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Evidence governance

Documented Evidentiary Due Diligence

A regulatory determination should not rest on documents alone. It should be possible to reconstruct what was reviewed, what was found, what stayed unresolved, and how the final human determination was reached.

ConceptWEETRA methodology
OutputDetermination Package
IntegritySHA-256 reference hashes

WEETRA structures the evidentiary process behind a regulatory determination. It links the documentation reviewed, the facts extracted, the control results, the contradictions, the limitations, the remediation carried out and the human review events to the final locked determination.

The result is not simply a report. It is a preserved, reviewable evidentiary state.

What documented evidentiary due diligence means

Depending on the review level and mandate, the process can make it possible to demonstrate:

  • what evidence was received;
  • when it entered the controlled workflow;
  • which version was examined;
  • which facts were extracted or recomputed;
  • which source supported each material fact;
  • which contradictions or documentary gaps were identified;
  • which requests for clarification or remediation were issued;
  • which human reviewer validated or rejected a proposed finding;
  • which evidentiary state supported the final determination.
Due diligence does not make uncertainty disappear. It makes the work performed, the basis relied upon and the limitations known at the time demonstrable.

The WEETRA reference process

The following is the WEETRA reference model. The depth of each stage, and the deliverables attached to it, depend on the agreed review level and contractual scope.

  1. 01

    Controlled evidence ingestion

    Documents enter through the controlled workflow. A SHA-256 hash is calculated at ingestion, and each file is recorded with its filename, size, type, uploader and server timestamp.

  2. 02

    Evidence registration and version identification

    Each file becomes a registered evidence record. Records are append-only. A later correction is linked to the original through a supersedes reference rather than replacing it.

  3. 03

    Extraction and canonical fact registration

    Material facts are extracted or recomputed and recorded as canonical facts, each tied to the source that supports it.

  4. 04

    Documentary and computational controls

    Structured controls run across and within the evidentiary domains, comparing declared, extracted and, where possible, recalculated values.

  5. 05

    Contradiction and limitation recording

    Where the record conflicts with itself, or a source cannot carry a claim, the contradiction or limitation is recorded rather than smoothed over.

  6. 06

    Clarification and remediation where included

    When the mandate provides for it, requests for clarification or correction are issued, and their outcomes are recorded.

  7. 07

    Human review and determination

    Automated controls propose; a human reviewer validates or rejects. No status is assigned automatically.

  8. 08

    Determination locking

    Only an authorised senior reviewer or methodology owner may lock a determination. The lock records the reviewer's identity and role, the timestamp, the decision, its justification and the version hashes involved.

  9. 09

    Evidence Manifest and package preservation

    Depending on the level, a versioned Evidence Manifest and a Determination Package are assembled and preserved, linked to the exact versions relied upon.

  10. 10

    Subsequent integrity verification

    A file presented later can be compared against a recorded reference hash to confirm whether it is the same version.

No evidence is silently replaced, and no historical version is overwritten.

The Determination Package

Depending on the review level and mandate, the package may include:

  • the final Determination Report;
  • the documentary inventory;
  • the Evidence Manifest;
  • the evidence register;
  • the canonical fact register, or the relevant extracts;
  • the control results relied upon;
  • the contradiction and limitation register;
  • the remediation history;
  • the human review record;
  • the determination lock record;
  • SHA-256 reference hashes;
  • package and report version information.

Each locked determination stays linked to the exact versions of the facts and evidence relied upon at the moment of decision.

From documents to a chain of explanation

  1. Source document
  2. Registered evidence
  3. Extracted or declared fact
  4. Control result
  5. Contradiction or limitation
  6. Human review
  7. Determination
  8. Locked report
  9. Reference hash and manifest

Document versioning and correction

  • a client cannot silently delete or replace evidence;
  • an incorrect submission can be withdrawn through a controlled correction request;
  • the original remains preserved;
  • a new version is recorded separately;
  • superseded versions remain traceable;
  • the current version and the historical versions are never confused.
Correction does not erase history. It adds a documented new state.

Integrity verification

SHA-256 lets a presented file be compared with a recorded reference hash.

A matching result confirms that the presented file has the same byte sequence as the referenced WEETRA file. A non-matching result indicates that the presented file is not identical to that reference version.

A mismatch can come from editing, format conversion, re-saving, replacement, corruption, or the use of another version. It is a difference in bytes, nothing more, and it is read as such.

How the package can support the organisation

The package may help an organisation:

  • present a structured documentary basis to an internal reviewer;
  • prepare exchanges with an authorised CBAM declarant;
  • organise information for an accredited verifier;
  • respond more coherently to a competent authority or a customs-related request;
  • explain how a determination was reached;
  • tell the historical reviewed state apart from later changes;
  • avoid rebuilding a file from scattered emails and uncontrolled document versions.
On use of the package

The package may be presented or relied upon as an organised evidentiary record, subject to the applicable legal framework, confidentiality rules and the recipient's own assessment.

Review levels

LEVEL I

Initial documentary review

  • hashes calculated at ingestion;
  • internal evidence registration;
  • human-locked determination;
  • controlled final report.

A complete client-facing Evidence Manifest is not automatically included.

LEVEL II

In-depth consistency & defensibility

  • extended documentary mapping;
  • evidence and contradiction registers;
  • remediation history where included;
  • client-facing Evidence Manifest;
  • covered file hashes;
  • structured Determination Package.
LEVEL III

Forensic evidence-chain review

  • advanced evidence-chain reconstruction;
  • adversarial review;
  • deeper contradiction analysis;
  • exact version linkage;
  • enhanced preparation for external scrutiny;
  • advanced evidentiary package.

The levels describe the depth of review and package construction. They are not quality grades, and they do not represent increasing guarantees of regulatory acceptance.

Precise boundaries

Boundaries

Documented Evidentiary Due Diligence is a WEETRA methodological concept. It does not designate an autonomous statutory due-diligence regime.

A WEETRA Determination Package documents the review performed, the evidentiary basis available, the limitations identified and the human determination issued at a defined point in time. It does not transfer the regulatory responsibility that law assigns to the declarant, operator, importer or other responsible actor.

An integrity comparison does not establish the truth, authenticity, authorship or regulatory validity of a document's content. WEETRA does not guarantee that a verifier, a customs authority, a competent authority, a court or another third party will reach the same conclusion, or accept the package without asking for more.

Evidence governance

Preserve today the evidentiary state you may have to explain tomorrow.

WEETRA helps organisations move from scattered documentation to a structured, reviewable and preserved determination record.