
This working paper proposes the ARCH Framework — Adaptive Regulatory Compliance and Human Oversight — a field-level implementation framework for anchoring AI proof certificates natively within the CDISC Unified Study Definitions Model (USDM) without requiring new standards or infrastructure. The framework specifies a three-gate schema for regulatory compliance verification, formal structural verification, and human oversight attestation, including field-level specifications, conformance rules, controlled vocabularies, and programmatic dependencies. Additional topics include risk-based quality management integration anchored to ICH E6(R3), PCCP dynamic ingestion architecture, retroactive compliance invalidation with risk-calibrated escalation workflows, continuous learning governance, biomedical concept verification via the BiomedicalConceptSurrogate trap, dataset provenance and EU AI Act Article 10 compliance, SLA adjudication architecture, living protocol governance, real-time clinical trial support aligned with FDA's April 2026 RTCT initiative, and multi-jurisdictional interoperability. Companion Excel data dictionary included as the authoritative field-level specification. Version 2.1 Working Paper. Explanatory narrative sections in progress. Builds upon Thompson, S. (2026). Toward a Regulatory Validation Framework for AI-Assisted Clinical Trial Activation and Execution. NexTrial Dispatch, March 2026.
RTCT, 21 CFR Part 11, ICH E6R3, ICH M11, USDM, Clinical Data Standards, SDTM, RBQM, Proof Certificates, EU AI Act, ARCH, CDISC, AI Validation, Living Protocols, Artificial Intelligence Governance, Digital Health, Clinical Trials, Regulatory Compliance, Real Time Clinical Trials, PCCP
RTCT, 21 CFR Part 11, ICH E6R3, ICH M11, USDM, Clinical Data Standards, SDTM, RBQM, Proof Certificates, EU AI Act, ARCH, CDISC, AI Validation, Living Protocols, Artificial Intelligence Governance, Digital Health, Clinical Trials, Regulatory Compliance, Real Time Clinical Trials, PCCP
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