ADR-003 — Subject key custody

Status: Accepted (2026-07-16).

Context

Performers will not, in general, run key management. Custody has to be real without pretending the subject is operating HSMs.

Decision

Custodial-with-fiduciary custody is the default for performers: the custodian holds the subject's signing key under fiduciary oversight. Self-custody remains available for sophisticated subjects. Custody model is recorded, not assumed.

Consequences