Why PSU Pilots Stall at the Vigilance Desk

The pilot had a champion, a GPU, and a banner. It sat on the CVO's desk for eleven weeks. The champion told the board that vigilance was anti-innovation. The CVO's query list was four lines: who wrote the specification, why this vendor, what data leaves, and whether the manpower slide is a staffing proposal. None of the four had a sentence. The stall was the file.

This teardown is for founders and for the PSU programme manager who has to walk a first agent past the Chief Vigilance Officer. It is not a guide to capturing a CVO. It is a guide to not handing them a case. CVC expectations on transparency, vendor neutrality, hospitality, and Integrity Pacts were not written for LLMs. They still attach to the purchase and to the data.

Pilots stall at vigilance for the same reasons other PSU pilots stall: a specification that reads as vendor-written, a single-source story that was not earned, a free POC that looks like a gift in either direction, and a slide that implies posts will vanish. AI adds a fifth: the corpus is itself a valuable asset. Giving it to a vendor to 'train' is a disposal of property until you write that it is not.

Not legal advice and not a CVC manual. Read the live CVC circulars your CVO cites, your Integrity Pact, and counsel.

The four lines that stop the file

Who wrote the specification. If the SOW contains the vendor's product nouns and no other product could fit, the CVO will read a tailor-made tender. Rewrite in outcomes, interfaces and tests. The companion pieces on vendor-written specifications apply with extra heat in a CPSE.

Why this vendor. A paid pilot, a GeM discovery, an IREPS notice, or a documented unique capability with a PAC if your manual allows it — those are stories. 'The CMD saw a demo' is not. Unsolicited proposals need a recorded handling path, not a quiet work order.

What data leaves. Training on company documents, a foreign prompt path, or a vendor engineer with production access is a disposal and a leak. Write the training ban, the residency, and the access list. Attach a classification note.

Whether posts are in play. A manpower-optimisation slide will be read as a hidden IR file and as a motive. Take it out. Retrieval, not replacement.

The CVO's four lines, translated into artefacts.

Query	Artefact that unblocks	Artefact that extends the stall
Who wrote the spec	Outcome-based SOW initialled by the user department	A pasted vendor data sheet
Why this vendor	Portal path, competitive note, or a real PAC	CMD WhatsApp screenshot
What data leaves	Classification, training ban, residency, access list	'We anonymise' with no method
Staffing	Explicit 'no change to sanctioned strength'	A heat map of low-value roles

Free POCs, GPUs, and hospitality

A free three-month pilot with the vendor's engineers on site, dinners, and a GPU left behind is a hospitality and a consideration question. Some manuals want even a rupee-one contract so the file can exist. Some want a paid POC. What they do not want is an undocumented gift. Write the consideration, the equipment custody, and who pays power and travel.

Do not let the vendor write the success criteria after they have seen the corpus. That is how every POC 'succeeds' and the CVO smells it.

The Integrity Pact and the incumbent SI

If the company uses an Integrity Pact, the agent vendor and any SI they hide behind are in it. Name the beneficial owner. A startup that is actually a reseller of a foreign API should say so before the CVO finds the hostname.

Incumbent SIs sometimes stall pilots at vigilance by whispering 'single source'. Sometimes they are right. If you need the SI, put them on the RACI and the invoice path. If you do not, write why the pilot is separable. Silence is what the whisper fills.

How to brief the CVO without a deck

One page. Need. Portal path. Spec author. Data classification and training ban. No staffing change. Integrity Pact status. Success tests written before the corpus is opened. Residual risks. That is the briefing. A twelve-slide vision of the intelligent maharatna is how you lose the morning.

Objections you will hear — and what to do with them

These are the lines that stall the file. Answer them in the room, then put the answer in the note. A spoken answer without paper will be forgotten by the next officer.

The CVO is blocking national AI.

The CVO is blocking an unwritten file. National strategy speeches are not a purchase path. Write the four lines.

Other maharatnas did a free POC.

Bring their written consideration and their CVO note. Anecdotes are not your Integrity Pact.

We cannot write success tests without seeing the data.

Then write tests on a redacted sample the company prepared. Seeing the full corpus before the test is how the test becomes theatre.

Vigilance wants ISO, STQC and a CAG certificate.

Ask which circular. Some asks are real for later production. Some are anxiety. Put the phase in the note: pilot versus production gates. Do not promise a fictional CAG AI certificate.

A four-week unblocking playbook

If the file is already on the desk, do not add slides. Add the missing sentences.

1. Week 1: rewrite the SOW without product nouns. Record who wrote it. Attach the user department's initial.
2. Week 2: write the procurement path and the consideration for the POC. Close any free-equipment ambiguity with a custody note.
3. Week 3: classification, training ban, residency, access list, no staffing change. Integrity Pact names.
4. Week 4: one-page CVO brief. Pre-agreed success tests on a company-prepared sample. Ask for queries in writing and answer in writing.

How this shows up in the file

Subject: AI pilot — specification authorship, consideration, data, no staffing change.

The user department wrote the outcome specification (annexure). The procurement path is (GeM / IREPS / advertised / PAC with reasons). Consideration and equipment custody are (note). Company data will not train a vendor model and will not leave the stated perimeter. Sanctioned strength is unchanged. Integrity Pact parties are listed.

This note is not a CVC circular and not legal advice.

This article is informational field guidance for Indian public sector undertakings and their vendors, not legal, audit, labour, energy-regulatory, banking-regulatory or procurement advice. Confirm the live circular, DPE guideline, CVC instruction, sector regulator text, purchase manual and your counsel before you file it.

How this clears vigilance and the board

A P5 Startup/Vendor in a PSU will meet CVC-shaped questions even when there is no special 'AI circular'. “Why PSU Pilots Stall at the Vigilance Desk” has to survive a technical committee, a cost centre, and a union conversation if jobs appear threatened.

The CVO is not anti-AI. The CVO is anti-a file that looks like a favoured vendor, a hidden staffing cut, or a gift of the company's corpus. Write the file they can defend. OT networks stay off-limits. Navratna autonomy speeds buying; it does not waive DPDP or data classification. IREPS is not GeM. RBI-shaped rules still localise payment data.

• Classify data before the POC.
• Keep agents off OT.
• Write the board memo with residual risk.
• Engage unions on retrieval vs replacement.

Close this loop before the next CAB

Put “Why PSU Pilots Stall at the Vigilance Desk” on the next change-advisory or bid-opening agenda as a single line item with an owner. If it cannot earn a line item, it will not earn a control. The owner should be a P5 Startup/Vendor, not “the vendor.”

Revisit the item when the model, the GeM term, the region, or the SI changes. “PSU pilot approval delay” is not a one-time workshop. It is a watch item. Date the last check. Unsigned watch items are souvenirs.

What must be true before you file this

If “Why PSU Pilots Stall at the Vigilance Desk” is only a heading, it will not survive a file inspection. A P5 Startup/Vendor should be able to attach one artefact that proves “PSU pilot approval delay”: a log export, a clause, a scored row, a dated notice, or a refusal rule.

Write three dated sentences: what was decided, who owns it, and when it will be re-checked. Unsigned sentences are souvenirs. Dated sentences are controls.

• Name the owner of “PSU pilot approval delay” inside the institution.
• Attach one artefact a stranger can open next year.
• Revisit when the model, the notice, or the SI changes.
• Do not treat a vendor slide as evidence.