{
  "schema": "cortist.milestone.operational-protocol.v2",
  "version": "2026-10-27-v2",
  "publishedDate": "2026-10-27",
  "referenceDate": "2026-10-27",
  "status": "editorial_draft_for_external_validation",
  "purpose": "Candidate-level source-anchored operational resolution protocols for exactly CM-003 and CM-004. Not a formal forecast lock, probability, scoring event, final external legal opinion or verified outcome.",
  "supersedesExistingCandidate": false,
  "predecessor": "/data/milestones/source-audit-v1-20261027.json",
  "originalQuestions": "/data/milestones/registry-v1-20261027.json",
  "activeForecastLocks": 0,
  "newProbabilities": 0,
  "resolvedOutcomes": 0,
  "independentSignoffs": 0,
  "sharedRules": {
    "originalEventDeadline": "27 October 2027, 23:59 UTC",
    "candidateWindowStart": "2026-10-27",
    "candidateWindowEnd": "2027-10-27",
    "utcCutoffSeconds": "Future independent reviewer must freeze final cutoff seconds and inclusive publication-lag policy before any forecast lock.",
    "forecastSnapshotRule": "Prospective, separately registered original probability and stable binary condition must be independently timestamped. This document itself is not that registration.",
    "auditTrail": "Original documents must be linked with retrieval date, publisher, version, archived snapshot or verifiable document ID; later updates are separate records. A silent copy edit never changes the v1 research question.",
    "outcomeStatus": "UNRESOLVED",
    "noInferenceFromSilence": true
  },
  "candidates": [
    {
      "id": "CM-003",
      "originalUrl": "/milestones/first-eu-gpai-article-101-fine-2027/",
      "originalQuestion": "Will the European Commission impose an Article 101 GPAI fine by October 2027?",
      "proposedOperationalQuestion": "Between 27 October 2026 and 27 October 2027 (inclusive, UTC), will the European Commission adopt at least one formal decision imposing a fine on a provider of a general-purpose AI model expressly under Article 101(1) of Regulation (EU) 2024/1689?",
      "editorialScopeWarning": "The shorthand \"first-ever fine\" is NOT established by this candidate. The existing v1 measurable event is at least one Article 101 fine decision in the defined window; a first-ever formulation requires exhaustive earlier-decision evidence and a distinct prospective version.",
      "positiveConditions": [
        "Issuer is the European Commission, not a national or regional authority, court, or other supervisory office.",
        "Addressee is a provider of a general-purpose AI model and the decision expressly imposes a fine under Article 101(1) of Regulation (EU) 2024/1689.",
        "Legally operative Commission ADOPTION date (not website publication date) falls within the original candidate window.",
        "Decision identifier and official issuing record, or an independently verifiable authoritative disclosure, are available to reviewers."
      ],
      "negativeConditions": [
        "Only an investigation, request for information, preliminary findings, warning, administrative correspondence or hearing has occurred.",
        "Only a sanction under a different AI Act article, the DSA, the GDPR, or by a national authority has been found.",
        "A fine decision is dated outside the original event window, even if announced inside that window.",
        "Public-source checks have not exhausted all relevant decision archives, so an absence claim cannot yet be certified."
      ],
      "dateConventionProposal": "Use formal Commission adoption date. Later publication may prove an earlier adoption, but cannot change its date. The original cutoff remains 27 October 2027 23:59 UTC; precise event inclusion and lag procedure require independent prospective signoff.",
      "delayedEvidenceProposal": "Predefine a 90-day document-publication observation window after 27 October 2027. Unavailable decisions or incomplete archives remain \"unresolved\" rather than automatically \"NO\" until the agreed legal review method concludes.",
      "sourcePriority": [
        "EUR-Lex operative legal text and Commission decisions with identifiable document numbers",
        "European Commission official AI Office or digital strategy enforcement notices",
        "Commission press releases explicitly identifying the formal Article 101 fine decision",
        "Independent legal adjudication with supporting official records"
      ],
      "baselineAudit": {
        "status": "not_exhaustively_verified",
        "searchScope": "Public indexed official Commission and EUR-Lex pages were checked as of 27 October 2026. This does not establish a complete register of unpublished or non-indexed decisions.",
        "firstEverFineEstablished": false,
        "noEarlierFineProved": false,
        "publishedEnforcementRules": {
          "article101": "Regulation (EU) 2024/1689, Article 101",
          "implementing": "Commission Implementing Regulation (EU) 2026/1755",
          "startOfCommissionEnforcement": "2026-08-02"
        },
        "additionalReviewRequired": "Commission decision archive / AI Office response, clear treatment of confidential or later-published decisions, dated legal reviewer signoff."
      },
      "sourceLinks": [
        {
          "type": "official-law",
          "name": "EU AI Act Article 101 (Commission GPAI fines)",
          "url": "https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-101"
        },
        {
          "type": "official-law",
          "name": "EUR-Lex consolidated AI Act, Article 101",
          "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02024R1689-20260727"
        },
        {
          "type": "official-implementing-regulation",
          "name": "Commission Implementing Regulation 2026/1755 on GPAI enforcement procedures",
          "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32026R1755"
        },
        {
          "type": "official-commission",
          "name": "European Commission: AI Act enforcement framework",
          "url": "https://digital-strategy.ec.europa.eu/en/policies/enforcement-ai-act"
        }
      ],
      "remainingGates": [
        "Independently validate complete pre-period baseline and whether \"first\" may ever be used.",
        "Confirm adoption/publication date convention and resolution-lag rules with qualified independent legal reviewer.",
        "Obtain stable archive and adoption-document identifiers for final adjudication.",
        "Prospectively lock final binary question and probability using third-party timestamp service before any scoring."
      ],
      "editorialReadiness": "improved_operational_rules_but_NOT_ready_to_lock",
      "externalLegalReviewSigned": false,
      "outcome": "UNRESOLVED",
      "probability": null,
      "scoreEligible": false
    },
    {
      "id": "CM-004",
      "originalUrl": "/milestones/waymo-munich-paid-driverless-rides-2027/",
      "originalQuestion": "Will paid, driverless Waymo rides launch in Munich by October 2027?",
      "proposedOperationalQuestion": "By 27 October 2027, will Waymo have made at least one fare-paying, genuinely driverless passenger ride bookable and completed by a member of the general public within Munich city limits, with no on-board safety driver?",
      "positiveConditions": [
        "Waymo-branded or Waymo-operated passenger service is available to ordinary members of the public, not only invited testers or personnel.",
        "Booking and a real quoted or paid monetary fare are documented; a public demo or free media ride does not count.",
        "At least one qualifying completed passenger ride occurs inside Munich municipal boundaries, with no human safety driver or human operator on board.",
        "Official Waymo release/FAQ corroborates commercial availability and qualified independent evidence establishes actual launch or the completed service.",
        "The qualifying ride and launch occurred within the original 27 October 2027 23:59 UTC cutoff."
      ],
      "negativeConditions": [
        "Vehicles only perform safety-driver mapping or manual road tests.",
        "Only a launch announcement, application, permission, publicity trip, waitlist or technology demo exists.",
        "Only private invitations, controlled free pilots or on-board human drivers are offered.",
        "Only service in a different Bavarian or German municipality exists, not the City of Munich.",
        "Only regulatory type approval or permitted operating zone is documented with no completed public paid ride."
      ],
      "geographyProposal": "City of Munich municipal boundary (Landeshauptstadt München), not the entire Munich metropolitan region. Geocoded trip evidence must demonstrate an eligible ride within the city.",
      "humanRole": "Remote technical supervision allowed only if there is no safety driver or human operator physically riding in the car; resolve remote-driving exceptions independently before forecast lock.",
      "dateConventionProposal": "Use earliest independently corroborated qualifying completed passenger ride date, not first mapping, media announcement or regulatory permit date.",
      "operatorTimeline": {
        "waymoAnnouncement": "2026-08-25",
        "cityStatement": "2026-09-03",
        "announcedCommercialTarget": "towards end of 2027",
        "cortistExistingCutoff": "2027-10-27",
        "warning": "Our deadline is earlier than the operator and city public target. This is a meaningful forecast hurdle, not a mistake to silently extend."
      },
      "observedBaseline": {
        "status": "operator_reports_testing_only",
        "asOf": "2026-10-27",
        "documented": "Waymo official Germany FAQ says validation drivers are still on board and commercial rides are not yet being offered on the checked page. The City of Munich describes upcoming manually controlled mapping and late-2027 service target.",
        "negativeOutcomeProved": false,
        "regulatoryApprovalVerifiedForCommercialLaunch": false
      },
      "regulatoryEvidence": {
        "requiredOperatingType": "Germany autonomous driving authorization if this legal regime applies to the service design",
        "legalSources": [
          "AFGBV §2 vehicle operating authorization from Kraftfahrt-Bundesamt (KBA)",
          "AFGBV §7 approval of defined operating area by competent state authority",
          "Bavarian ministry summary on KBA and operating-area responsibilities"
        ],
        "caveat": "Regulatory approval alone is not proof of paid public service, and its exact applicability must be verified for Waymo’s actual permit pathway."
      },
      "sourcePriority": [
        "Waymo official Germany booking and commercial availability notice including date",
        "City of Munich or competent Bavarian regulatory notice on approved public service",
        "Public booking interface and independently verifiable price/ride records with privacy-safe documentation",
        "Original relevant KBA or operating-area approval identifiers if issued"
      ],
      "sourceLinks": [
        {
          "type": "operator",
          "name": "Waymo: August 2026 Munich service plans",
          "url": "https://waymo.com/blog/2026/08/waymo-in-munich/"
        },
        {
          "type": "operator-status",
          "name": "Waymo: live Germany testing / booking FAQ",
          "url": "https://waymo.com/waymo-in-germany/"
        },
        {
          "type": "municipality",
          "name": "City of Munich: September 2026 robotaxi service announcement",
          "url": "https://stadt.muenchen.de/lhm-ms-wirtschaftsfoerderung-en/en/business-news/waymo-robotaxi-eng.html"
        },
        {
          "type": "federal-law",
          "name": "Germany AFGBV §§ 2 and 7 — permits and operating zones",
          "url": "https://www.gesetze-im-internet.de/afgbv/BJNR098610022.html"
        },
        {
          "type": "bavarian-government",
          "name": "Bavarian government autonomous driving legal framework",
          "url": "https://www.autonomes-fahren.bayern.de/recht/index.php"
        }
      ],
      "adjudicationProposal": "Require both official operator evidence and independent verification of actual publicly fare-paying driverless service. If official operator statement or booking evidence is absent, status remains unresolved at review rather than conjectured YES or NO.",
      "remainingGates": [
        "Confirm independent evidence threshold and treatment of an anonymous member of the public.",
        "Freeze exact Munich municipal geography, ride completion standard and acceptable proof of fare.",
        "Independently confirm regulatory route and date of any commercial operating-area approval.",
        "Obtain independent reviewer approval and prospective version timestamp before any probability is issued."
      ],
      "editorialReadiness": "candidate_resolvable_but_NOT_externally_locked",
      "independentReviewerSigned": false,
      "outcome": "UNRESOLVED",
      "probability": null,
      "scoreEligible": false
    }
  ],
  "finalDisposition": "No candidate is being promoted to an official forecast in this release. Original v1 research questions, original cutoff date, historical estimates and source-audit v1 must remain unchanged."
}
