3. Normative Language and Conformance
3.1 Normative Terms
The terms shall and must indicate mandatory requirements. The terms should, may, example, rationale, recommended practice, informative, or guidance indicate non-normative material unless explicitly referenced by a mandatory control.
3.2 Binary Rule
Every normative DACS control shall resolve to exactly Pass or Fail when applicable to a stated decision scope. A control that is not applicable may be recorded as Not Applicable only under the explicit applicability rule below. DACS does not permit Unknown, Partial Pass, Pending, or equivalent intermediate control results.
A control may be Not Applicable only when a recorded Applicability Rule evaluates false for the stated decision scope. Not Applicable is not a Pass. The Conformance Record shall preserve the rule reference and the evidence that caused the rule to evaluate false. Uncertainty about applicability shall not be recorded as Not Applicable.
An exception may allow constrained use, but it does not convert a failed control into a passed control. The Conformance Record shall preserve the failed condition, exception authority, constraint, review date, and resulting readiness state.
3.2.1 Deterministic Evaluation Algorithm
Control numbering identifies catalog entries; it does not prescribe execution order. Establish the scope through CORE-001. Then evaluate CORE-002 before CORE-003 and before any control that depends on a conditional rule or authority reference. For each control, resolve the governing rules, determine applicability, inspect required evidence, test the Pass criteria, and record the result.
If the recorded Applicability Rule evaluates false, record Not Applicable with the reason, rule reference, and supporting facts. If it evaluates true, evaluate the applicable control. If a required rule or predicate cannot be resolved, record Fail for the affected control; do not infer Not Applicable.
Record Pass only when every mandatory Pass criterion is true. Every required evidence element must also be present, retrievable, independently supported, and linked to the stated decision scope. Record Fail if any required criterion, evidence element, rule, authority, threshold, version, or condition cannot be established. If CORE-002 fails, dependent controls with unresolved prerequisites shall Fail.
A conditional predicate is a condition that affects whether a requirement applies or how it is tested. Examples include whether an item is material, an action is authorized, or two representations are equivalent. The recorded rule or authority reference must resolve the condition before the dependent control is evaluated.
Where a Pass statement joins conditions with “and,” every condition is mandatory. Where it uses “or,” each listed alternative is an acceptable evidence path only if the control or a recorded Equivalence Rule explicitly permits it. An approved exception may permit constrained use and a Caution readiness state, but the failed control remains Fail.
3.2.2 Applicability, Materiality, Approval, and Equivalence Binding
Terms such as material, where applicable, where required, equivalent, approved, authorized, compatible, and multi-value shall be resolved using recorded rules or authority references for the decision scope. Assessor judgment alone shall not establish those conditions. The governing rule shall exist independently of the result it governs. It shall not depend on a downstream record that needs the same unresolved condition to be valid. If recorded evidence cannot resolve a required condition, the affected control shall Fail.
3.2.3 Missing Evidence and Exceptions
Missing evidence is a control failure when the evidence is required by an applicable control. A missing record, missing field, inaccessible record, expired record, unresolved authority, or unresolved rule reference shall not be treated as an exception, Caution, or Not Applicable by default. Exception handling occurs only after the control result is recorded and cannot alter that result.
3.2.4 Non-Circular Evidence and Dependency Rule
The DACS control dependency model shall be a directed acyclic graph. This means no control may depend directly or indirectly on itself. Each control shall be testable using its own evidence and the recorded outputs of its declared prerequisites. A reference to a record completed later shall not become a prerequisite for an earlier assessment. If independent authoritative evidence cannot resolve a circular dependency, the affected control shall Fail. Correct the dependency before releasing the affected control set. The DACS Control Dependency Map records immediate and inherited dependencies, their required statuses, and evaluation order. Control numbers are catalog identifiers.
3.2.5 Prerequisites and Dependency-Ordered Evaluation
The Prerequisites entry under each control title states what must be established before that control can Pass. It uses two labels: Pass required and Recorded result required. Assess the listed controls first for the same decision scope, relevant evidence, and effective versions. Evidence collection, failure diagnosis, containment, and remediation may continue when a prerequisite has failed. These activities do not authorize material use.
Pass required means the prerequisite control must have an evidence-backed Pass for the applicable scope and evidence. If that requirement is unmet, the dependent control cannot Pass. An exception does not convert the prerequisite failure into Pass.
Recorded result required means an evidence-backed assessment result and its supporting records must be available. The result may be Pass, Fail, or Not Applicable with reason. A recorded Fail allows the current control to test failure handling, containment, recording, or another stated obligation. It does not satisfy a separate Pass requirement or authorize material reliance.
Resolve conditional dependencies under the recorded Applicability Rule. Not Applicable is not Pass and does not remove another requirement automatically. A dependency may be excluded only when the recorded rule and scope facts establish that its output is not needed for the current control. Keep the reason and any alternative required evidence. Unresolved dependency applicability or missing required prerequisite evidence prevents Pass.
List the nearest necessary prerequisites rather than repeating the entire chain. An earlier dependency may be omitted from the displayed list only when a retained prerequisite guarantees the earlier dependency's required status and evidence. A recorded result alone does not guarantee that the assessed control passed or that its own prerequisites were met. Retain independent branches and distinct status requirements, even within one profile. Check the full chain in the Dependency Map; do not infer coverage from control numbers.
The Requirement and Pass/Fail sections describe the current control's own obligation. Apply the prerequisite rules together with the global assessment algorithm in Section 3.2.1. Every applicable mandatory Pass condition and evidence element must be satisfied. The local Fail section identifies control-specific failure conditions; it is not an exhaustive replacement for the global rules.
Evaluate controls incrementally using their own evidence and established prerequisite outputs. If a prerequisite result, its evidence, scope, or effective version changes, reassess the affected dependent controls unless a recorded rule requires a broader assessment. Validate the Specification and Dependency Map together. References and required statuses must agree. No dependency cycle is permitted. Prerequisites must precede their dependent controls in the declared assessment order.
3.2.6 Assessment and Record Completion
Record collection, control evaluation, Gate authorization, and completion of a Conformance Record are separate activities. Collecting or naming a record shall not establish Pass, a Gate readiness state, or permission for material use.
Scope facts, rule references, profile applicability, and other supporting evidence may be collected before the related Gate Record or Conformance Record is completed. Linking independently established evidence to a record completed later does not make that evidence depend on the later record being valid. This also applies when rules use identity or semantic facts: collecting those facts is separate from recording Pass for the related controls. Where a control expressly requires a prior Gate decision or prior control result, that prerequisite must already exist and be valid.
Evaluate the controls needed for the proposed transition or action from independently established evidence. The Gate shall record the controls actually evaluated, their results, the applicable authority, and the resulting readiness state. It shall not claim that a control has passed merely because its final record will be completed later.
When execution or durable persistence creates evidence needed by an execution-completion control, evaluate that control when the required evidence exists or its declared deadline expires. Identify required follow-up evaluations separately from the controls evaluated at the pre-action Gate. An incomplete evaluation is not Pass or Not Applicable and does not create an intermediate control result. Do not claim full decision-scope conformance while a mandatory evaluation remains incomplete.
A complete Conformance Record shall preserve all applicable control results and required evidence references for the claimed scope. It may link earlier independently established profile or control evidence to the final determination. Record-existence and structure checks test the record and its fields. They shall not use the conformance claim itself as evidence that other controls passed.
Keep the original pre-action Gate determination unchanged. Later persistence verification, execution findings, failures, exceptions, and reassessments shall be new linked records. A later failure governs subsequent reliance and remediation; it shall not erase what was captured or authorized at the earlier time.
3.3 Prohibited Subjective Sufficiency Language
Normative controls shall not rely on phrases such as accountable enough, trusted enough, appropriate enough, strong enough, sufficient enough, high quality, reasonable, adequate, or acceptable unless the control defines the evidence, threshold, rule, authority, or Gate readiness state that makes the phrase testable. Terms such as approved, authorized, compatible, equivalent, or material are testable only when the applicable authority, threshold, Materiality Rule, Applicability Rule, or Equivalence Rule is recorded.
3.4 Control Results and Gate Readiness States
Control results are Pass, Fail, or Not Applicable. Gate readiness states are Proceed, Caution, Stop, and Quarantined. These are separate concepts.
| State | Meaning | Allowed use |
|---|---|---|
| Proceed | All controls applicable to the Gate are Pass; controls that do not apply are recorded Not Applicable with reason. No failed control is being overridden for use. | Use is permitted only within the recorded scope and while the readiness validity condition remains true. |
| Caution | One or more conditions require explicit constraint, monitoring, remediation, or an approved constrained-use exception. Any failed control remains Fail. | Use is permitted only within the recorded constraint, authority, and readiness validity condition. Caution never converts Fail into Pass. |
| Stop | A completed evaluation identifies a failed control, prohibition, missing authority, invalid context, contract violation, or other rule that prohibits stated use. | Use is not permitted for the stated material decision scope. |
| Quarantined | Candidate evidence has not completed the required evaluation or is held pending review or remediation and is not ready for stated use. | Evidence may be explored, reviewed, remediated, or routed through additional Gates but shall not be relied on for material decisions. |
Quarantined allows candidate evidence to be captured and reviewed without relying on it for material decisions. Stop prevents failed, prohibited, or unauthorized evidence from being used for the stated decision scope.
3.5 Conformance Rule
DACS conformance is determined for a stated decision scope, not for an enterprise, platform, vendor, model, or repository in general. Full DACS conformance for a decision scope requires all applicable mandatory controls to Pass or be recorded as Not Applicable with reason. An approved exception for a failed applicable control may allow constrained use and a Caution readiness state. That scope shall not be represented as fully DACS-conformant until the failed control passes or is no longer applicable.
3.6 DACS Capability Levels Are Informative
DACS separates control conformance from organizational capability. Control conformance remains binary for a stated decision scope. DACS Capability Levels describe how an organization applies DACS across scopes over time: the breadth of adoption, repeatability, governance, operating practices, and ability to adapt. A Capability Level never causes a control to Pass. A conformant decision scope never gives an organization a higher Capability Level by itself.
Annex C explains the distinction between organizational Capability Level and decision-scope conformance. It does not define the levels or change any control requirement. The DACS Capability Levels and Organizational Adoption Guide defines the levels, evidence expectations, organizational boundary, progression, retention, loss, and public claims.
3.7 Principle of Non-Automatic Trust
Discovery may be automated. Readiness shall not be assumed merely because discovery occurred or because evidence is technically accessible. Stated use under DACS requires an evidence-backed Gate Record with a resulting readiness state anchored in approved meaning, authority, rules, thresholds, stewardship, or authorized operating procedures.
3.8 Public Claims Boundary
Public claims about DACS shall preserve the distinction between conformance, alignment, support, certification, training authorization, partner status, and vendor or product claims.
An aggregate count, composite or weighted score, grade, percentage rating, or probability of defensibility shall not be represented as a DACS conformance determination or Gate readiness state. Counts describe evidence-backed findings; they do not grant permission for use.
- DACS-conformant decision scope may be claimed only when the Conformance Record shows all applicable mandatory controls Pass or are Not Applicable with reason for the stated decision scope.
- DACS-aligned may describe informative materials, practices, tools, or implementation efforts that intentionally follow DACS language but do not claim DACS conformance.
- DACS-supporting tool, platform, service, or evidence source means the tool or service may provide evidence, workflows, controls, or records used in DACS assessment or control execution. It does not mean the tool, platform, service, vendor, or implementation is broadly DACS-conformant or DACS-certified.
- DACS Certified, DACS-certified vendor, DACS-certified platform, DACS-certified product, DACS-compliant platform, and similar claims shall not be used unless DataVaultAlliance Holdings LLC has published an applicable certification, assessment, vendor-adherence, or claims program.
- Authorized training or partner status permits approved education, enablement, or delivery activity only within the scope granted. It does not create control conformance, product certification, vendor certification, or certification of a customer decision scope by itself.