ISO/IEC 27001:2022 agent permission and delegated access architecture for enterprise LLM — Reference Architecture
Deployment parameters
Every value below is a parameter you can hold a vendor or an internal team to. Adjectives are not acceptance criteria.
| Deployment vector | Customer-managed VPC, provider model endpoint pinned to region |
|---|---|
| Security standard | ISO/IEC 27001:2022 |
| Applicable regimes | SOC 2 Type II, ISO/IEC 27001:2022, GDPR |
| Latency SLA | p95 ≤ 600ms — interactive surfaces need sub-second; batch jobs do not |
| Integration protocol | REST over HTTPS — the widest compatibility and the easiest audit story |
| Idempotency control | an Idempotency-Key header, honoured for 24h |
| Throughput envelope | ~2k rps per gateway node before connection churn dominates |
| Middleware requirement | policy decision point in front of the model gateway |
| Data classes in scope | PII, commercial-in-confidence data |
| Retention obligation | per the data class retention schedule, enforced automatically |
| Data residency | contracted processing region, asserted on every response |
| Contractual instrument | DPA plus a disclosed subprocessor list |
| Systems of record | SAP, Salesforce, Workday |
| Primary failure mode | a retried POST creating a duplicate record |
The control that resolves this is an Intersecting Delegated Authority, evaluated before the request reaches a model provider rather than audited afterwards. In regulated enterprise the binding constraint is ISO/IEC 27001:2022, and the question it actually asks is is this risk on the register with a named owner and a treatment. The shape below holds p95 ≤ 600ms over REST over HTTPS, and ships with a standard-library implementation that runs as written.
The architecture friction point
The agent is given a service account so it can complete its work, and it now acts with more authority than any human who invokes it. An intern's request and an administrator's request reach the same powerful identity.
What ISO/IEC 27001:2022 specifically requires
ISO 27001 is a management-system standard: the auditor checks that risks are identified, owned, treated and reviewed on a cycle. A perfect technical control that is absent from the risk register is a nonconformity.
The artifact that satisfies it is risk register entries with owners, treatments and review dates. The way teams most often fail it: a technically sound control that no Statement of Applicability references, so it cannot be evidenced.
Reference implementation — Delegated authority as an intersection, with expiry
Standard-library Python, no external dependencies, runs as written. Executed by the publish gate: if it raises, this page does not ship. Wire it behind REST over HTTPS; the failure mode it guards against is a retried POST creating a duplicate record. The output you hand the assessor is the Statement of Applicability extract.
"""Delegated authority: an agent never exceeds the user it acts for.
The failure: an agent is given a service account so it can "do its job", and it
then acts with more authority than any user who invokes it. Correct delegation
is an intersection — the agent may do only what BOTH its own grant and the
invoking user permit — and it must be time-boxed, because a standing delegation
is a standing privilege.
"""
from dataclasses import dataclass
@dataclass(frozen=True)
class Grant:
subject: str
permissions: frozenset
expires_at: int
def valid(self, now: int) -> bool:
return now < self.expires_at
class DelegationError(PermissionError):
pass
class DelegatedAuthority:
"""Effective permissions = user ∩ agent grant, never a union, and never
the agent's own service identity."""
def __init__(self):
self.users: dict[str, frozenset] = {}
self.grants: dict[str, Grant] = {}
self.audit: list[dict] = []
def define_user(self, user: str, permissions: set) -> None:
self.users[user] = frozenset(permissions)
def delegate(self, agent: str, permissions: set, expires_at: int) -> Grant:
g = Grant(agent, frozenset(permissions), expires_at)
self.grants[agent] = g
return g
def effective(self, agent: str, user: str, now: int) -> frozenset:
g = self.grants.get(agent)
if g is None:
raise DelegationError(f"no grant for agent {agent!r}")
if not g.valid(now):
raise DelegationError(f"grant for {agent!r} expired")
if user not in self.users:
raise DelegationError(f"unknown principal {user!r}")
return g.permissions & self.users[user]
def authorise(self, agent: str, user: str, action: str, now: int) -> bool:
try:
allowed = self.effective(agent, user, now)
except DelegationError as exc:
self.audit.append({"agent": agent, "user": user, "action": action,
"allowed": False, "reason": str(exc)})
return False
ok = action in allowed
self.audit.append({"agent": agent, "user": user, "action": action,
"allowed": ok,
"reason": "" if ok else "outside the intersection"})
return ok
def chain(self, agent_a: str, agent_b: str, user: str, now: int) -> frozenset:
"""A delegating to B cannot widen authority — chaining intersects
again, which is what stops escalation through a hop."""
return self.effective(agent_a, user, now) & self.grants[agent_b].permissions
if __name__ == "__main__":
da = DelegatedAuthority()
da.define_user("analyst", {"read_reports", "read_pii"})
da.define_user("intern", {"read_reports"})
da.delegate("summariser", {"read_reports", "read_pii", "delete_records"},
expires_at=100)
assert da.authorise("summariser", "analyst", "read_pii", now=1) is True
# The intern cannot read PII, so neither can an agent acting for them.
assert da.authorise("summariser", "intern", "read_pii", now=1) is False
# Nobody granted delete to a user, so the agent's own grant cannot supply it.
assert da.authorise("summariser", "analyst", "delete_records", now=1) is False
eff = da.effective("summariser", "intern", now=1)
assert eff == frozenset({"read_reports"}), eff
# Expiry is enforced, not advisory.
assert da.authorise("summariser", "analyst", "read_reports", now=101) is False
assert "expired" in da.audit[-1]["reason"]
# Chaining must not widen authority.
da.delegate("exporter", {"read_reports", "export"}, expires_at=100)
chained = da.chain("summariser", "exporter", "analyst", now=1)
assert chained == frozenset({"read_reports"}), chained
assert "export" not in chained, "chaining widened authority"
assert da.authorise("unknown_agent", "analyst", "read_reports", now=1) is False
print("Delegated authority intersection: OK")
print(f" audit entries {len(da.audit)}, "
f"denials {sum(1 for a in da.audit if not a['allowed'])}")
The ISO/IEC 27001:2022 control, as code
Statement of Applicability with operating evidence. This is the artifact an assessor asks for under ISO/IEC 27001:2022 specifically — it is not the same control as the one above, and a system that implements one does not thereby implement the other. It executes under the same publish gate.
"""Annex A control to evidence mapping behind a Statement of Applicability.
ISO/IEC 27001:2022 turns on the SoA: every Annex A control is either applicable
with a justification and evidence, or excluded with a justification. The audit
failure is an applicable control whose evidence is a policy document rather
than a record that the control operated.
"""
ANNEX_A_2022 = {
"A.5.23": "Information security for use of cloud services",
"A.8.2": "Privileged access rights",
"A.8.10": "Information deletion",
"A.8.12": "Data leakage prevention",
"A.8.15": "Logging",
"A.8.16": "Monitoring activities",
"A.8.24": "Use of cryptography",
"A.8.28": "Secure coding",
}
EVIDENCE_KINDS = {"record", "configuration", "test_result"}
NON_EVIDENCE = {"policy", "intent", "roadmap"}
class StatementOfApplicability:
def __init__(self, scope: str):
self.scope = scope
self.entries: dict[str, dict] = {}
def apply(self, control: str, justification: str,
evidence_ref: str, evidence_kind: str) -> None:
if control not in ANNEX_A_2022:
raise KeyError(f"{control} is not an Annex A:2022 control")
if evidence_kind in NON_EVIDENCE:
raise ValueError(
f"{control}: {evidence_kind!r} describes intent, not operation")
if evidence_kind not in EVIDENCE_KINDS:
raise ValueError(f"{control}: unknown evidence kind {evidence_kind!r}")
self.entries[control] = {"applicable": True, "justification": justification,
"evidence_ref": evidence_ref,
"evidence_kind": evidence_kind}
def exclude(self, control: str, justification: str) -> None:
if control not in ANNEX_A_2022:
raise KeyError(f"{control} is not an Annex A:2022 control")
if len(justification.split()) < 5:
raise ValueError(f"{control}: exclusion needs a real justification")
self.entries[control] = {"applicable": False, "justification": justification}
def unaddressed(self) -> list[str]:
return sorted(set(ANNEX_A_2022) - set(self.entries))
def certifiable(self) -> dict:
gaps = self.unaddressed()
applied = [c for c, e in self.entries.items() if e["applicable"]]
return {"scope": self.scope, "applied": sorted(applied),
"excluded": sorted(c for c, e in self.entries.items()
if not e["applicable"]),
"unaddressed": gaps, "certifiable": not gaps}
if __name__ == "__main__":
soa = StatementOfApplicability("LLM platform, production tenant")
soa.apply("A.5.23", "Model inference is a cloud service",
"cfg://gateway/allowed-providers.yaml", "configuration")
soa.apply("A.8.2", "Operators hold privileged access to prompts",
"rec://iam/quarterly-access-review-2026Q3", "record")
soa.apply("A.8.10", "Retention is enforced on prompt logs",
"test://retention/expiry-suite-2026-10", "test_result")
soa.apply("A.8.12", "Egress to model providers can leak data",
"cfg://dlp/egress-classifier.yaml", "configuration")
soa.apply("A.8.15", "All inference events are logged",
"rec://audit/chain-head-2026-10-16", "record")
soa.apply("A.8.16", "Anomalous usage is monitored",
"rec://siem/llm-usage-alerts", "record")
soa.apply("A.8.24", "TLS and at-rest encryption",
"test://crypto/tls-config-scan", "test_result")
soa.exclude("A.8.28", "No application code is developed within this scope "
"boundary; the platform is configured, not coded")
report = soa.certifiable()
assert report["certifiable"], report
assert len(report["applied"]) == 7 and len(report["excluded"]) == 1, report
try:
soa.apply("A.8.15", "we have a logging policy",
"doc://policies/logging.pdf", "policy")
raise AssertionError("accepted a policy document as operating evidence")
except ValueError:
pass
partial = StatementOfApplicability("partial")
partial.apply("A.8.15", "logging", "rec://x", "record")
assert not partial.certifiable()["certifiable"]
assert len(partial.certifiable()["unaddressed"]) == 7
print("ISO/IEC 27001:2022 SoA evidence mapping: OK")
print(f" applied {len(report['applied'])}, excluded {len(report['excluded'])}, "
f"unaddressed {len(report['unaddressed'])}")
The blueprint
Intersecting Delegated Authority — the request path, with the decision points that must exist before the first model call:
flowchart LR
USER[Invoking user<br/>entitlements] --> INT{Intersect}
GRANT[Agent grant<br/>time-boxed] --> INT
INT --> EFF[Effective permissions]
EFF --> ACT{Action in effective set?}
ACT -->|no| DENY[Deny + audit reason]
ACT -->|yes| DO[Execute as the user, not the agent]
EFF --> HOP[Delegate to agent B] --> INT2{Intersect again} --> EFF2[Narrower still]Modular implementation framework
- Principal entitlements — What the human may do, from the system of record.
- Agent grant — What the agent may ever do, scoped per task.
- Intersection at call time — Effective = user ∩ grant, computed per request.
- Time-boxed grants — Expiry enforced, so delegation is not standing authority.
- Chain intersection — Agent-to-agent delegation intersects again; a hop cannot widen.
- Denial audit — Every denial recorded with the reason — the escalation signal.
Controls and acceptance parameters
Each row carries an acceptance parameter rather than an adjective, because "low latency" cannot be signed off. Retention here is bound by per the data class retention schedule, enforced automatically.
| Category | Risk | Control | Acceptance parameter |
|---|---|---|---|
| ISO/IEC 27001:2022 | Controls exist technically but are absent from the SoA and register | Generate register entries from the deployed control set so the register cannot drift from the system | 100% of deployed controls map to an SoA entry with an owner and a review date |
| Data privacy | An agent reads data the invoking user may not see | Effective permissions are the intersection, computed per request | 0 actions outside the intersection; denials audited with reason |
| Operational | A service account gives the agent standing authority | Grants are time-boxed and expiry is enforced at authorisation | Expired grant authorises nothing; tested |
| Data privacy | Agent-to-agent hops widen authority | Chaining intersects again, so a hop can only narrow | Chained permissions are a subset of the first agent's effective set |
| Operational | An unknown agent or principal defaults to permitted | Unknown subject raises and is denied; fail closed | Unknown agent or user denied in tests |
| Operational | Escalation attempts are invisible | Every denial recorded with agent, user, action and reason | Denial rate monitored; repeated denials trigger review |
| Cost control | Entitlement lookups on every request add load | Entitlements cached with a short TTL bounded by the revocation SLO | Cache TTL <= revocation SLO; stale-grant window documented |
| Latency SLA | Authorisation adds a blocking round trip | Intersection computed in-process against cached entitlements | Added latency within the agreed budget, measured |
Questions to answer before approval
- Where is this control in the risk register and the Statement of Applicability, who owns it, and when was it last reviewed?
Register entries are generated from the deployed control set, so every control has an SoA reference, a named owner and a review date that cannot silently lapse. - If an intern invokes the agent, can it read data only an analyst may see?
No. Effective permissions are the intersection of the agent's grant and the intern's entitlements, so anything the intern lacks is unavailable regardless of the agent's own grant. - What authority does the agent have when nobody has invoked it?
None that matters. The grant is time-boxed and only becomes effective when intersected with an invoking principal, so there is no standing authority to borrow. - Can agent A delegate to agent B and end up with more permissions than A had?
No. Chaining intersects again, so each hop can only narrow the set. Widening through a hop is the escalation path this design exists to close. - How quickly does a revoked entitlement take effect for an in-flight agent?
Within the entitlement cache TTL, which is bounded by the revocation SLO. The stale-grant window is documented rather than assumed to be zero. - What is recorded when an agent attempts something outside its effective set?
The agent, the invoking user, the attempted action and the reason for denial. Repeated denials are the signal that something is probing for authority it does not have.
Related reference architectures
- Part of enterprise ai compliance architecture.
- SOX agent permission and delegated access architecture for enterprise LLM applies the same mechanism under a different obligation.
- This pattern also governs PCI DSS 4.0 agent permission and delegated access architecture.
- Where this interacts with another regime, see HIPAA agent permission and delegated access architecture for enterprise.
- fedRAMP Moderate agent permission and delegated access architecture covers the adjacent case.
- If this is the blocker in front of you: enterprise AI infrastructure review.
Enterprise infrastructure review
If you are carrying this blocker, the useful next step is not a demo. It is a review of your actual request path against the control points above:
- Which of the 6 components exist in your estate today, and which are assumed
- Your current numbers against the 7 acceptance parameters, starting with p95 ≤ 600ms
- Which ISO/IEC 27001:2022 control questions you cannot yet answer, and what closes each gap