Hunterson Standard Inference, Europe

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

ParagraphWhat it asksHow Hunterson standsStatus
1.1A methodology formalised, documented and publicThe methodology is public, versioned, and in force on every day it namesMet
1.2Assessments that are reliable, undistorted and representative of the marketEach 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 judgementSections 3 to 7. No judgement is used on any day (section 15)Met
1.3(b)Consistency among assessorsNo assessor makes a judgement on the day; the rules are applied by published code to every provider alikeMet in another form
1.3(c)The relative importance of each criterionThe 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 noneFive contributors, or no price (section 9)Met
1.3(e)What happens when data is insufficientNo 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 submissionNot applicable: nobody submits data. The data are Hunterson's own purchases, made in a fixed windowNot applicable
1.3(g)Dependence on key submittersEvery 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 dataEight tests, each with the reason published for every exclusion (section 7)Met
1.4The rationale, including for the time window; internal review and its frequency; external review and consultationWhy the hour was chosen (section 3); a yearly review, published (section 12); comment on every change (section 12)Met
1.5Public procedures for changes: notice, comment, publication of comments and responsesThirty days' notice of any change, with the comments and the response published (section 12)Met
1.6Routine re-examination against the physical market, with stakeholders' viewsThe yearly review (section 12), and the grade boundary's review (section 4.2)Met

2. Quality and integrity of assessments

ParagraphWhat it asksHow Hunterson standsStatus
2.1Measures for the quality and integrity of the processRecords 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 productThe specification (section 3)Met
2.2(b)Concluded transactions first, then bids and offers, then other informationOnly concluded transactions are used: Hunterson's own purchases, priced from their receipts. Listed prices serve only as a checkMet, more strictly
2.2(c)Bona fide data at arm's length, with care over transactions between affiliatesEvery 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 recordedEvery exclusion is recorded with its reason and published each day (sections 7 and 10)Met
2.2(e)Encouraging submitters to report all qualifying dataNot applicable: nobody submits dataNot applicable
2.2(f)Measures to enforce submitters' complianceNot applicable: nobody submits dataNot applicable
2.3(a)With each assessment, a concise explanation of how it was madeFrom 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 appliedNone is applied on any day (section 15)Met
2.4Who may submit data; verifying submitters; criteria for submitting staff; detecting improper communicationsNot applicable: no data is submitted. The receipts are the venue's own record of Hunterson's purchasesNot applicable
2.5Rules for selecting assessors, with training and competenceNo 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
2.6Assessments produced consistently and regularlyThe 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
2.7Continuity and successionThe 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 plainlyPartly met
2.8Supervision of assessors, and sign-off before releaseNot 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 unseenNot met
2.9A contemporaneous record of all data, judgements and exclusions, and of who was involvedEvery request, reply, receipt and exclusion is recorded as it happens, written once and fingerprinted. One person is involvedMet
2.10Records kept for at least five yearsKept permanently, and for at least five years in any case (section 8)Met
2.11Policies to identify, disclose, manage and avoid conflicts of interestSection 14; and, from the first publication, a fuller statement of interests and conflictsMet
2.12(a)No influence from business or personal relationshipsNo figure depends on any judgement on the day (section 15)Met
2.12(b)Controls on staff's personal interests, outside work and giftsSection 14 covers holdings and payments; the statement of interests and conflicts, published with the first figures, adds gifts and outside workMet from the first publication
2.12(c)Segregation of functionsNot met as written: one person does everything. The rules, the code and the records are public or fingerprinted in its placeNot met
2.12(d)Confidentiality of dataRaw records are kept privately; the register of registered users is never sharedMet
2.12(e)No bids, offers or trades by assessors or managers in the market assessedThe producer holds no position in anything assessed or dependent on the figures (section 14)Met
2.12(f)Separation of the assessment from conflicting businessesHunterson has no other business in the market it assesses. A related newsletter comments on the figures only after they are publishedMet
2.14Other business operations that minimise conflictsAs 2.12(f)Met
2.15Segregated reporting lines, defined responsibilities, reporting to senior management and a boardNot met as written: a sole trader has no boardNot met
2.16Prompt disclosure of conflicts arising from ownershipHunterson has one owner, its producer, whose interests are disclosed (section 14)Met
2.17Written, published procedures for complaintsSection 11Met
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 yearsAcknowledged 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 involvedNot met: the producer handles every complaintNot met
2.18(g)Recourse to an independent third party within six monthsNot met: no third party is yet namedNot met
2.19Standard procedures for disputes over a day's price, with any change communicated promptlyA published figure is never changed; a correction is a new dated entry, and registered users are told directly (sections 11 and 13)Met
2.20Audit trails and records made available to market authorities without delayMade available to any market authority entitled to them by law (section 8)Met
2.21An independent external auditor, the first audit within a year of publication and then annually, with the results publishedNot 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 registeredNot 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.