Gemacode
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Gemacode Research · Applied Mathematics Laboratory · Bilbao

Digital decision systems cannot currently produce verifiable evidence.

This is becoming non-compliant.

Gemacode builds the technical architecture that bridges the gap between what regulation requires and what current systems can demonstrate.

AI Act Art. 13 · Traceability obligation · In force · MiFID II RTS 6 · Algorithmic audit trail · In force · AIFMD · Independent risk evidence · In force · DORA · Operational resilience · In force · EU AI Act Art. 17 · Quality management · In force · AI Act Art. 13 · Traceability obligation · In force · MiFID II RTS 6 · Algorithmic audit trail · In force · AIFMD · Independent risk evidence · In force · DORA · Operational resilience · In force · EU AI Act Art. 17 · Quality management · In force ·

Most regulated entities currently resolve these obligations through manual reconstruction. That gap is structural. It will not be resolved by procedure alone.

Regulatory pressure

The obligation already exists.
Enforcement is accelerating.

Five frameworks already in force converge on a single technical requirement: automated decisions must produce evidence that survives independent scrutiny. Most institutions resolve this through procedure. Procedure is no longer sufficient.

MiFID II · RTS 6
Algorithmic trading systems must maintain complete audit trails for every order, including algorithm parameters at the time of decision.
In force · Enforcement: Active
EU AI Act · Arts. 13–17
High-risk AI systems must be designed for human oversight and produce technical traceability of operation and decision logic.
In force · Technical Standards: In Development
AIFMD
Independent risk function with continuous exposure monitoring and documented evidence of supervision.
In force · Supervisory Focus: Increasing
UCITS
Global exposure calculation with auditable, reproducible reporting chain and continuous regulatory disclosure.
In force · Reporting Obligations: Active
Solvency II
Prudence principle, ongoing systemic risk monitoring, structured documentation at each decision point.
In force · Monitoring: Required

Most regulated entities currently demonstrate these obligations through manual reconstruction. That is a technical gap, not a procedural one.

The technical gap

Current systems cannot demonstrate what regulators require.

Digital self-attestation

Systems that certify themselves

In most architectures, decisions, logs, signatures and timestamps live inside the same digital domain that produced them. If that domain is compromised, the evidence is compromised with it.

Compliance reconstruction

Compliance built on reconstruction

In regulatory audits and litigation, most organisations reconstruct what happened after the fact. The original technical evidence — the state, the context, the path — was never captured.

External reference

Evidence needs an external reference

Strong evidence requires a reference point that is independent of the system it is meant to verify. Software alone cannot provide that independence.

Software can record. Physics can anchor.

Gemacode develops architectures that move decision evidence beyond internal digital assertion — toward structures that include references outside the software layer.

Systems

Two operational systems from the same framework.

QEL · Quantum Evidence Ledger

Decision evidence anchored beyond digital self-attestation

QEL converts automated decisions into structured, verifiable certificates. It does not decide. It observes, structures, and anchors. Its evidence layer is designed to incorporate references outside the purely digital domain.

View system →
AEL · Advanced Execution Layer

A regulatory risk-control layer for financial systems

A structural control layer positioned between investment signals and execution. It applies limits, monitors exposure, and generates audit-ready evidence. It is not a trading system. It does not generate alpha. The system is not regulated. The client is.

View system →
Research architecture

Four layers of research

01 · Mathematical Substrate Decision processes as state transitions.
02 · Physical Evidence Layer Evidence rooted beyond software.
03 · Verifiable Decision Systems Structured certificates, logs and traces.
04 · Regulatory Execution Technical evidence for regulated obligations.

Each layer is formally grounded in the one above it.

Publications

Recent working papers and research notes.

2025 · Physical anchoring

Physical Anchoring of Digital Decision Evidence

Framework conditions under which decision evidence can incorporate physical references external to the digital domain.

→ Available under institutional access
2025 · Decision evidence

Decision Evidence Systems for Regulated AI

Structural requirements for verifiable decision certificates in AI systems subject to regulatory governance obligations.

→ Working paper
2024 · Risk modulation

Structural Control Layers for Financial Risk Governance

A formal approach to bounding execution decisions through non-bypassable architectural constraints in regulated portfolios.

→ Available under institutional access
Institutional access

Technical documentation under controlled access

System overviews, regulatory mappings, physical evidence specifications and working papers are available to qualified institutions. Access is individual, time-limited and monitored.

Access is subject to qualification review. Not all requests are granted. Documents are not downloadable.