SEBBI.PRO · The Rule · The Test · Check a proof

A PROPOSED CHANGE IN THE LAW

A log only its owner can vouch for is a statement, not evidence.

Courts, regulators and insurers still accept audit logs that the organisation relying on them could have edited at any time, with nobody able to tell. There was no practical alternative when that habit formed. There is one now, it is published, and checking it is free. So the question is simple: now this exists, why is the other still accepted?

Test your own log in one minuteRead the rule

The Independent Check Rule (ICR-1)

  1. A self-attested record is a record whose integrity can be shown only by the person relying on it, or by someone acting for them.
  2. An independently checkable record is a record for which a person with no access to the holder's systems, and no need to trust the holder, can detect any later alteration, deletion or back-dating, using a published method.
  3. No presumption of integrity applies to a self-attested record. The person relying on it must show that it has not been altered since it was made.
  4. An independently checkable record that passes its check is presumed unaltered since the time of its independent timestamp, unless the contrary is shown.
  5. The rule is neutral as to method. Any published method that meets the second clause qualifies.

The rule is about whether a record was changed after it was made. Whether the system that made the record was working correctly is a separate question, and the rule leaves the court's time free for it.

Sealed 2026-11-10 15:39:56 UTC in block 37723. Fingerprint 60fc822c780630eee5c627a1e23369fca300c68506132c8d57e74da289667611

Why now

THE PRESUMPTION

In criminal cases in England and Wales a computer is presumed to have been working correctly unless the contrary is shown. The safeguard in section 69 of the Police and Criminal Evidence Act 1984 was repealed in 1999.

THE REVIEW

The Ministry of Justice called for evidence on the presumption in January 2025. Peers moved amendments to remove it in February and March 2026. No replacement has been settled.

THE PRECEDENT

EU law already gives a qualified electronic time stamp a presumption of the integrity of the data it is bound to: eIDAS, Article 41(2). Security law already measures conduct against the state of the art.

THE DEADLINE

Article 12 of the EU AI Act requires automatic logs for high-risk AI systems. The standards that will say what a sufficient log is are being written now.

State of the Art Notice

SEALED 10 NOVEMBER 2026

Methods that let a person outside an organisation detect any alteration, deletion or back-dating of that organisation's logs and records are published, are free to check, and are in production use. From the sealed date of this notice, no one relying on a self-attested log can say that an independent check was unavailable, unproven or unaffordable.

SINCEMETHODPUBLISHED AS
1991Linked time-stamping of digital documentsHaber and Stornetta, 'How to Time-Stamp a Digital Document', Journal of Cryptology 3(2)
2001Trusted time-stamp protocolIETF RFC 3161
2013Append-only public logs with inclusion and consistency proofs (Certificate Transparency)IETF RFC 6962; RFC 9162 (2021)
2014Qualified electronic time stamps with a legal presumption of the integrity of the dataRegulation (EU) No 910/2014 (eIDAS), Article 41(2)
2016Timestamps committed to the Bitcoin blockchain, checkable by anyoneOpenTimestamps (opentimestamps.org), open source
2021Public transparency logs for software signingSigstore Rekor, open source
2026Sealed, Bitcoin-timestamped records of AI decisions with a free offline verifiersebbi.pro, https://sebbi.pro/forever

Checking is free under every method listed. Timestamping a fingerprint through the public notary at https://sebbi.pro/bitcoin is free. Continuous sealing with sebbi.pro is 50p per device per month. What leaves the organisation: a fingerprint, never the record.

Sealed 2026-11-10 15:39:56 UTC in block 37722 and timestamped into Bitcoin, so the date of this notice cannot be disputed. Fingerprint e17d13ed797e4162747782e69d0bdb4da1c31daced0577702996db89a02e81f5. Machine-readable: https://sebbi.pro/.well-known/state-of-the-art-logging.json

Six questions for anyone relying on a log

For a lawyer in disclosure, an insurer handling a claim, an auditor, a regulator, or a board about to rely on its own records.

  1. Who had the technical ability to alter or delete entries in this record between the day it was made and today?
  2. What evidence, held outside your organisation's control, shows that no entry has been altered?
  3. What evidence, held outside your organisation's control, shows that no entry has been deleted?
  4. What evidence, held outside your organisation's control, shows when each entry was made?
  5. Can an independent expert confirm those three things without access to your systems and without relying on your staff, using a published method?
  6. Methods that allow exactly that have been published since 1991 and are free to check. Why was none used for this record?

Model clause

For supply contracts, AI service terms and policy wordings.

Independently checkable records. The Supplier shall keep the Records in a form in which a person with no access to the Supplier's systems, and no need to trust the Supplier, can detect any alteration, deletion or back-dating of a Record after it is made, using a published method. The Supplier shall give the Customer, on request and without charge, everything needed to carry out that check. A Record that cannot be checked in this way shall not be relied on by the Supplier as evidence of the matters it records.

The open submission

Published in full, and filed with the people who decide.

The problem

In criminal proceedings in England and Wales a computer is presumed to have been working correctly unless the contrary is shown. Section 69 of the Police and Criminal Evidence Act 1984, which put the burden the other way, was repealed by section 60 of the Youth Justice and Criminal Evidence Act 1999. The Ministry of Justice called for evidence on the presumption in January 2025. In February and March 2026 peers moved amendments to the Victims and Courts Bill to remove it. The difficulty on every side has been the same: nobody wants trials slowed by proof that every device works, and nobody has offered a test a court can apply quickly.

One part of the problem now has a clean answer

Two different questions are bundled into 'is this computer evidence reliable'. The first is whether the system that produced the record was working correctly. The second is whether the record has been changed since it was made. The second question no longer needs argument or expert evidence. A record can be kept so that any change, deletion or back-dating is detectable by a person outside the organisation, at no cost to check.

The proposal

Adopt the Independent Check Rule (ICR-1) for records produced by software: no presumption of integrity for a self-attested record, and a presumption of integrity for a record that passes an independent check. The rule is neutral as to method and names no product. It keeps uncontroversial evidence moving, because an independently checkable record is confirmed in seconds, and it ends reliance on records that only their owner can vouch for.

The law already does this elsewhere

Article 41(2) of Regulation (EU) No 910/2014 (eIDAS) gives a qualified electronic time stamp a presumption of the accuracy of the date and time and of the integrity of the data it is bound to. Security law already measures conduct against the state of the art: Article 32 of the GDPR and UK GDPR requires appropriate measures having regard to the state of the art and the cost of implementation. Article 12 of the EU AI Act requires automatic logs for high-risk AI systems; the standards that will say what a sufficient log is are being written now.

The evidence

The State of the Art Notice published with this submission lists the methods, from 1991 to today, and is itself timestamped so its date cannot be disputed. The Editable Log Test lets any person change one line of a log on their own phone and see that nothing outside the organisation records the change, then see the same change caught to the line. Both are free and public.

What we ask

That the Independent Check Rule be considered in the Ministry of Justice's work on evidence generated by software, in rules of court on the reliability of computer evidence, and in guidance on the weight to be given to logs in regulatory and civil proceedings. We will give evidence, in writing or in person, and will demonstrate the test.

sebbi.pro (Monop Content). This page proposes a change in the law; it is not legal advice. Sealed 2026-11-10 15:39:56 UTC in block 37726.

The petition wording

TITLE

End the legal presumption for computer records only their owner can verify

WHAT WE WANT THE GOVERNMENT TO DO

Change the law so that a computer record is presumed unaltered only if someone independent of its owner can check it. Records that only their owner can vouch for should carry no presumption, and the owner should have to show they were not changed.

WHY

Courts in England and Wales presume a computer was working correctly unless the contrary is shown. The Post Office Horizon scandal showed where that leads. Published methods now let anyone detect a change, deletion or back-dating in a record without trusting its owner, and checking is free. EU law already gives qualified time stamps a presumption of integrity. The same principle should apply to logs used as evidence: independently checkable, or no presumption.

Put your own log to the test

0 tests sealed · 0 self-attested

Load any log on your phone, change one line, and see who could tell. Nothing is uploaded.

Run the Editable Log TestTimestamp a fingerprint freeSeal every record: get a key

Can an audit log be edited without anyone knowing? · What is a self-attested log? · What is the Independent Check Rule?

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