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The mitigation ladder

Five mitigation rungs worked top down, from eliminate to accept and monitor, each with its stack control and evidence; transfer sits beside the ladder.

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The mitigation ladder Five rungs worked top down (eliminate, substitute, engineer, administrative, accept and monitor), each with its stack control and its evidence; transfer sits beside the ladder, and the ladder ends in acceptance. Work top down, and write down why 1 2 3 4 5 Eliminate legal floor: AI Act bans Policy deny; prohibited-use blocklist Deny verdict Substitute Design record; narrower registry scope Design decision linked to the risk id Engineer Eval gate, guardrail, approval, kill switch Eval results, guardrail events Administrative Instructions for use; training records Training attestations Accept and monitor Signed acceptance; telemetry; review date Acceptance record; monitoring signal Beside the ladder: transfer Insurance, indemnities: moves the financial consequence, not the harm to the person Every rung leaves a residual.
The mitigation ladder The five rungs of the mitigation hierarchy, worked top down, each with the stack control that implements it and the evidence it leaves; transfer sits beside the ladder, not on it. Start at the top and record why each higher rung was infeasible before you settle on a lower one. Drawn from chapter 13.

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1 Eliminate: do not build it, remove the capability or refuse the use, with a policy deny, a prohibited-use blocklist or a tool never granted; evidence: the deny verdict. Elimination has a legal floor: practices the AI Act prohibits are eliminated, never treated or accepted. 2 Substitute: the same goal at lower risk, with a design record and a narrower registry scope; evidence: the design decision linked to the risk id. 3 Engineer: controls that act without relying on anyone remembering (eval gate, runtime guardrail, approval gate, kill switch); evidence: eval results, guardrail events and approval logs. 4 Administrative: rules for people, such as instructions for use and training; evidence: training attestations and versioned instructions. 5 Accept and monitor: carry what is left, knowingly, with a signed acceptance, telemetry and a review date; evidence: the acceptance record and a monitoring signal. Transfer (insurance, contractual indemnities) sits beside the ladder: it moves the financial consequence, not the harm to the person on the other end of the decision. Every rung leaves a residual; the ladder ends in acceptance, never in 'resolved'.

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Five mitigation rungs worked top down, from eliminate to accept and monitor, each with its stack control and evidence; transfer sits beside the ladder.
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“The mitigation ladder” by Jorge García Aibar, aigovernanceengineer.com (https://aigovernanceengineer.com/figures/mitigation-ladder), v0.5.0. Licensed under CC BY 4.0 (https://creativecommons.org/licenses/by/4.0/).

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*[The mitigation ladder](https://aigovernanceengineer.com/figures/mitigation-ladder) by Jorge García Aibar, aigovernanceengineer.com, v0.5.0. Licensed under [CC BY 4.0](https://creativecommons.org/licenses/by/4.0/).*