HITL and EU-aware governance for brownfield systems
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Juan Antonio Breña Moral Engineering @ IG Group, EU Division
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"Make it work, make it right, make it fast." - Kent Beck "Lead me, follow me, or get out of my way.", "Pressure makes diamonds." - George S. Patton Jr. |
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Source: Leavitt's Alignment Model (1965) >> People, Process and Technology
Framework
ACT I
Implementation accelerates. Context and review capacity do not.
💥 Production breaks
The checks proved the implementation—not the whole consequence.
RenamecustomerIdtoclientId.
record Order(String clientId, BigDecimal total) {}
Locally correct. What else depends on this contract?
customerId → clientIdThe repository cannot always be the unit of correctness.
Behavior already exists in code, data, and operations.
Decisions and ownership span teams, repositories, and time.
Consumers and contracts can fail outside the changed repository.
AI can produce the rename quickly. Discovering its consequences still requires people, evidence, and time.
Rename customerId
to clientId
clientId compatiblycustomerId after adoptionSame requirement. Different context. Different plan.
Parallel Change: expand → migrate → contractMost coding agents start at task and repository.
Many
dependency failures live outside them.
Diff
Repository tests
CI status
Agent summary
External consumers
Uncertainty
Applicable controls
Decision authority
Without system context, a merge approval can become cosmetic oversight.
ACT II
Classify → Expose evidence → Route → Decide → Observe.
Autonomy may propose. Authority must decide. Evidence must connect the two.
A human presence does not guarantee a human judgment.
Without them, approval is human-as-a-button.
Start with impact and uncertainty. Autonomy, reversibility, data, rights, safety, sector, and applicable law can raise the level.
The goal is effective control where consequences matter, not approval everywhere.
The diff proposes the change; the evidence package makes the consequence reviewable.
“The customerId migration was validated successfully.”
Checks are green.
The diff looks reasonable.
APPROVE
Which consumers were checked?
What remains unverified?
How is compatibility preserved?
What triggers rollback?
The right reviewer depends on the risk, not on who is available.
A reviewer needs real alternatives to “Approve.”
Monitor, roll back, preserve evidence, and improve the control that failed.
Prediction ↔ outcome ↔ corrective action
ACT III
Laws, standards, and frameworks become useful when they change engineering decisions.
HITL is the decision mechanism connecting policy to execution.
Article 14 requires effective human oversight for applicable high-risk AI systems.
Using an AI coding agent does not by itself classify the software being changed as a high-risk AI system.
Classify the deployed system and use case first. Apply human review, intervention, auditability, and rollback as engineering controls regardless.
Regulation (EU) 2024/1689These are routing signals—not final applicability determinations. Put broader product, platform, and market lenses in the appendix.
Development governance controls the agent-created PR. System regulation depends on what the deployed system does and where it operates.
CLOSE
Turn human presence into accountable human judgment.
Agents may propose.
Accountable humans decide.
The system must remember why.
Classify · Challenge · Trace
🙏 Thank you 🙏
AI inventory · ownership · generated-code review · provider and data boundaries · risk treatment · monitoring · corrective action
Functional suitability · performance · compatibility · interaction · reliability · security · maintainability · flexibility · safety
Use these as prompts for accountable legal and compliance owners, not as automatic applicability claims.
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