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Praxikon

Example from the AI agent safety scan

AI agent passport: what a reviewed AI agent looks like

An agent passport sets out on one page what an AI agent may read, send and change, which rules apply, what has been arranged and what is still open. It is meant for the board, procurement or the insurer. Below is a filled-in passport for a municipal agent that handles reports about public space.

Fictional example

The Municipality of Exampletown, the agent, the vendor, the names and the dates are fictional. The passport shows what the review looks like, not what applies to your agent: that depends on what your agent can actually do.

By Zahed Ashkara, AI and privacy legal adviser

Agent passport

Fictional example
Organisation
Municipality of Exampletown (fictional)
Agent
Public space reports agent
Owner
Team lead for public space reports
Version and date
Version 1, 2 November 2026 (fictional)
Next review
On every major change, and within six months at the latest

The agent reads new reports from the web form and the app (a loose paving stone, a broken street light, litter), asks the resident a follow-up question in the form where needed, sets category and location, checks whether a report already exists for that spot and prepares a draft case for the right team in the case system. A staff member picks up the case.

1.Entry in the agent register

In order
Vendor and model
Vendor of the reporting platform (fictional), with a language model from a model provider through that platform
Connections and permissions
Reads the web form and the app; creates draft cases in the case system; no access to the population register or to other cases; fetching web pages is switched off
Personal data
Name, email address and optionally the phone number of the resident, the location, the free text and photos, which may show people or number plates
Role under the GDPR
The municipality is the controller, the vendor the processor, with a data processing agreement
DPIA
Carried out before going live, with date and reason in the register
Algorithm Register
The municipality publishes the agent. According to the Algorithm Register itself, a legal duty has been announced but not yet introduced (as of 5 November 2026)

2.The dangerous triangle

Measure taken

At intake

  • Reads outside content
  • Sees confidential data
  • Sends something out by itself
  • 3/3

After the measure

  • Reads outside content
  • Sees confidential data
  • Sends something out by itself
  • 2/3
At intake
All three legs were present: the agent read reports from residents (outside content), saw the names and contact details of other residents when looking for duplicate reports (confidential) and answered the resident in the form (outward). A hidden instruction in a report could therefore make the agent pass on other people's data.
Measure
The confidential data leg has been removed: the search returns only the case number, category and status, without data about other residents. Fetching web pages is switched off, because an agent can also put data in a web address.
Outcome
The combination of three is broken. If a connection is added, the triangle is tested again.

3.Human approval and Article 22 GDPR

In order
What the agent does itself
Ask follow-up questions, propose category and location, prepare a draft case
What only a staff member does
Close, reject or pass a report on to enforcement, and every message to the resident other than the fixed acknowledgement
Article 22 GDPR
The agent takes no decisions with legal or similarly significant effects: a staff member who looks at the report takes them. Meaningful human involvement beforehand takes a decision outside Article 22; rubber-stamping does not. That is why the municipality measures how often staff depart from the proposal.
Enforced in
The permissions in the case system, not only in the instructions to the model

4.Logging and kill switch

In order
Logging
Every call to a connection, every proposal by the agent and what the staff member did with it, in logs the agent cannot change, with a recorded retention period
Kill switch
The team lead and the application manager can switch the agent off; reports then continue through the manual queue and the agent's access is revoked
Last test
Kill switch tested before going live (fictional date)

5.Disclosing that it is AI (Article 50 AI Act)

In order
Role under the AI Act
The municipality had the agent developed and puts it into service under its own name. It is then the provider itself and Article 50(1) falls to it.
What the resident sees
At the first question in the form, the resident is told they are talking to an AI assistant of the municipality (Article 50(1) and (5)). According to the Commission guidelines (point 31), an agent also discloses on whose behalf it acts; that is not literally in Article 50 and the guidelines are not binding.
Applies since
2 August 2026
High risk
No. The agent does not evaluate whether someone is eligible for an essential public benefit or service (Annex III, point 5(a)) and falls under no other point of Annex III. For Annex III the high-risk requirements apply from 2 December 2027; if the task changes, test again.
AI literacy
Staff who review the proposals have been trained (Article 4 AI Act)

6.Agreements with the vendor (Article 28 GDPR)

Open point
Data processing agreement
Signed
Training on municipal data
Excluded in the contract. If a vendor may use your data to train its model, it becomes a controller for that purpose itself and you need a legal basis to provide that data.
Sub-processors
Open point: the model provider is a sub-processor, but the municipality's prior written authorisation has not yet been recorded (Article 28(2))
Incidents
The vendor notifies the municipality of a breach without undue delay (Article 33(2))

7.Incident reporting guide

In order
Why three laws
A municipality is an essential entity under the Dutch Cybersecurity Act (Article 8(1)(h)). Besides the GDPR, the reporting clocks of that Act therefore apply too. The AI Act reporting duty of Article 73 rests on the provider of a high-risk system, and this agent is not one.
What happensWhich lawReport toDeadline
The agent shows or sends personal data of another residentArticles 33 and 34 GDPRDutch Data Protection Authority; in the event of a high risk also the data subjectsWithout undue delay and where feasible within 72 hours, unless the breach is unlikely to result in a risk. Recording it internally is always required (Article 33(5)).
A significant incident with the reporting platform, for example a disruption caused by misuse of the agentArticles 25 to 29 Dutch Cybersecurity ActThe CSIRT and the competent authorityEarly warning within 24 hours, notification within 72 hours, final report within a month of the notification
The vendor discovers a breach on its sideArticle 33(2) GDPRThe vendor notifies the municipality, which then assesses whether it must reportWithout undue delay
A serious incident with a high-risk systemArticle 73 AI ActNot applicable as long as the agent is not a high-risk system; otherwise the provider reports to the market surveillance authorityImmediately and at the latest within 15 days; in the event of a death 10 days; for a widespread infringement or a disruption of critical infrastructure 2 days

8.Signed opinion

Open point
Opinion
Fit for use on one condition: measure 2 below is completed before the agent is rolled out more widely

The three measures that remove the most risk

  1. 1.Let the duplicate search return only the case number, category and status, so the agent sees no data about other residents.Measure taken
  2. 2.Record the written authorisation for the model provider as a sub-processor, with the exclusion of training on municipal data.Open point
  3. 3.Test the kill switch periodically and after every change to the platform, and try a hidden instruction in a report text or with a photo while doing so.Open point

Opinion

In this form the public space reports agent is fit for use on one condition: the authorisation for the sub-processor is recorded before the agent is rolled out more widely. The dangerous triangle is broken, decisions stay with staff and residents know they are talking to AI.

Example, not signed. A real agent passport carries the name, the date and the signature of the reviewer.

What the passport is for

  • The board sees on one page what the agent may do, what has been arranged and what is still open.
  • Procurement and contract management see which agreements with the vendor are still missing.
  • The DPO, the CISO and the insurer get evidence, with the legal provision for every finding.
  • When an incident happens, the reporting guide is ready: who reports what, where and within which deadline.

Start with the agent register yourself

The passport builds on the entry in the agent register. The free agent dossier contains the agent register in Excel, with fourteen fields per agent, and a board deck on AI agents. You receive it by email.

Download the agent dossier

An agent passport for your own agent

With the AI agent safety scan, Praxikon maps for each agent what it may read, send and change, and delivers an agent passport, an incident reporting guide and a signed opinion with the three measures that remove the most risk. Fixed price per agent, proposal within three working days.

Frequently asked questions about the agent passport

What is an agent passport?

A one-page summary for each AI agent: what it does, what it may read, send and change, which rules from the GDPR, the AI Act and, where needed, the Dutch Cybersecurity Act apply, what has been arranged and what is still open. It is a working format from the AI agent safety scan, not a document required by law.

Is an agent passport mandatory?

No. No law prescribes an agent passport. As a controller, however, you must be able to demonstrate that you comply with the GDPR (Article 5(2) GDPR), and the Dutch Data Protection Authority considers a clear and up-to-date overview of agents and their permissions necessary. The passport is one way to demonstrate that.

How does it differ from the agent register?

The agent register is the list with one entry per agent. The passport is the review of one agent: it takes over that entry and adds the dangerous triangle test, approval, logging and kill switch, Article 50, the vendor, the reporting guide and the opinion.

Why does an approved passport contain an open point?

Because the opinion must be honest about what has not been arranged yet. What is unknown or not recorded appears in the passport as an open point and never as in order. The opinion then states the condition under which the agent is fit for use.