设计可共存争议的问责记录，确保中立性不依赖任何一方解释。

Shared accountability records are often used by parties who may never agree about causation, responsibility, or normative interpretation. For such records, neutrality cannot be achieved by omitting contested information, because accountability requires preserving the claims parties made, with their sources and provenance. Nor can neutrality be achieved by asserting one contested interpretation as the shared base. This paper defines a neutral substrate as a shared representational layer that provides stable reference while making no object-level substrate-layer commitments to causal or normative propositions. The central design constraint is that, when causal and normative propositions are contestable across admissible frameworks and the substrate's referential commitments are common ground, the substrate's neutrality is guaranteed at design time if and only if its foundational layer is restricted to those referential commitments and attribution propositions whose attributional basis is fixed by them. Causal and normative content may still be represented, but not as object-level foundational-layer commitments: it may appear there only as the content of attributed assertions with provenance, made by some identified framework, source, agent, institution, record, or document. The representational machinery used here is standard: reification, attribution, and provenance. The contribution is the constraint: a checkable condition on the foundational layer of a shared record, stated together with the assumptions it depends on and the boundary condition under which the constraint does not apply. A neutral substrate says enough to preserve accountability, but it does not turn one party's interpretation into an object-level substrate-layer commitment. The constraint does not apply at that layer when the referential regime or attributional basis is contested among the frameworks in play.