cannot distinguish between the three. Treating 200 high-visibility cases driven by public figures monitoring their own names as representative of the full 123,000-record dataset is not a statistical argument. It is a press conference.&lt;/p&gt;
&lt;h2&gt;So What Does All of This Mean?&lt;/h2&gt;
&lt;p&gt;The answer to that is simple. The dataset has duplicates. The timing raised questions. Some names were submitted without consent. None of those observations, examined carefully, change what the data shows: roughly ten Washington residents opposed this bill for every one who supported it in committee. That signal has survived every test applied to it.&lt;/p&gt;
</content:encoded></item><item><title>Teach to the Median, Punish the Variance</title><link>https://unmitigatedrisk.com/2026/02/teach-to-the-median-punish-the-variance/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/02/teach-to-the-median-punish-the-variance/</guid><description>Factories exist to produce consistent, cost-effective products. That is the point. The relentless optimization of cost of goods sold is not a side effect of industrial production. It is the mandate. And it works, until…</description><pubDate>Tue, 24 Feb 2026 19:56:45 GMT</pubDate><content:encoded>&lt;p&gt;Factories exist to produce consistent, cost-effective products. That is the point. The relentless optimization of cost of goods sold is not a side effect of industrial production. It is the mandate. And it works, until it doesn&apos;t. The reason products last so much less than they did twenty years ago is not that we forgot how to make durable things. It is that durability lost the cost argument. Quality is expensive. Variance is expensive. The system optimizes both out. What survives is the median product, built to a price, reliable enough to ship, and no more.&lt;/p&gt;
&lt;p&gt;Modern schooling often behaves the same way. It batches children by age, sequences content for throughput, and optimizes for a predictable median. &lt;a href=&quot;http://youtube.com/watch?v=iG9CE55wbtY&amp;amp;vl=en&quot;&gt;Sir Ken Robinson made this observation twenty years ago,&lt;/a&gt; and the metaphor stuck, not because it is clever but because it names incentives, not architecture. When a system must operate at scale under budget, policy, and staffing constraints, variance becomes expensive. The median becomes the target. Outliers become the problem.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-47.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-47-1024x578.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;That is how you get the loop so many families recognize.&lt;/p&gt;
&lt;p&gt;A child with a spiky profile, gifted and struggling at the same time, or simply learning in a different sequence, is hard for a production line to interpret. &lt;a href=&quot;https://unmitigatedrisk.com/2026/01/intuition-comes-last/&quot;&gt;The system cannot see internal state&lt;/a&gt;. It can only see outputs it knows how to count. Pacing, compliance, turn in rates, standardized measures, and classroom friction. When it cannot measure what is actually happening, it collapses complexity into a label. Lazy. Defiant. Behind. Broken. Sometimes worse. The misclassification is not incidental. It is structural. The factory cannot afford to treat every student as a special case, so it treats special cases as defects.&lt;/p&gt;
&lt;p&gt;Twice exceptional programs were a serious attempt to address exactly this failure mode. 2e was not supposed to be a vibe. It was an operational category, a way to route support without denying capability.&lt;/p&gt;
&lt;p&gt;Institutions rarely attack reforms head-on. They metabolize them. The common move is not to announce that everyone is 2e. It is more subtle. Fold 2e into the general program, justify the change as an opportunity for all, and quietly remove the differentiated pathways, expertise, and accountability that made 2e real. The label survives. The function does not. The specialist becomes a roaming consultant, the pull-out becomes a generic intervention block, and the documentation becomes a checkbox.&lt;/p&gt;
&lt;p&gt;Spencer Silver at 3M spent years trying to make a strong adhesive and produced one that was too weak to hold permanently. By factory logic it was a failed batch. It sat in the lab for years because the system had no category for a glue that did not stick properly. A colleague with a different problem recognized the variance as the feature. The factory almost never found out what it had.&lt;/p&gt;
&lt;p&gt;This pattern is familiar in M&amp;amp;A. Companies are often acquired to address a capability, culture, or talent gap. The acquirer gets what it wanted on paper, and then the organization takes over. Microsoft bought Hotmail to compete in web-based email. Hotmail ran on Linux. Microsoft ported it to Windows, the product degraded, and what had been acquired to solve a problem became an example of the problem. The engineers who built Hotmail watched what they had created get dismantled and left. The institution did not transform around the acquisition. The acquisition transformed into the institution, and the talent that made it valuable walked out with their badges.&lt;/p&gt;
&lt;p&gt;The proof a program still exists is not whether the brochure mentions it. It is whether the supports remain distinct, staffed, and enforceable. When a category stops changing what adults do, the system reverts to default settings. Teach to the median, punish variance, treat the casualties as defects.&lt;/p&gt;
&lt;p&gt;You can see the same dynamic in curriculum fights. When a system cannot reliably lift the floor, the path of least resistance is to lower the ceiling and call it equity. This is not cynical in intent. It is cynical in effect. Acceleration does not disappear. It moves off the books. Tutoring, test prep, schedule hacking, summer programs, parent advocacy. The families who can afford those channels use them. The families who cannot are left with the official story that the ceiling was lowered for their benefit. The median experience is preserved. The gap widens. Official metrics improve because the ceiling has been redefined.&lt;/p&gt;
&lt;p&gt;None of this is morally mysterious. It is operational. What makes it damning is that schooling runs this population optimization model without the measurement and accountability that would make it legitimate.&lt;/p&gt;
&lt;p&gt;Medicine is honest about something uncomfortable. Treatments have side effects. They do not affect everyone equally. Approval assumes some negative outcomes are acceptable in exchange for a greater good. But medicine only earns the right to make that utilitarian bargain because it is paired with surveillance and accountability. Trials, defined endpoints, adverse event reporting, label changes, and sometimes recalls. When a drug underperforms or causes unacceptable harm, the system has mechanisms to withdraw it.&lt;/p&gt;
&lt;p&gt;Schooling borrows the utilitarian posture and skips the legitimacy conditions. There is no adverse event tracking for predictable harms like anxiety spirals, learned helplessness, disengagement, or the systematic grinding down of nonstandard profiles. When you ask what the rollback criteria are, you get a blank stare, because the system does not think in rollback terms. It thinks in throughput terms.&lt;/p&gt;
&lt;p&gt;Here is a small, concrete example. One of my children has an accommodation plan tied to a documented set of specific needs. A teacher recently told us the plan would not be needed anymore because the child does not show ADHD signs. There is no ADHD diagnosis, and the plan is not based on ADHD. The teacher was not acting maliciously. They were acting normally inside a system that treats supports as vibes. In a system with real measurement, you do not withdraw support based on a vibe. You tie withdrawal to documented criteria, with a rollback plan if the criteria are wrong. This is not exotic engineering. It is basic change management. Define the hypothesis, define success, define failure, and pre-commit to the revert.&lt;/p&gt;
&lt;p&gt;Schooling routinely does the opposite, and the response when things go sideways is not to revisit the decision. It is to escalate.&lt;/p&gt;
&lt;p&gt;More pressure. More compliance. More labeling. The system treats opt-out as a containment breach rather than a performance signal, because enrollment and funding are coupled together. The institution has no incentive to register failure. It has strong incentives to frame failure as the students&apos;.&lt;/p&gt;
&lt;p&gt;So why does this cycle finally have a credible exit?&lt;/p&gt;
&lt;p&gt;Because &lt;a href=&quot;https://unmitigatedrisk.com/2025/10/llms-are-the-new-printing-press-why-im-optimistic-about-my-kids-future/&quot;&gt;AI breaks the monopoly on instruction&lt;/a&gt;.&lt;/p&gt;
&lt;p&gt;For most of modern history, if you wanted a coherent explanation, feedback loops, sequenced practice, and the ability to revisit a concept from a different angle without embarrassment, you needed the institution or you needed money. Those are the same thing for most families. AI makes those pieces abundant. It makes it cheaper to learn in a different order. &lt;a href=&quot;https://unmitigatedrisk.com/2024/12/beyond-memorization-preparing-kids-to-thrive-in-a-world-of-endless-information/&quot;&gt;It makes it cheaper to revisit a concept from five angles&lt;/a&gt; without being punished for needing a sixth. It reduces the penalty for variance in a way that nothing else in the past century has.&lt;/p&gt;
&lt;p&gt;This is why models like &lt;a href=&quot;https://alpha.school/&quot;&gt;Alpha School&lt;/a&gt; are worth watching, whatever you think of their specific implementation. They are proof that you can architect learning around mastery and coaching rather than batching and seat time. They are not just a new school brand. They are evidence that instruction is no longer scarce, and that the existing system&apos;s grip on the delivery layer is loosening.&lt;/p&gt;
&lt;p&gt;The tradeoff is real and worth being honest about. The devil you know versus the one you do not.&lt;/p&gt;
&lt;p&gt;The existing system&apos;s harms are normalized, which means they are mostly invisible. The new world introduces different risks. Dependency on opaque tools, misinformation at scale, AI-driven learning environments that are even more coercive than human ones because they optimize metrics nobody agreed to, and a widening gap between families who can navigate the options and those who cannot.&lt;/p&gt;
&lt;p&gt;The credential layer will be the next fight. Institutions that lose control of instruction will shift to defending legitimacy. Seat time requirements, accreditation barriers, and the bureaucratic right to define what counts for the purposes of the next gate. If instruction becomes abundant, the last monopoly is not learning. It is recognition.&lt;/p&gt;
&lt;p&gt;But the direction of travel is hard to reverse. Bureaucracy protects the status quo long past the point where the quo has lost its status. AI accelerates the expiration date. The more schooling responds to exits with escalation rather than adaptation, the more it will be outcompeted by systems that treat variance as signal rather than a defect.&lt;/p&gt;
&lt;p&gt;I keep coming back to the medicine analogy, but with a sharper edge. In medicine, adverse events are data. In schooling, adverse events become discipline referrals and bad grades. One system updates on failure. The other system records the failure as the student.&lt;/p&gt;
&lt;p&gt;AI is not a magic cure. But it is the first credible exit from a century-old loop. A factory that mistakes difference for defect, and calls the casualties the cost of scale.&lt;/p&gt;
</content:encoded><category>parenting</category><category>thoughts</category></item><item><title>The Data Doesn&apos;t Support the Narrative</title><link>https://unmitigatedrisk.com/2026/02/the-data-doesnt-support-the-narrative/</link><guid isPermaLink="true">https://unmitigatedrisk.com/2026/02/the-data-doesnt-support-the-narrative/</guid><description>SB 6346 would create Washington&apos;s first personal income tax in nearly a century. A 9.9% rate on income above \$1 million, projected at \$3.4 billion annually, it passed the Senate 27-22 on party lines and is now in the…</description><pubDate>Tue, 24 Feb 2026 06:03:59 GMT</pubDate><content:encoded>&lt;h2&gt;What This Is About&lt;/h2&gt;
&lt;p&gt;SB 6346 would create Washington&apos;s first personal income tax in nearly a century. A 9.9% rate on income above $1 million, projected at $3.4 billion annually, it passed the Senate 27-22 on party lines and is now in the House. Washington voters have rejected income taxation ten times at the ballot over the last hundred years. This is the most contested piece of legislation the state has seen in a generation.&lt;/p&gt;
&lt;p&gt;Washington&apos;s legislature runs an online sign-in system for committee hearings. Anyone can go to the legislative website and register their position on a bill, pro or con, without testifying. Legislators see the totals. The system is designed to give ordinary people a voice even if they can&apos;t show up in Olympia. On SB 6346, it may be the &lt;em&gt;only&lt;/em&gt; meaningful voice many residents have: the legislature designated the bill an emergency measure, which prevents a voter referendum. There is no ballot option. For most Washington residents opposed to this bill, signing in here, or calling their representative directly, is the entire menu.&lt;/p&gt;
&lt;p&gt;When those numbers get manipulated, the perception gets manipulated. On a bill this significant, in a state with a century of voter resistance to income taxes, that is not a minor data quality problem. It is a distortion of the democratic signal legislators and journalists are using to understand where the public actually stands.&lt;/p&gt;
&lt;p&gt;Which is why getting the analysis right matters. And why it matters that GeekWire got it wrong.&lt;/p&gt;
&lt;hr /&gt;
&lt;p&gt;GeekWire &lt;a href=&quot;https://www.geekwire.com/2026/group-alleges-fake-sign-ins-used-to-pad-apparent-opposition-to-washington-state-millionaires-tax/&quot;&gt;reported Monday&lt;/a&gt; (Added 2/24/26: and apparently the &lt;a href=&quot;https://www.seattletimes.com/seattle-news/politics/wa-millionaires-tax-group-alleges-37000-fake-opposition-sign-ins/&quot;&gt;Seattle Times&lt;/a&gt; too) that fraudulent sign-ins were used to inflate CON opposition to SB 6346. Named public officials confirmed their identities appeared without their consent. The framing was clear: the anti-tax side cheated.&lt;/p&gt;
&lt;p&gt;The data tells a different story.&lt;/p&gt;
&lt;p&gt;The story was built on analysis provided by Invest in Washington Now, a PRO-tax advocacy group that examined CON submissions and held a press conference. They reported a true incident, but failed to do the basic symmetric analysis needed to justify the narrative they attached to it.&lt;/p&gt;
&lt;p&gt;I downloaded the full legislative sign-in export at 5:51 PM Pacific on February 23rd, 123,289 records, and ran the same tests on both positions. Here is what it shows.&lt;/p&gt;
&lt;p&gt;The data confirms fraud. It does not confirm that fraud explains the opposition. Those are different claims, and the difference matters enormously on a bill this significant.&lt;/p&gt;
&lt;hr /&gt;
&lt;h2&gt;Who Actually Showed Up&lt;/h2&gt;
&lt;p&gt;&quot;Legitimate&quot; here means a unique name that appears at least once during daytime hours (7 AM to 11 PM PT). The export does not verify identity.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;CON: roughly 90,000 legitimate unique participants.&lt;/strong&gt;&lt;/p&gt;
&lt;p&gt;CON was underrepresented during overnight Pacific hours, which is exactly what you would expect from Washington residents who are asleep at 2 AM. By every geographic measure in the data, CON&apos;s daytime participation pattern is consistent with Washington residents showing up. CON does have an overnight anomaly, roughly 2,800 names that appear only in overnight windows and never in five days of daytime sign-ins, which reduces the legitimate unique count to roughly 90,000. More on this below.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;PRO: roughly 9,100 apparent legitimate unique participants.&lt;/strong&gt;&lt;/p&gt;
&lt;p&gt;The PRO side has 9,919 unique names across the full hearing. But between 1 and 5 AM Pacific on February 20th, 934 submissions arrived in a single five-hour overnight window (1:00–5:59 AM). That window accounts for about 8.4% of all PRO submissions across the entire hearing period. Of those 934 submissions, 807 were unique names. Set those aside, and you have roughly 9,100 apparent legitimate PRO participants.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;That is a roughly 10-to-1 ratio&lt;/strong&gt; (90,408 CON vs 9,112 PRO in the export, after removing overnight-only names as defined here). A margin like that on a contested tax bill during a legislature that removed opportunity for feedback other than this survey is not, on its own, statistically implausible.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-42.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-42.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;Here is what the data actually shows. Both sides have anomalous overnight submissions that do not match the daytime participation signature. On the CON side, roughly 2,800 names, about 3% of their total, appear only overnight and never during five days of daytime sign-ins. On the PRO side, 807 names, about 8% of their total, appeared in a single five-hour overnight window. Both anomalies are real. But after removing them, roughly 90,000 legitimate CON participants remain against roughly 9,100 legitimate PRO participants. The fraud did not manufacture the opposition. The fraud, such as it is, was larger in proportional terms on the side that was already losing 10 to 1.&lt;/p&gt;
&lt;p&gt;The story treated fraud as the explanation for the margin. The data shows the margin survived the fraud. On every test, the more anomalous signal sits on the PRO side, not the CON side.&lt;/p&gt;
&lt;hr /&gt;
&lt;h2&gt;The Geography Test&lt;/h2&gt;
&lt;p&gt;The most straightforward test requires no statistics at all. Washington residents sleep on Pacific time. If you plot submissions by hour of day, genuine local participation should cluster during waking hours and drop off after midnight.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-43.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-43.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;CON activity drops overnight, consistent with local participants sleeping on Pacific time.&lt;/p&gt;
&lt;p&gt;PRO shows a pronounced spike on February 20th between 1 and 5 AM, running at close to 190 submissions per hour for five straight hours, while Washington residents were asleep and the CON side was quieter than usual. &lt;strong&gt;The spike is not a few night owls.&lt;/strong&gt;&lt;/p&gt;
&lt;hr /&gt;
&lt;h2&gt;The Community Test&lt;/h2&gt;
&lt;p&gt;Here is where it gets harder to explain away.&lt;/p&gt;
&lt;p&gt;Across five full days of daytime sign-ins, we have an observable picture of who the PRO community actually is. Roughly 9,100 people engaged during normal waking hours. Five days is a long window. If you are a genuine PRO supporter, the probability that you appeared in that record at least once is high.&lt;/p&gt;
&lt;p&gt;Name communities have statistical fingerprints. Any two groups drawn from the same population will share common names at a predictable rate, the same demographic mix, the same frequency of &quot;James Kim&quot; or &quot;Sarah Johnson.&quot; So even if the overnight submitters were entirely different individuals from the daytime crowd, you would still expect their names to collide with the daytime pool at a rate consistent with drawing from the same community. The longer the daytime window, the higher that rate gets.&lt;/p&gt;
&lt;p&gt;You can test this directly. Draw 934 random names from the known PRO pool and ask how many appear somewhere in five days of daytime submissions. Across 10,000 simulations, the answer is about 86%.&lt;/p&gt;
&lt;p&gt;The observed overnight overlap was 13.6%. Nearly nine out of ten overnight names had never appeared in five days of daytime PRO submissions.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-44.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-44.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;Every one of the 10,000 simulations produced more overlap than the overnight batch did. The minimum was 82%.&lt;/p&gt;
&lt;p&gt;The same test applied to CON tells a similar structural story. CON&apos;s overnight names also show only 21–25% overlap with the daytime pool across five nights, against an expected 90–94%. Both positions have overnight participants who are largely absent from the five-day daytime record. The difference is in magnitude and concentration. CON&apos;s anomaly spreads 2,800 names across five nights. PRO&apos;s concentrates 807 names into a single five-hour overnight window. The PRO signal is sharper, but the underlying pattern of overnight names that don&apos;t match the daytime community appears on both sides.&lt;/p&gt;
&lt;hr /&gt;
&lt;h2&gt;The Name Collision Test&lt;/h2&gt;
&lt;p&gt;In any large population, names repeat. If you pull 934 people at random from Washington state, some of them will be named James Kim. Some will be named Sarah Johnson. That is not fraud, that is just how names work. The question is whether the names repeat at the rate you would expect given the size and demographic makeup of the community you are drawing from.&lt;/p&gt;
&lt;p&gt;934 overnight PRO submissions produced zero repeated names. Not fewer than expected. Zero.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-40.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-40.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;p&gt;From a genuine community of roughly 9,100 PRO supporters, you would expect around 60 name collisions in a sample that size, just by chance. We ran 10,000 simulations drawing from the actual PRO participant pool. Every single one produced collisions. The lowest was around 30. The observed overnight batch produced none.&lt;/p&gt;
&lt;p&gt;The most consistent explanation is that someone built a list and specifically made sure no name appeared twice. That is not what organic participation looks like. That is what a curated submission operation looks like.&lt;/p&gt;
&lt;p&gt;The CON side shows the opposite pattern. Several overnight windows had more name repeats than expected, consistent with people resubmitting or households submitting together. Messy, in other words. The kind of messy that real participation produces.&lt;/p&gt;
&lt;p&gt;934 submissions. 934 unique names. Zero repeats. That is the number that should be in the headline.&lt;/p&gt;
&lt;hr /&gt;
&lt;h2&gt;On CAPTCHA&lt;/h2&gt;
&lt;p&gt;The form uses CAPTCHA verification. This comes up because some coverage implies it as a meaningful protection.&lt;/p&gt;
&lt;p&gt;It is not, against this class of problem. CAPTCHA distinguishes automated bots from humans. It provides no protection against human click farms, which are operations that pay workers in other countries to solve CAPTCHAs manually and complete form submissions by hand. This is a commercial industry. Services are publicly listed, priced at $1 to $3 per 1,000 submissions.&lt;/p&gt;
&lt;p&gt;The pattern observed on February 20th is most consistent with coordinated human submissions using a curated name list: overnight timing, near-zero overlap with the daytime community, and zero name collisions across 934 submissions. A click-farm-style mechanism is one plausible explanation. The public export cannot prove attribution without server-side logs.&lt;/p&gt;
&lt;p&gt;At those rates, the 934 anomalous overnight PRO submissions represent a trivial cost against a bill projecting $3.4 billion in annual revenue.&lt;/p&gt;
&lt;p&gt;&lt;a href=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-41.png&quot;&gt;&lt;img src=&quot;https://unmitigatedrisk.com/wp-content/uploads/2026/02/image-41.png&quot; alt=&quot;&quot; /&gt;&lt;/a&gt;&lt;/p&gt;
&lt;hr /&gt;
&lt;h2&gt;On the Audit Trail&lt;/h2&gt;
&lt;p&gt;The public data export does not include IP addresses. Whether internal server logs exist and whether they have been preserved is unknown. That is a question the AG&apos;s investigation should answer before those logs age out.&lt;/p&gt;
&lt;p&gt;Even with full IP logs, naive geolocation proves little. Click farm operations commonly route through VPNs, and an IP address alone does not establish geographic origin without infrastructure-level analysis of the autonomous system it belongs to. What you want to know is not which city the IP is registered to. You want to know whether it belongs to a residential ISP, a datacenter, or a known VPN provider range. Those are different findings with different implications.&lt;/p&gt;
&lt;hr /&gt;
&lt;h2&gt;What This Means&lt;/h2&gt;
&lt;p&gt;Neither finding resolves cleanly without a real investigation. The named official impersonations on the CON side are real and the AG should pursue them. But confirming specific named victims is the easiest fraud to find because the victims can self-report. That is not a statistical audit, and it does not address what the data shows on the other side.&lt;/p&gt;
&lt;p&gt;Both findings warrant investigation. The system made both possible.&lt;/p&gt;
&lt;p&gt;There is a useful analogy here. Risk-Limiting Audits are the gold standard for post-election verification. The premise is that you do not need to check every ballot to establish confidence in the outcome. You need to bound the probability that the anomalies are large enough to change the result. Advocates of RLAs often argue, correctly, that statistical evidence is sufficient to certify an election without requiring individual identity verification for every voter.&lt;/p&gt;
&lt;p&gt;That is precisely what this analysis does. It does not identify every fraudulent submission. It asks whether the fraud on either side was large enough to manufacture the margin. The answer is no. After removing every overnight anomaly on both sides, roughly 90,000 legitimate CON participants remain against roughly 9,100 legitimate PRO participants. If statistical sampling is rigorous enough to certify an election, it is rigorous enough to evaluate a legislative sign-in system.&lt;/p&gt;
&lt;p&gt;The sign-in infrastructure was built for access. Low friction, no identity binding, no rate limiting that held against coordinated submission. I have &lt;a href=&quot;https://unmitigatedrisk.com/2026/02/disdain-or-design/&quot;&gt;written before&lt;/a&gt; about how Washington has accumulated individually defensible choices that collectively produce systems incapable of defending their own integrity. The legislature is now trying to adjudicate participation fraud on infrastructure that was never designed to be auditable.&lt;/p&gt;
&lt;p&gt;The question that does not get asked in any of the coverage: why did Washington build a public participation system with no ability to verify, audit, or forensically reconstruct what happened, and what would it take to build one that can?&lt;/p&gt;
&lt;hr /&gt;
&lt;h2&gt;Methodology&lt;/h2&gt;
&lt;p&gt;All analysis was run on the public CSV export of sign-in records for SB 6346, downloaded at 5:51 PM Pacific on February 23rd, 123,289 records total. Every test was applied symmetrically to both positions using the same parameters. The analysis does not attempt attribution. It bounds the probability of innocent explanation under stated assumptions.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Geographic analysis.&lt;/strong&gt; Submissions were binned by Pacific hour. Each position&apos;s hourly share was compared to that position&apos;s overall base rate across the full hearing. CON activity drops overnight relative to daytime hours, consistent with participants sleeping on Pacific time. PRO showed a concentrated spike on February 20th between 1 and 5 AM, sustaining close to 190 submissions per hour across five consecutive hours. The 1 to 5 AM PT window corresponds to mid-day hours in parts of Asia and the Middle East.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Name overlap test.&lt;/strong&gt; This test requires no statistical model and is not sensitive to assumptions about name distributions. For each overnight window with at least 20 submissions, the unique names were compared against that position&apos;s daytime submissions (7 AM to 11 PM) across the full hearing. Overlap fraction equals names appearing in both sets divided by total overnight unique names.&lt;/p&gt;
&lt;p&gt;To establish expected overlap, 10,000 random samples of size n were drawn without replacement from that position&apos;s full-hearing participant pool, and the overlap fraction with the daytime set was computed for each draw. On February 20th, the PRO observed overlap of 13.6% fell below the minimum of all 10,000 simulations. The lowest simulated value was about 82%. CON overnight overlap ranged from 21–25% across five nights, against a bootstrap expectation of 90–94%, also below every simulation on every night. Both positions show overnight communities that are largely disconnected from their daytime pools.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Birthday-corrected collision analysis.&lt;/strong&gt; Raw name duplication rates are not meaningful without correcting for sample size. In any large sample, some names will repeat by chance regardless of how the data was generated. The expected number of name collisions for a sample of size n drawn from a pool of N_effective distinct names follows the occupancy problem:&lt;/p&gt;
&lt;blockquote&gt;
&lt;p&gt;expected unique names = N_effective × (1 − e^(−n/N_effective)) expected collisions = n − expected unique&lt;/p&gt;
&lt;/blockquote&gt;
&lt;p&gt;N_effective was estimated separately for each position from that position&apos;s own daytime submissions using the method-of-moments estimator: N_effective = u² / (2s − u), where u is the number of unique names and s is total daytime submissions. This assumes the overnight community draws from the same underlying name distribution as the daytime community. That assumption is explicit and falsifiable. CON showed collision excesses across multiple nights, with effect sizes of 1.8%, 2.3%, and 4.1% on the three most anomalous nights. PRO worst night (February 20th): 0 observed collisions, approximately 60 expected, deficit of ~60. Statistical significance was assessed using the Poisson distribution, upper-tail for excess and lower-tail for deficit.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Sensitivity.&lt;/strong&gt; The collision deficit finding holds unless the PRO overnight community drew from a pool of at least approximately 200,000–300,000 distinct name combinations, roughly 20–30 times the total observed PRO participant base across the full hearing. The entire PRO participant pool across five days is 9,919 unique names. A reader who disputes this should specify what pool size they would defend, and explain why that entire community was absent from every daytime window across the hearing period.&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;Duplicate submissions&lt;/strong&gt;. The same name appearing multiple times are a separate question and not the subject of this analysis. Some duplication is expected in any real participation dataset; people resubmit, households share names, and common names genuinely recur. The relevant question is whether duplication rates deviate from what the population would predict. The overnight CON windows showed collision excesses consistent with resubmission or household participation. That is a different signal from the overnight PRO deficit, and it points in a different direction&lt;/p&gt;
&lt;p&gt;&lt;strong&gt;What this analysis cannot determine.&lt;/strong&gt; The geographic origin of submissions, the identity of any operator or coordinator, whether the system maintains server-side logs, and the mechanism behind any anomalous pattern. Attribution of intent from behavioral data alone is not supportable. These findings bound the probability of innocent explanation. They do not establish what the non-innocent explanation is.&lt;/p&gt;
&lt;p&gt;I ran this analysis quickly after the GeekWire story published. There may be subtle issues in the methodology I have not caught. I am confident it is directionally correct. If you find an error, I will correct it.&lt;/p&gt;
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