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ZKAP (Zero-Knowledge Audit Protocol) is a legal-engineering methodology for cryptographic verification of regulatory compliance of artificial intelligence systems, introduced by Bulgarian jurist Radoslav Yordanov Radoslavov in the period 2025–2026, and the subject of two Bulgarian patent applications.[1][2] The protocol applies zero-knowledge proofs to allow a regulator to obtain mathematical assurance that a given system satisfies a formally specified regulatory requirement, without disclosing the sensitive data, model parameters or internal state on which the assurance rests.
ZKAP in this sense is distinct from other cryptographic schemes that share the same acronym, in particular Zero-Knowledge Access Pass — an anonymous-authorisation token used in distributed-storage and blockchain systems. Both approaches are built on the mathematics of zero-knowledge proofs, but they address different problems: Zero-Knowledge Access Pass establishes a right of access without revealing the user's identity, whereas the Zero-Knowledge Audit Protocol establishes regulatory compliance without revealing the regulated data.
The concept was first presented in March 2026 at the XI International Scientific Conference "High Technologies. Business. Society" in Borovets, Bulgaria.[1] A preprint with full cryptographic formalisation and a soundness theorem was deposited on Zenodo on 22 April 2026.[3] Two further pieces appeared in the European Commission's Apply AI Alliance community-content platform (Futurium) on 2 April and 18 April 2026, presenting the method to a regulatory audience.[4][5]
The conceptual core of the method is described in an earlier 2025 publication by Radoslavov in Industry 4.0 (Winter Session, vol. 2), where the dual-domain architecture and the idea of cryptographic verification of legal duties are introduced, but without specification of the full protocol.[2]
ZKAP is a methodological response to a structural conflict between three regulatory regimes of the European Union:
For cognitively opaque models — in particular large language models — the AI Act's transparency duties and the GDPR / trade-secret prohibitions enter into direct collision: full disclosure as required by the supervisor simultaneously violates the other two frameworks. The same conflict structure arises under the NIS2 Directive in respect of cybersecurity duties.[5]
The protocol substitutes a duty of disclosure with a duty of cryptographic proof: the regulator receives a mathematical assurance that the system is compliant with a particular rule, without seeing the data, the model weights, or the internal state on which the rule operates.[2][1] The proof is a zero-knowledge proof — a cryptographic construction known since the 1980s, which allows one party to prove the truth of a statement without revealing the underlying content.[1]
The methodology partitions information in the system into two zones:
According to the publications, sensitive information consequently does not travel along the conventional chain "regulator → court → experts → opposing party", because such information does not exist outside the obligated party's perimeter.[2]
The conceptual core of ZKAP is the so-called "polynomialisation of law" — the translation of formalised legal norms into mathematical constraints, which can be verified by means of zero-knowledge proofs (such as zk-SNARKs or zk-STARKs).[1] An obligation expressed in legal language is transposed into an obligation expressed in the language of cryptography, so that verification becomes machine-executable and independent of human discretion.
The publications describe the possibility of embedding basic formalised regulatory rules directly into hardware — at the level of the computational element, rather than as a subsequent software control layer. The implementation uses a specialised hardware element designated Provable Arithmetic Logic Unit (pALU), which secures determinism and resistance to algorithmic drift. This approach realises the principle of "safe by design": violation of a regulatory invariant cannot occur during execution, instead of being detected after the fact.[1]
The protocol is presented as operating in several modes depending on the system's risk profile and regulatory context:[1][5]
ZKAP is the work of Bulgarian jurist Radoslav Yordanov Radoslavov (ORCID: 0009-0003-6868-8083). The methodology was developed independently in 2025–2026 on the basis of a dual practical engagement — in civil forfeiture practice and in legal regulation of artificial intelligence. Both fields share a common structural problem: a duty to disclose imposed by a supervising authority versus a prohibition against disclosure of sensitive material.[2][1]
Between 2006 and 2023, Radoslavov served as a jurist in the Bulgarian anti-corruption commission (successively known as CECDPMI, KONPI, and the Commission for Counteracting Corruption and Forfeiture of Illegally Acquired Property) — the institutional context on which the conceptual foundations of ZKAP were later built.[6]
The principal technical constructions of ZKAP are the subject of two Bulgarian patent applications:[1]
Both filings activate Paris Convention priority until 30 March 2027 and 12 April 2027, respectively, for international extension via the European Patent Office, the UK Intellectual Property Office, and the Patent Cooperation Treaty.
ZKAP forms part of a broader academic line which applies zero-knowledge cryptography to the auditing of machine learning. Related frameworks include:
ZKAP is distinguished from these by its focus on the legal-engineering layer — specific articles of the AI Act (Articles 12, 13, 14, 15, 27) and the architectural separation between R-Domain and C-Domain — rather than on individual engineering components.[1]
Category:Artificial intelligence Category:Cryptography Category:Zero-knowledge proofs Category:Technology law Category:Artificial intelligence regulation Category:Bulgarian inventions
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