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Map a new regulation to policies and controls, rule by rule

For: Head of compliance or regulatory change manager implementing a new rule

Pattern: Hierarchical decompositionNeeds live modelsDesigned for 8 to 400 agents
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The pain today

A new regulation arrives with obligations buried in articles, annexes and guidance. The gap analysis becomes a spreadsheet that maps articles to policy titles, not to what the policy text and the controls actually say.

The ask

“I attached the regulation with its annexes and guidance, our policies and procedures, and our control library. Break the regulation into single requirements, tell me for each one which policy text and control covers it, quote both, and list the requirements nothing covers.”

Plain words, as you would say it to a colleague. Edit it to fit your case before you send it.

What you attach or connect

  • Regulation text, annexes and supervisory guidance
  • Internal policies, standards and procedures
  • Control library with descriptions and owners
  • Scope note: entities and activities affected

The unit of work

One worker task per one atomic requirement against the policy set.

Why a swarm fits

A regulation decomposes into chapters, articles and single requirements. Each leaf is tested against a few retrieved policy passages, and chapter-level coverage is only reported once its leaves are verified.

Not for

A short circular that changes one threshold: a compliance officer and one strong model handle it in an afternoon.

The decision tree

6 typed decisions, each with an action for every answer

At fixed moments in a run, the engine puts one narrow question to a decision model. The decision model never writes text: it answers yes or no with a probability, picks from listed options, or gives a score, about a small slice of the material. The engine then does exactly what this tree says, which is what makes the run auditable. The thresholds are the template's design values, not measured results.

  1. Planner, while planning

    Split or keep serialYes or no, with a probability

    While planning

    Does this article impose more than one obligation, each of which could be met or missed on its own?

    Sees only: One article with its paragraphs

    Why: Atomic requirements are what make a mapping checkable.

    • Yes: 0.60 or higherthenSplit the work
    • Unsure: 0.40 up to 0.60thenKeep serial
    • No: below 0.40thenKeep serial

  2. Scope checkYes or no, with a probability

    Before work starts on a unit

    Does this requirement apply to the entities and activities in the scope note, once the article's exemptions are read?

    Sees only: The requirement, its exemptions and the scope note

    Why: Out-of-scope chapters are dropped before any policy is searched.

    • Yes: 0.60 or higherthenAccept
    • Unsure: 0.30 up to 0.60thenEscalate to a strong model
    • No: below 0.30thenSkip this unit

  3. After workers, the judge checks

    Evidence checkA choice among options

    After a worker answers

    Set against the quoted requirement, what does the quoted policy or control text do?

    Sees only: One requirement and the quoted policy or control passage

    Why: Keeps partial coverage from being rolled up as full.

    • Satisfies every elementthenAccept
    • Satisfies some elementsthenMark unresolved
    • Contradicts the requirementthenAsk a person
    • Addresses a different subjectthenReject and retry

  4. Evidence checkYes or no, with a probability

    After a worker answers

    Does the quoted policy text name who does what and when, as opposed to restating the rule or declaring an intention to comply?

    Sees only: The quoted policy passage

    Why: A policy that only repeats the regulation is the classic paper gap.

    • Yes: 0.85 or higherthenAccept
    • Unsure: 0.50 up to 0.85thenMark unresolved
    • No: below 0.50thenMark unresolved

  5. Run control, between rounds

    Retry or stopA choice among options

    After a rejection or low confidence

    Why did this mapping fail?

    Sees only: The rejected mapping, the retrieval log and the requirement

    Why: Separates a search miss from a real gap before it reaches the gap list.

    • No policy passage was retrievedthenReject and retry
    • Passage retrieved and falls shortthenMark unresolved
    • Requirement wording is ambiguousthenEscalate to a strong model

  6. Accountable person, before anything is settled

    Person decidesYes or no, with a probability

    Before anything is reported as settled

    Does this item turn on an interpretation of the regulation, or would it be recorded as a gap to accept or remediate?

    Sees only: The register entry with its coverage status

    Why: Interpretation and accepted risk belong to the head of compliance.

    Accountable: The head of compliance decides interpretation, scope and which gaps are accepted risk or need remediation.

    • Yes: 0.40 or higherthenAsk a person
    • Unsure: 0.15 up to 0.40thenAsk a person
    • No: below 0.15thenAccept

The fleet: who does what

Model tiers by role, not brands: you choose the models. Strong reasoning models plan and reconcile, small fast models do the wide work, and the judge is a decision model from a different family, so it does not share the workers' blind spots.

  1. Planner

    A strong reasoning model splits the regulation into a tree of atomic requirements, keeping definitions and exemptions attached.

    Decisions here:1. Split or keep serial2. Scope check

  2. Workers

    Small fast workers from an open-weight family test one requirement against the candidate policy passages and controls.

    Designed for 8 to 400 agents, one worker task per one atomic requirement against the policy set. Each worker receives only its own unit.

  3. Judge, from a different model family

    A decision model from a different family checks that the quoted policy text actually satisfies the quoted requirement.

    Decisions here:3. Evidence check4. Evidence check

  4. Reconciler

    A strong reasoning model rolls coverage up by article and chapter and keeps partial coverage distinct from full.

    Decisions here:5. Retry or stop

  5. Accountable person

    The head of compliance decides interpretation, scope and which gaps are accepted risk or need remediation.

    Decisions here:6. Person decides

Checked before anything is accepted

  • Each mapping quotes both the requirement and the policy or control text
  • A policy that only restates the rule without a mechanism counts as partial
  • Definitions and exemptions are applied before a requirement is marked out of scope
  • A parent node is covered only when every child requirement is

What comes back

  • Requirement register with covering policy text and control
  • Uncovered and partially covered requirements by chapter
  • Policies that contradict the regulation
  • Draft remediation list by policy owner

What to measure

  • Mappings a compliance reviewer overturns in a sample
  • Gaps found later by audit or the regulator
  • Analyst hours per mapped requirement

Names of measures only. No result is claimed for this template.

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