Subnet345

Industries · Federal · Record Substrate

Your AI agents are acting inside an authorization boundary an auditor will ask you to account for.

Federal agencies are moving agentic systems into production inside their authorization boundaries. FISMA and NIST 800-53 expect an attributable record of that action. Built by a veteran-led team, the substrate produces it, inside your own boundary, designed to run air-gapped. Until the model runs inside your boundary, the model path leaves it: that path is not air-gapped and is not for controlled or classified information.

FISMA
Every federal system carries an authorization to operate against the NIST 800-53 baseline. Agents acting inside that boundary inherit its audit and accountability obligations.
NIST 800-53 · AI RMF
The control baseline (audit, accountability, access) plus the NIST AI RMF, made binding for federal agencies by OMB M-25-21.
OMB M-25-21 / M-25-22
The April 2025 federal governance and procurement requirements for high-impact AI; agentic deployments fall within their scope.

§ 01 Why now

Can you account for what your agents did inside the boundary?

2026 to 2027

Enforcement. The auditor asks.

The NIST 800-53 audit and accountability controls expect a complete, reviewable trail, and agent-specific control overlays for 800-53 are in development. The obligation to account for what an agent did inside the boundary arrives before the overlay that names it.

The audit question

If an agency inspector general asked you to reconstruct every action your agents took inside your authorization boundary last quarter, what would you show them?

§ 02 Use cases

Where the substrate lands first.

Mission work inside the boundary

Agents that draft, review, and reconcile against federal systems of record, with access attributed and reviewable.

In-perimeter and disconnected operation

Coordination, policy, and the record run inside your authorization boundary. The substrate is designed to run air-gapped: once installed, the substrate needs no route out, so it fits environments that cannot reach the open internet. An offline install path is on the roadmap. The substrate is designed to run air-gapped; the models are not yet. Sovereign-model deployment inside the perimeter, where even the model behind the agent runs without outbound traffic, is on the roadmap through our model-training pipeline. In a fully self-hosted deployment, with the model on your GPUs and the record and telemetry on your own infrastructure, your data stays in your perimeter. That is a configuration you set, not the shipped default.

Agency and contractor accountability

Shared accountability across handoffs: which agent acted, under whose authority, against which system.

§ 03 Against the frameworks

Measured against what the audit expects.

FISMA, the NIST 800-53 baseline, and the AI Risk Management Framework point toward a common expectation: action inside the boundary must be attributed, reviewable, and kept where the system is authorized.

This material does not constitute legal or regulatory advice, and Subnet345 holds no FedRAMP authorization or ATO. Assess your obligations with your assessor.

ExpectationAttributable action inside the boundary
FrameworkFISMA · 800-53 AU
WithoutNo action trail
With Subnet345Action attributed
ExpectationOperation inside the authorization boundary
Framework800-53 · zero-trust
WithoutCloud-dependent
With Subnet345In-perimeter
ExpectationReviewable agent action history
Framework800-53 AU
WithoutReconstructed later
With Subnet345Attributed, tamper-evident chain

Sources: FISMA (44 U.S.C. 3551); NIST SP 800-53 (Rev 5); NIST AI RMF (AI 100-1); OMB M-25-21 & M-25-22. Regulatory mapping reviewed: August 2026. Informational, not legal advice.

The question we help you answer

Can you show what your agents did inside the boundary, and under whose authority?