Telemetry and Concealment in Self-Adapting Generative AI: Logging Architecture, Adversarial Model Hiding, and the Limits of Detection

Abstract

Model risk management (MRM) guidance assumes a static model lifecycle, in which models are developed, independently validated, and implemented without further autonomous modification. Continually self-adapting generative AI systems --- models that update their own weights during production deployment --- fundamentally violate this assumption and render point-in-time validation inadequate. This paper addresses the resulting governance problem in two parts. Part I develops a rigorous telemetry architecture for such models, operating simultaneously in discrete and continuous time. We establish a Minimal Sufficient Statistic for audit purposes, construct a tamper-evident Merkle chain for discrete weight sequences, derive the appropriate continuous-time generalization via the Ito formula, and propose event-driven logging via KL divergence stopping times that is both computationally tractable and meaningful for validation. Part II asks what happens when the model provider is adversarial. A firm deploying such a model has strong incentives to conceal learning updates that would trigger mandatory validation review. We formalize this as the Model Hiding Problem and provide a systematic taxonomy of six distinct attack strategies against the Part I architecture, spanning discrete and continuous time, with a formal countermeasure for each. Together the two parts establish a dual-regime architecture in which continuous telemetry is necessary but not sufficient, narrowing---but never replacing---periodic invasive audit. The framework is model-architecture-agnostic and is designed to satisfy the three pillars of traditional MRM.