The DMA does give the Commission a power to appoint independent external experts. It is discretionary, and it verifies after deployment. Here is what closes the gap it leaves regardless.

A reference mapping of 69 questions professionals ask about proving DORA compliance to the corresponding term in the SOURCE 0 doctrinal vocabulary.

A gatekeeper designation ruling and a pending interoperability dispute are frequently treated as the same question. They are not. One determines who the Digital Markets Act applies to; the other determines what standard of evidence a regulator will accept once it does. This article examines the distinction the European Commission has already drawn, and the structural parallel it carries for pre-execution evidentiary architecture.

The Digital Omnibus on AI defers the enforcement of high-risk obligations but leaves evidentiary exposure unchanged. When a system acts before the deferred deadlines, the governance state operative at T-0 remains the central question in civil, insurance, and contractual proceedings. The postponement affects regulatory temporality, not the requirement to hold an independently fixed, opposable governance record. The proof gap persists throughout the deferral window, closed only by a pre-execution cryptographic attestation architecture such as SOURCE 0.

Governance only becomes enforceable when three conditions are simultaneously met: T‑0 fixation, structural independence (S ∩ C = ∅), and legal opposability. Without these properties, no post-execution record can establish a governance state that was never sealed. This article articulates the architectural conditions under which governance ceases to be a management assertion and becomes a verifiable system property.

States do not lose climate litigation because their policies were inadequate. They lose because they cannot prove, with forensic finality, what those policies were based upon at the moment they were adopted. SOURCE 0 seals that proof before litigation exists. The Irish multi-generational climate case as paradigmatic demonstration. SOURCE 0 Doctrine Series — Authoritative Public Release.

Landgericht München I, 28 May 2026. Google bore direct liability for AI-generated content. The defence it did not pursue — proof of E(T₀) singularity — did not exist.

This article defines the evidentiary boundary of autonomous AI intent and introduces the Intent Seal — the pre‑execution proof that turns Operational Intent into a judicial fact.

SOURCE 0 — Evidentiary Sovereignty for Autonomous Systems

SOURCE 0 introduces the first evidentiary architecture designed for autonomous systems operating under endogenous observation. It establishes a structural truth: no system can verify itself without perturbing itself. Instead of denying this limit, SOURCE 0 makes it explicit, measurable, and legally enforceable.

Across the European regulatory landscape — NIS 2, DORA, AI Act, eIDAS 2, and the EU Customs Trust & Check regime — a unified expectation is emerging: proof must be contemporaneous, independent, and externally verifiable.

At the core of SOURCE 0 is the Historical Reality Dossier (HRD): a sealed, pre‑execution evidentiary record, anchored through qualified timestamps and held under judicial custody. It transforms digital events into sovereign, regulator‑grade evidence.

SOURCE 0 is not a compliance framework. It is a doctrine of evidentiary sovereignty. Compliance is no longer declared — it is proven, sealed, and timestamped at T‑0.