You can express them as tests, but you also need a feedback mechanism that creates the rule that when the LLM generates some net new code or performs some refactor, that there are these CAPAs that it needs to cover with test cases.

The CAPA is a learning that sits outside of the mechanism of verification; it is a record of problem:root_cause:preventative_action. I see it as the instruction that would be required to generate the test case to prevent the next occurrence of a class of failures.

In a real-world process, for example, there is usually a QA lead that is verifying that the process is followed by looking at the paperwork and evidence.