Disclosure substrate

@@ -10,11 +10,11 @@ index_group: core-named-substrates
short_description: "Mechanism making a version-controlled Markdown wiki the primary continuous-disclosure record, with signed authorship chains and cryptographic content hashes."
status: active
bcsc_class: public-disclosure-safe
last_edited: 2026-05-15
last_edited: 2026-08-24
editor: pointsav-engineering
cites:
 - ni-51-102
 - osc-sn-51-721
 - np-51-201
 - bcsc-continuous-disclosure
 - mondaq-ni-51-102-summary
 - sec-17a-4-f
@@ -46,7 +46,7 @@ The practical consequence for regulated buyers: a reporting issuer that serves i

The substrate collapses three conventionally separate bodies of text — internal documentation, an investor relations website, and statutory filings — into one Markdown corpus under issuer infrastructure, rendered into reader-facing wiki pages, regulator-compliant export packages, and cryptographic proof-of-state artefacts from the same source.

For regulated issuers under `[ni-51-102]` and `[osc-sn-51-721]`, the export adapters and cryptographic anchoring described in this article are planned infrastructure; the signed authorship chain and content-hash anchoring are operational today.
For regulated issuers under `[ni-51-102]` and `[np-51-201]`, the export adapters and cryptographic anchoring described in this article are planned infrastructure; the signed authorship chain and content-hash anchoring are operational today.

## Overview

@@ -73,9 +73,9 @@ Two timestamp mechanisms are planned for Phase 7 of the wiki engine (intended; a
- **OpenTimestamps anchoring** `[opentimestamps]` — planned cryptographic anchoring of each commit to the Bitcoin blockchain. Bitcoin anchoring is free, open-source, and external to the issuer's infrastructure; it produces proof that a specific content state existed at a specific block height, without requiring trust in any single intermediary.
- **RFC 3161 timestamping** `[rfc-3161]` — planned formal timestamp tokens from a recognised Time-Stamp Authority. RFC 3161 tokens carry legal recognition in EU and most common-law jurisdictions. The planned use of both mechanisms provides cryptographic redundancy: one anchors to a decentralised ledger; the other provides the formally-recognised token a regulator or court can verify.

Two timestamp fields are planned per TOPIC — `published_at` (when the wiki rendered this content state) and `valid_at` (when the underlying fact the TOPIC asserts holds). The distinction matters for forward-looking information labelled under `[osc-sn-51-721]`: the publication date and the validity period of the information are separate facts that a disclosure record must be able to distinguish.
Two timestamp fields are planned per TOPIC — `published_at` (when the wiki rendered this content state) and `valid_at` (when the underlying fact the TOPIC asserts holds). The distinction matters for forward-looking information labelled under `[np-51-201]`: the publication date and the validity period of the information are separate facts that a disclosure record must be able to distinguish.

Material-change commits — those whose TOPIC edits constitute material changes under the `[bcsc-continuous-disclosure]` posture — are intended to emit a signed Disclosure-Diff artefact alongside the updated TOPIC. The Disclosure-Diff is a cryptographically signed diff of the change, not a derivative of the TOPIC; it is planned to be committed as a W3C Verifiable Credential `[w3c-verifiable-credentials]` alongside the affected article. This is forward-looking and subject to the cautionary factors in `[ni-51-102]` and `[osc-sn-51-721]`.
Material-change commits — those whose TOPIC edits constitute material changes under the `[bcsc-continuous-disclosure]` posture — are intended to emit a signed Disclosure-Diff artefact alongside the updated TOPIC. The Disclosure-Diff is a cryptographically signed diff of the change, not a derivative of the TOPIC; it is planned to be committed as a W3C Verifiable Credential `[w3c-verifiable-credentials]` alongside the affected article. This is forward-looking and subject to the cautionary factors in `[ni-51-102]` and `[np-51-201]`.

### Per-jurisdiction export adapters (planned)

@@ -110,7 +110,7 @@ Vendor SaaS disclosure platforms running on US-headquartered infrastructure face

A disclosure substrate that permits AI-generated text to reach publication without verification produces a structural liability: if the AI hallucinated a fact, that fact is in the disclosure record. Vectara's HHEM `[vectara-hhem]` is a detection-only approach — identifying hallucinations after generation. The substrate's planned mechanism is refusal-to-render: a TOPIC whose proof-of-grounding chain does not verify does not reach the reader.

The planned mechanism (Phase 9 of the wiki engine; intended subject to the `project-disclosure` cluster reaching this milestone; subject to the cautionary factors in `[ni-51-102]` and `[osc-sn-51-721]`):
The planned mechanism (Phase 9 of the wiki engine; intended subject to the `project-disclosure` cluster reaching this milestone; subject to the cautionary factors in `[ni-51-102]` and `[np-51-201]`):

1. Every claim in an AI-drafted TOPIC must be paired with a citation ID resolvable in the citations registry.
2. Each citation's content hash must verify against the registry's stored hash.