ProductBoard · PDLC Gate

Does this feature need an IRA?

An automated pre-screen that reads a requirement and decides whether it must go through the IRA process — or reports what the requirement fails to say. Derived from IRA Checklist 3.

DRAFT — parameters below are proposed, not confirmed by Compliance

The IRA Checklist defines what gets reviewed once an initiative is already in IRA. It does not define what sends an initiative there in the first place. This page fills that gap with a working rule set, and states plainly which numbers in it are placeholders.

Of the checklist's 60 items, only the 8 under Business Sponsor → Risk identification have screening semantics. Those 8 are the rules below. The other 52 describe the review itself and are out of scope here.

Provisional parameters

Some of these await Compliance sign-off; one — the definition behind IRA-7 — does not exist yet, so that rule reports without triggering.

The estimate threshold is not among them. It cannot send work to Compliance and cannot hide anything a requirement states; it only splits “cleared” from “ask the author”. It is a workload dial, set at 50 (30 for financial crime and conduct, which carry most of the checklist’s intent). At 50 a returned requirement has a median of 2–3 items to answer, against the 7–8 of the previous version that nobody acted on.

Trigger logic ANY single stated YES Proposed

One rule firing on the requirement’s own words is enough to route it to IRA. An estimate never routes. No second threshold, no weighting. Compliance may want a higher bar for some rules.

N — financial lines > 100 customers / day Proposed

Customer reach above which IRA-5 fires, for features under a financial product (Credit, CashNow, Money, Collections, Lending, Acquiring, Quantix Risk…).

N — communication lines > 10,000 customers Proposed

The same threshold for non-financial products (Core, Core CoE, Connect, AI, Open Platform). The business line is read from the ProductBoard hierarchy, never guessed by the model; anything unmapped defaults to the stricter financial threshold.

X — rollback window 2 hours Proposed

Revertable within 2 hours via remote config or server-side rollback, or IRA-6 fires. Note the consequence: a client change with no config switch can only be reverted by shipping a new build, which always exceeds 2 hours — so every such change triggers IRA. Compliance should confirm this is intended, or grant client releases a separate rule.

IRA-7 — "critical path" not defined Missing

Without a definition IRA-7 cannot return NO. On technical and infrastructure work it fires on documented failure modes — reading a described fallback as evidence of risk — so it currently penalises the best-written requirements and is held out of the trigger set. On financial requirements it caused zero false triggers: every feature it flagged was already triggered by another rule. Proposed wording: a dependency is critical if its failure affects call setup, message delivery, login, or any movement of funds.

How a verdict is reached

Two tiers, and the split between them is about accountability, not confidence. What a requirement states is taken as written. Where it is silent, the screen estimates how likely the rule is to apply, given the kind of change it appears to be.

The requirement says itThe requirement is silent
Risk present Flag to IRA
goes to Compliance, with the quote
Need more Info
a question for the author
Risk absent Cleared by IRA
the author’s own declaration
No action needed
no reason found, nobody declared

Only stated evidence reaches Compliance. A referral has to come with something a reviewer can read. “We estimate 40%” is not something anyone can act on, and a queue full of evidence-free flags teaches everyone to ignore the evidenced ones too. Measured across 210 requirements: letting estimates refer would have sent 544 of 665 to Compliance — 3.2× today’s load, 373 of them with no written risk at all. Referring on stated evidence alone holds it at 171, essentially unchanged, while still clearing 122 outright.

So inference may do exactly two things: clear a rule the text does not mention when the scenario makes it unlikely, and raise one as a question for the author. It may never refer, and it may never overturn what the text states.

Before any of that: is there enough to read?

No descriptionNothing is written. IRA Check stays blank, which means “not screened yet” — what actually happened. No action needed on an empty document would read as “we checked and found no risk”. The screen re-runs once a description exists.
Under 200 charactersStated answers only; no estimates. Below this the model extracts zero stated answers 61% of the time (93% at zero characters), against 16% above 600 — there is nothing there to infer a scenario from, and an estimate built on the product name alone is worse than an open question.
200 characters or moreBoth tiers.

Silence is still never a pass on its own. An estimate can clear a rule, but the result is recorded as No action needed — the screen found no reason — never as Cleared by IRA, which is reserved for the case where the author wrote all eight answers down and can be held to them. Across 256 requirements screened, none reach that bar; the best manages seven of eight. The path is kept as the definition of “fully specified”, not as a working outcome.

Out of scope: the exclusion list

Five kinds of work the IRA process does not cover at all, supplied by Compliance. This is not a restatement of the eight rules — it cuts across them. Rule 8 treats promotional claims as a trigger while EX-e exempts promotional campaigns outright, so before this existed the screen referred exactly the work that is out of scope.

EX-aLook and feel
Visual or layout changes only — nothing about what the product does.
EX-bProduct information
Presenting information about products, SO LONG AS it is not construed as sales. An upsell, cross-sell or acquisition surface is sales and is NOT exempt.
EX-cSurveys and usage analytics
Running surveys or collecting app-usage data, ONLY where that collection was already made clear during customer onboarding. A disclosure added later does not qualify.
EX-dT&C updates
Updating terms and conditions.
EX-ePromotional campaigns
Running a time-bound promotional campaign — a special rate for a week, a fee waiver for a limited period. Building a permanent promotional surface or product entry point is NOT this.

The qualifiers carry most of the weight and are kept word for word. “So long as it is not construed as sales” turns on how a customer reads it, not on intent — an upsell or acquisition surface is sales however it is described. “Must have been made clear during customer onboarding” is past tense; a disclosure added later does not earn the exemption. And both promotional examples are time-bound: running a campaign is exempt, building a permanent promotional surface is not.

A stated risk outranks an exclusion. An exclusion applies only when the requirement states no risk. A week-long promotional rate is exempt; a promotion whose own text says it changes a fee has stated rule 8, and letting the exclusion win there would drop the one thing this screen exists to catch. Where they collide the stated trigger wins and the exclusion is reported rather than applied, so a reviewer can see it was considered and why it lost.

When an exclusion does apply, the verdict is No action needed and the eight rules are not run. The follow-up names the exclusion and quotes the phrase behind it — because “out of scope” and “we checked all eight and found nothing” are very different claims about what was examined.

Provenance not yet recorded. Whether this list sits in IRA Checklist 3 itself or arrived as a later clarification is still to be confirmed, so that the basis for an exemption can be cited.

The eight rules

RuleFires whenStatus
IRA-1
Third parties
A vendor, partner, processor, external SDK or third-party API is introduced that is not already in production use. Active
IRA-2
Data
A personal or sensitive data type new to this product is processed, or existing data moves across a new border or to a new party. Active
IRA-3
Regulatory
A jurisdiction we do not already serve is targeted, or an activity falls outside the licence this product operates under. Active
IRA-4
Financial crime
A new money-movement path, funding or payout channel is created, or KYC / screening / limits / transaction monitoring change. Active
IRA-5
Customer impact
Customer-facing reach exceeds the threshold for the business line — 100/day financial, 10,000 communication. Active
IRA-6
Reversibility
Rollback takes longer than 2 hours, needs an app-store release, or the change is irreversible (migration run, notification sent, funds moved). Active
IRA-7
Resilience
A new dependency lands on the critical path — pending a definition of "critical path". Reports only
IRA-8
Conduct
Pricing, fees or customer-facing claims change, or the target segment may include vulnerable customers. Flags for review; never clears on its own. Active

Dry run on real requirements

Run read-only against all 68 released features on financial product lines (Botim Money, CashNow, EasyCash, SNPL, Acquiring, Quantix Risk, Collections, Salary Loan, Split Pay, SME Lending, WPS, Middle Service — plus unclassified products, which default to the financial threshold). Timeframes ending 31 Jul – 1 Oct 2026. Nothing was written back.

44%
30 features triggered IRA
55%
38 undetermined — not enough information to decide
0%
cleared — nothing could be ruled out
7.1
of 8 items missing, on average, per requirement

What triggered, and why

The 30 triggers hold up to review. No false positives were found in the list. The features tripping the most rules:

FeatureRules fired
Terrapay Integrationthird party · data · regulatory · financial crime
Mastercard (Global provider) integrationthird party · financial crime
ARP Digital Integration (India & Phil)third party · regulatory · financial crime
Migration to ZAND VIBAN for merchantsthird party · financial crime · reversibility
Credit card fee on checkoutfinancial crime · reversibility · conduct
SNPL — Risk Based Pricing (Phase 2)financial crime · conduct
Cashnow RENEWAL Customer Tiering & Screeningfinancial crime · conduct

Payment-rail integrations, cross-border corridors, card-scheme onboarding, pricing strategy and credit-risk rule changes — each one genuinely warrants a compliance look. Two rules carry most of the signal: IRA-4 (money movement) fired 16 times and IRA-8 (pricing and claims) 18 times, together 62% of all triggers.

Why the other 55% could not be decided

Read the 55% correctly. It does not say those features are low-risk. It says their requirements do not contain enough information to judge risk at all.

Of the 68: 24 have a completely empty description and 42 are under 400 characters. The median is 195 characters.

Whether a feature can be decided tracks almost entirely with whether anything was written down. Requirements that triggered average 857 characters of description; those that could not be decided average 312 — barely a third as much.

So the constraint today is requirement quality, not the strictness of the compliance bar. That changes what to do about it: tighten the PRD standard, not staff up the review.

Comparison: mixed sample

An earlier run over 30 randomly sampled features across all product lines gives a useful contrast — 30% triggered, 70% undetermined, 0% cleared. Two differences matter:

Proposed rollout

Split by business line, because the two behave differently.

In both cases the screen reports missing information back to the author from day one. That part needs no one's agreement and delivers value immediately.

What we need from Compliance