Hunterson and the IOSCO principles
Statement of adherence, 30 October 2026. Reviewed each year, and updated as soon as anything in it changes; every version is kept in this repository's history.
Hunterson Standard Inference, Europe is written with reference to the IOSCO Principles for Oil Price Reporting Agencies, published by the International Organization of Securities Commissions on 5 October 2012 (FR06/12). They are the principles written for agencies that assess the price of a physical product, which is what Hunterson does: it buys a defined quantity of AI model output each weekday and publishes what it cost. IOSCO's Principles for Financial Benchmarks of 2013 are written for figures built from data that others submit; Hunterson's figures are built from its own purchases. Which set applies is looked at again when the first use of the figures in a contract or financial product is registered under the data licence.
This statement takes each paragraph of the principles in turn and says whether Hunterson meets it, meets it in another form, does not need to because the paragraph does not apply, or does not meet it. The principles' own numbering is kept; their text has no paragraph 2.13.
In short. Hunterson is produced by one person. Four principles need a second person, a board or an independent auditor, and are not met as written: supervision and sign-off before release (2.8), segregation of functions and reporting lines (2.12(c) and 2.15), independent handling of complaints with recourse to a third party (2.18(d) and (g)), and an annual external audit (2.21). What stands in their place is said against each. Several principles are met more strictly than the principles require, above all the hierarchy of data (2.2(b)): every observation is a completed purchase with its receipt.
The methodology is METHODOLOGY.md, referred to below as "the methodology", with its section numbers.
1. Quality and integrity of the methodology
| Paragraph | What it asks | How Hunterson stands | Status |
|---|---|---|---|
| 1.1 | A methodology formalised, documented and public | The methodology is public, versioned, and in force on every day it names | Met |
| 1.2 | Assessments that are reliable, undistorted and representative of the market | Each figure is built from what every qualifying provider charged on its own receipt, trimmed of its highest and lowest quarter, with at least five contributors. The methodology says plainly where it is not representative: it does not see private deals, and it moves with who delivered (sections 7 and 18) | Met in another form |
| 1.3(a) | Criteria and procedures: use of data, time window, units, guidelines for judgement | Sections 3 to 7. No judgement is used on any day (section 15) | Met |
| 1.3(b) | Consistency among assessors | No assessor makes a judgement on the day; the rules are applied by published code to every provider alike | Met in another form |
| 1.3(c) | The relative importance of each criterion | The tests are applied in a fixed order, and the first failure is the reason given (section 7) | Met |
| 1.3(d) | A minimum amount of transaction data, or why there is none | Five contributors, or no price (section 9) | Met |
| 1.3(e) | What happens when data is insufficient | No price is published, with the count and every reason (section 9); a grade below five for 20 assessment days is withdrawn (section 4.6) | Met |
| 1.3(f) | Timeliness and means of submission | Not applicable: nobody submits data. The data are Hunterson's own purchases, made in a fixed window | Not applicable |
| 1.3(g) | Dependence on key submitters | Every observation comes through one venue; the methodology says so, and what follows if the venue is lost (section 8) | Met |
| 1.3(h) | Criteria for excluding data | Eight tests, each with the reason published for every exclusion (section 7) | Met |
| 1.4 | The rationale, including for the time window; internal review and its frequency; external review and consultation | Why the hour was chosen (section 3); a yearly review, published (section 12); comment on every change (section 12) | Met |
| 1.5 | Public procedures for changes: notice, comment, publication of comments and responses | Thirty days' notice of any change, with the comments and the response published (section 12) | Met |
| 1.6 | Routine re-examination against the physical market, with stakeholders' views | The yearly review (section 12), and the grade boundary's review (section 4.2) | Met |
2. Quality and integrity of assessments
| Paragraph | What it asks | How Hunterson stands | Status |
|---|---|---|---|
| 2.1 | Measures for the quality and integrity of the process | Records written once and never changed; every record and every assessment fingerprinted and timestamped by two independent services when made (section 8) | Met |
| 2.2(a) | The criteria defining the product | The specification (section 3) | Met |
| 2.2(b) | Concluded transactions first, then bids and offers, then other information | Only concluded transactions are used: Hunterson's own purchases, priced from their receipts. Listed prices serve only as a check | Met, more strictly |
| 2.2(c) | Bona fide data at arm's length, with care over transactions between affiliates | Every purchase is made at arm's length at the price any buyer pays; providers under common control, or reselling one source, count once (section 5) | Met |
| 2.2(d) | Anomalous or suspicious data identified, and the decisions recorded | Every exclusion is recorded with its reason and published each day (sections 7 and 10) | Met |
| 2.2(e) | Encouraging submitters to report all qualifying data | Not applicable: nobody submits data | Not applicable |
| 2.2(f) | Measures to enforce submitters' compliance | Not applicable: nobody submits data | Not applicable |
| 2.3(a) | With each assessment, a concise explanation of how it was made | From the first publication, each day's page shows every provider tested, its prices paid, speed and first-token time, and whether it was included, and why (section 10) | Met |
| 2.3(b) | An explanation of any judgement applied | None is applied on any day (section 15) | Met |
| 2.4 | Who may submit data; verifying submitters; criteria for submitting staff; detecting improper communications | Not applicable: no data is submitted. The receipts are the venue's own record of Hunterson's purchases | Not applicable |
| 2.5 | Rules for selecting assessors, with training and competence | No assessor exercises judgement on the day. The three judgements the methodology involves are recorded publicly, with reasons, before they take effect (section 15) | Met in another form |
| 2.6 | Assessments produced consistently and regularly | The test and the assessment run automatically each weekday, and from the first publication so does the publication; a day that cannot be produced is marked, with the reason (section 9) | Met |
| 2.7 | Continuity and succession | The production is automated and documented, and a continuity note, published with the first figures, says what happens if the producer cannot continue. One person produces Hunterson, which is a risk this statement states plainly | Partly met |
| 2.8 | Supervision of assessors, and sign-off before release | Not met as written: there is no second person. In its place: there is no judgement to supervise, the rules run as tested code, and every input and every assessment is fingerprinted and timestamped before publication, so that nothing can be changed afterwards unseen | Not met |
| 2.9 | A contemporaneous record of all data, judgements and exclusions, and of who was involved | Every request, reply, receipt and exclusion is recorded as it happens, written once and fingerprinted. One person is involved | Met |
| 2.10 | Records kept for at least five years | Kept permanently, and for at least five years in any case (section 8) | Met |
| 2.11 | Policies to identify, disclose, manage and avoid conflicts of interest | Section 14; and, from the first publication, a fuller statement of interests and conflicts | Met |
| 2.12(a) | No influence from business or personal relationships | No figure depends on any judgement on the day (section 15) | Met |
| 2.12(b) | Controls on staff's personal interests, outside work and gifts | Section 14 covers holdings and payments; the statement of interests and conflicts, published with the first figures, adds gifts and outside work | Met from the first publication |
| 2.12(c) | Segregation of functions | Not met as written: one person does everything. The rules, the code and the records are public or fingerprinted in its place | Not met |
| 2.12(d) | Confidentiality of data | Raw records are kept privately; the register of registered users is never shared | Met |
| 2.12(e) | No bids, offers or trades by assessors or managers in the market assessed | The producer holds no position in anything assessed or dependent on the figures (section 14) | Met |
| 2.12(f) | Separation of the assessment from conflicting businesses | Hunterson has no other business in the market it assesses. A related newsletter comments on the figures only after they are published | Met |
| 2.14 | Other business operations that minimise conflicts | As 2.12(f) | Met |
| 2.15 | Segregated reporting lines, defined responsibilities, reporting to senior management and a board | Not met as written: a sole trader has no board | Not met |
| 2.16 | Prompt disclosure of conflicts arising from ownership | Hunterson has one owner, its producer, whose interests are disclosed (section 14) | Met |
| 2.17 | Written, published procedures for complaints | Section 11 | Met |
| 2.18(a) to (c), (e), (f), (h) | A complaints policy; target timetables; fair and timely investigation; prompt completion; a written outcome; records kept five years | Acknowledged within five working days and answered in writing within twenty; the outcome published with any correction; records kept at least five years (section 11) | Met |
| 2.18(d) | Investigation independent of the people involved | Not met: the producer handles every complaint | Not met |
| 2.18(g) | Recourse to an independent third party within six months | Not met: no third party is yet named | Not met |
| 2.19 | Standard procedures for disputes over a day's price, with any change communicated promptly | A published figure is never changed; a correction is a new dated entry, and registered users are told directly (sections 11 and 13) | Met |
| 2.20 | Audit trails and records made available to market authorities without delay | Made available to any market authority entitled to them by law (section 8) | Met |
| 2.21 | An independent external auditor, the first audit within a year of publication and then annually, with the results published | Not met: no auditor is appointed. Whether to appoint one is decided when the first use of the figures in a contract or financial product is registered | Not met |
What would change this statement
Any of the following would be recorded here at once: a second person taking part in the production or the review of complaints; a named independent reviewer for complaints; an external audit; a change in the venue or in how the data is obtained; or a decision that IOSCO's Principles for Financial Benchmarks should apply instead.
Questions about this statement: malcolm@hunterson.org.