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Applied and bridge studies study record
Hollow Win theory & mechanisms

DORA, the EU AI Act, and the self-application problem

STATUS · Manuscript in progressSSRN · Not yet posted
Open teaching deckSSRN — not yet postedPublication record
MECHANISM
Identify the incentive structure and the condition that would falsify the claim.
RULE CHANGE
Read the intervention only after the paper shows how the current payoff space fails to support system welfare.
READER USE
Use the summary to see where private gain creates system exposure, then check the study record.
Contribution — what this adds to the conversation
Decision Accounting's seventeen-field record satisfies the documentation function of DORA Articles 5, 6, 8, 11, 13, 17, 18, 19, 28, and 30 when it passes the five-minute/stranger test. The same record satisfies the documentation function of EU AI Act Articles 9, 11, 13, 14, and 26 for high-risk AI systems. A tool that scores Decision Accounting record quality is not high-risk under the AI Act unless its intended purpose or actual use places it in Annex III categories affecting natural persons.
WHAT'S NEW · Decision Accounting's seventeen-field record satisfies the documentation function of DORA Articles 5, 6, 8, 11, 13, 17, 18, 19, 28, and 30 when it passes the five-minute/stranger test. The same record satisfies the documentation function of EU AI Act Articles 9, 11, 13, 14, and 26 for high-risk AI systems. A tool that scores Decision Accounting record quality is not high-risk under the AI Act unless its intended purpose or actual use places it in Annex III categories affecting natural persons.

The paper applies Decision Accounting to the Digital Operational Resilience Act (DORA) and the EU AI Act, showing how a seventeen-field decision record can satisfy documentation obligations under both regulations. It resolves the self-application problem: a tool that scores Decision Accounting records is not high-risk unless it affects decisions about natural persons. The framework reduces documentation fragmentation but requires naming the flawed game, recording the Missing System Theory, and preserving human authority.