AI Alignment

Draft complete but not yet reviewed; expect revisions

The Field as of October 2026

The chapters are written to stay right when the particular laws, frameworks, models, and incidents they mention have changed. They state mechanisms, arguments, derivations, and the conditions under which results hold, and where a current instance illustrates a point they name it in one dated sentence and point here. This appendix holds the particulars: what a statute or standard requires and its status, what a developer's framework or specification says and how it changed between versions, what happened in an incident, what named models scored, and which institutions, agreements, and programs exist and who belongs to them.

Everything here was written in October 2026. The sources were read between 5 and 9 October 2026, with later additions and corrections on 13 and 14 October and on 23 and 24 October; nothing published after 24 October 2026 is reflected. Each block opens with the chapter it serves and the date its information carries, so a reader can tell what to recheck. The chapters' findings do not depend on these particulars staying true; where a chapter's argument uses one, it says which.

I.1 Statutes, orders, and standards #

Statutes, executive orders, regulations, codes of practice, and technical standards, with their provisions, thresholds, dates, enforcement, and status. Chapter 63 explains why each kind of legal instrument works or fails; this section records what the instruments said when the book was written.

I.1.1 Instruments governing frontier models, in one table #

From Chapter 63; as of October 2026.

Table I.1 Instruments governing frontier models as of October 2026, as their texts state them
Instrument Status Trigger What it requires Enforcer Maximum penalty
EU AI Act, models with systemic risk (European Parliament and Council of the European Union, 2024b) In force; model duties from 2 August 2025, fines from 2 August 2026 High-impact capabilities, presumed above 102510^{25} training operations; or designation Evaluation with adversarial testing, risk mitigation, incident reporting, cybersecurity; documentation for the authorities Commission, through the AI Office 3% of worldwide turnover or €15 million, whichever is higher; withdrawal or recall of the model
US Executive Order 14110 (Executive Office of the President, 2023) Revoked 20 January 2025 (Executive Office of the President, 2025c) Over 102610^{26} operations Ongoing reports of training, weight security, red-team results Commerce Department, under the Defense Production Act None in the order's text
US Executive Order 14409 (Executive Office of the President, 2026) In force from 2 June 2026 A classified cyber benchmark Voluntary pre-release access, up to 30 days None; the framework is voluntary None; authorizes no licensing or preclearance
California SB 53 (Legislature, 2025b) Approved 29 September 2025 Over 102610^{26} operations; revenue over $500 million for most duties Publish and follow a framework; transparency reports; internal-use summaries; incident reports; whistleblower protection Attorney General $1 million per violation
New York RAISE Act, as replaced in 2026 (Legislature, 2025a; Legislature, 2026) Signed 19 December 2025; its article replaced by a law signed 27 March 2026; takes effect 1 January 2027 Over 102610^{26} operations; revenue over $500 million for most duties Publish and follow a framework; transparency reports; internal-use summaries; 72-hour incident reports; a disclosure statement filed with a state office Attorney General; an office in the Department of Financial Services $1 million first, $3 million later; $1,000 a day for a missing disclosure statement
Japan, Act No. 53 of 2025 (Government of Japan, 2025) In force Use of AI in business Cooperation with government measures Government guidance and advice None stated

I.1.2 The EU AI Act's provisions for general-purpose models #

From Chapter 63; as of October 2026.

The AI Act, Regulation (EU) 2024/1689, was published on 12 July 2024 and entered into force twenty days later, on 1 August 2024 (European Parliament and Council of the European Union, 2024b). Its recitals call for "a clearly defined risk-based approach," with some practices prohibited, requirements for high-risk systems, and transparency duties for others (European Parliament and Council of the European Union, 2024b). Beside these tiers, which are drawn by use, the Act regulates general-purpose AI models themselves. Every provider of one must keep a copyright policy and publish a summary of its training content, and, unless it releases the model openly (Section I.1.17), document its training, testing, and evaluation for the authorities and inform downstream providers (European Parliament and Council of the European Union, 2024b).

A stricter tier applies to models "with systemic risk," presumed when "the cumulative amount of computation used for its training measured in floating point operations is greater than" 102510^{25}; the Commission may also designate models and amend the threshold by delegated act, a rule it adopts under powers the Act delegates to it. Providers in this tier must evaluate their models "including conducting and documenting adversarial testing," assess and mitigate systemic risks, report serious incidents "without undue delay," and protect the model's cybersecurity (European Parliament and Council of the European Union, 2024b). Until a harmonized standard exists they may show compliance through a code of practice, which Section 62.5 reports (European Commission, 2025).

Enforcement against model providers belongs to the Commission, through the AI Office, with a graduated set of powers. It may request documentation and conduct evaluations, for which it "may request access to the general-purpose AI model concerned through APIs or further appropriate technical means and tools, including source code," with independent experts if it chooses. It may request mitigation measures and, last, require a provider to "restrict the making available on the market, withdraw or recall the model" (European Parliament and Council of the European Union, 2024b). Fines reach "3 % of their annual total worldwide turnover in the preceding financial year or EUR 15 000 000, whichever is higher," including for refusing access for an evaluation. The chapter on general-purpose models applied from 2 August 2025, with models already on the market given until 2 August 2027. As published, the Act applies generally, with the enforcement powers and fines, from 2 August 2026, and its rules for high-risk systems in products under Article 6(1) from 2 August 2027 (European Parliament and Council of the European Union, 2024b). As of October 2026 the fining power was two months old. The AI Omnibus, which the Commission describes as "a targeted simplification of the AI rulebook," entered into force on 27 July 2026. The Commission's notice gives new dates for the rules on high-risk systems: 2 December 2027 for those listed in Annex III, and 2 August 2028 for those embedded in products under Annex I. It names no new date for general-purpose models, and it extends the AI Office's oversight to "certain AI systems, including those built on general-purpose models and embedded in large online platforms and search engines" (European Commission, 2026).

I.1.3 The AI Act's summary of training content #

From Chapter 27; as of October 2026.

The European Union's AI Act requires providers of general-purpose models to adopt a policy for complying with copyright law and to publish "a sufficiently detailed summary about the content used for training," following a template from the AI Office (European Parliament and Council of the European Union, 2024b). Its recital asks that the summary be "generally comprehensive in its scope instead of technically detailed," for instance a list of the main data collections (European Parliament and Council of the European Union, 2024b).

I.1.4 What the EU code of practice asks of a framework #

From Chapter 62; as of October 2026.

The European Union's code of practice for the most capable general-purpose models now asks for a safety margin that accounts for "capability improvements after the time of assessment" and for "under-elicitation of model evaluations" (European Commission, 2025). The code's risk tiers are to be "defined in terms of model capabilities, and may additionally incorporate model propensities, risk estimates, and/or other suitable metrics," and the provider must justify how using them ensures that risk is acceptable (European Commission, 2025).

The European code asks providers to describe whether, and by what process, input from external actors including governments influences whether they proceed (European Commission, 2025). The European code asks for a changelog "describing how and why the Framework has been updated, along with a version number and the date of change." It gives the AI Office, the body that assesses providers' compliance under the European Union's AI Act, unredacted access to each framework and update (European Commission, 2025). The European code asks for a framework with justified risk acceptance criteria and gives the AI Office unredacted access, while stating that "adherence to the Code does not constitute conclusive evidence of compliance" with the underlying law (European Commission, 2025).

I.1.5 Access for outside evaluators under the EU code #

From Chapter 67; as of October 2026.

For monitoring after release, a signatory of the European code of practice provides "an adequate number of independent external evaluators with adequate free access" to its most capable model version with regard to each systemic risk, to that version's chains of thought if available, and to the version with the fewest safety mitigations for that risk, such as a helpful-only model if one exists, unless the model is "similarly safe or safer" for that risk (European Commission, 2025). The access may come through an interface, on its premises, or by publishing the weights (European Commission, 2025). It does not train on the evaluators' test runs without permission. It "will not take any legal or technical retaliation" against them for their testing or publication of findings, provided they follow conditions that include its procedure for responsible disclosure, under which it "cannot delay or block publication for more than 30 business days" in most cases (European Commission, 2025). Before release, outside evaluators get "adequate access, information, time, and other resources," and a provider that cannot find a qualified evaluator after a public call open for 20 business days must weigh the added uncertainty in its decision (European Commission, 2025).

I.1.6 The EU product liability directive #

From Chapter 63; as of October 2026.

The European Union's product liability directive of 23 October 2024 defines a product to include software (European Parliament and Council of the European Union, 2024a). Its recitals list "AI systems" among the software it covers, state that information and "the mere source code of software" are not products, and treat providers of AI systems under the AI Act as manufacturers. Liability is no-fault. The directive applies to products placed on the market after 9 December 2026, the date by which member states must transpose it, so as of October 2026 it governs no product yet (European Parliament and Council of the European Union, 2024a). It answers part of the causation problem. A court presumes a product defective when the defendant fails to disclose relevant evidence or the product shows "an obvious malfunction," and presumes causation when the damage "is of a kind typically consistent with the defect." It presumes either or both when "the claimant faces excessive difficulties, in particular due to technical or scientific complexity," and shows that they are likely. The defendant may rebut each presumption (European Parliament and Council of the European Union, 2024a).

Its limits are as specific. Compensation is for natural persons and for listed kinds of damage: death or personal injury, including "medically recognised damage to psychological health," damage to property not used exclusively for professional purposes, and the destruction of data not used professionally. A producer escapes liability by proving that "the objective state of scientific and technical knowledge" at the time did not allow the defect to be discovered, though member states may keep, or under conditions introduce, liability despite this defense. A producer that proves the defect probably arose after the product was placed on the market also escapes, but not when the defect is due to software, a related service, missing safety updates, or a substantial modification within its control. And the directive "does not apply to free and open-source software that is developed or supplied outside the course of a commercial activity" (European Parliament and Council of the European Union, 2024a).

I.1.7 United States executive orders and standards #

From Chapter 63; as of October 2026.

Federal policy was made by executive order, and it reversed. Executive Order 14110 of 30 October 2023 required developers of potential dual-use foundation models to report "on an ongoing basis" their training, the security of their model weights (the trained parameters that are the model), and "the results of any developed dual-use foundation model's performance in relevant AI red-team testing." The duty covered models trained with more than 102610^{26} operations, or 102310^{23} on primarily biological sequence data (Executive Office of the President, 2023). It was revoked on 20 January 2025 (Executive Office of the President, 2025c). Executive Order 14179, three days later, set a policy "to sustain and enhance America's global AI dominance" and called for an action plan (Executive Office of the President, 2025d). The plan of July 2025 opens with "The United States is in a race to achieve global dominance in artificial intelligence (AI)." It would withhold federal AI funding from states with "burdensome AI regulations," and has the government's standards center "Evaluate frontier AI systems for national security risks in partnership with frontier AI developers" (House, 2025).

Executive Order 14365 of 11 December 2025 created an AI Litigation Task Force "whose sole responsibility shall be to challenge State AI laws inconsistent with the policy" of the order. It asked the Commerce Department to identify state laws that "may compel AI developers or deployers to disclose or report information in a manner that would violate the First Amendment," and the Federal Communications Commission to consider "a Federal reporting and disclosure standard for AI models that preempts conflicting State laws" (Executive Office of the President, 2025a). Executive Order 14409 of 2 June 2026 directed a classified benchmarking process for cyber capabilities, with the Director of the National Security Agency setting the threshold for a "covered frontier model." It called for a voluntary framework under which developers could give the government access to such models "for a period of up to 30 days before they plan to release such models to other trusted partners," and it authorizes no "mandatory governmental licensing, preclearance, or permitting requirement" (Executive Office of the President, 2026). The federal standards are voluntary. The NIST AI Risk Management Framework is, by its abstract, "intended to be voluntary, rights-preserving, non-sector specific, and use-case agnostic" (Tabassi, 2023); a later NIST document on misuse risk for dual-use foundation models could be read only by its title (NIST, 2025).

I.1.8 The June 2026 executive order on cyber capability #

From Chapter 58; as of October 2026.

A June 2026 executive order directed a classified process to benchmark models' cyber capabilities, to designate a threshold above which a model is a "covered frontier model," and to offer developers a voluntary framework for up to thirty days of pre-deployment government access, without authorizing any new mandatory licensing, preclearance, or permitting requirement for model release (Executive Office of the President, 2026) (government order).

I.1.9 United States oversight of dual-use life-science research #

From Chapter 59; as of October 2026.

The 2024 federal policy on dual-use research of concern and pathogens with enhanced pandemic potential, issued in May 2024 and effective in May 2025, is a unified oversight framework that superseded the 2012 and 2014 policies: it defines two categories of covered research and assigns responsibilities to principal investigators, to their institutions, and to the federal agencies that fund them (United States Government, 2024). Its point of contact with Chapter 59 is a single subsection, and it is voluntary. The policy recognizes the increasing use of computational models, including artificial intelligence, that could contribute to dual-use biological knowledge. For such work it encourages institutional oversight, regardless of funding source, where the research could directly enable the design of an enhanced pathogen or a novel agent, with an assessment of benefits and risks and a mitigation plan where appropriate (United States Government, 2024).

A 2025 executive order then revised the arrangement, which is itself the evidence that this kind of oversight moves with administrations. It directs agencies to end federal funding of dangerous gain-of-function research conducted by foreign entities in countries of concern, and to suspend such federally funded research pending a revised policy. It also directs that the 2024 policy be revised or replaced, that a strategy reach research conducted without federal funding, and that a public reporting mechanism be created for covered research (Executive Office of the President, 2025b). One of its provisions is the chokepoint that Section 59.4 identified as the target that cannot be copied: it directs revision of the framework for screening orders for synthetic nucleic acids so that providers implement comprehensive, scalable, and verifiable screening, with enforcement mechanisms, and requires federally funded researchers to buy only from providers that adhere to it (Executive Office of the President, 2025b).

I.1.10 California's and New York's frontier statutes #

From Chapter 63; as of October 2026.

SB 53, approved on 29 September 2025, covers frontier models trained with more than 102610^{26} operations, counting fine-tuning and reinforcement learning, and puts most duties on large frontier developers, those with annual gross revenues above five hundred million dollars (Legislature, 2025b). Its catastrophic risk is a risk of contributing to the death or serious injury of "more than 50 people or more than one billion dollars" in damage to, or loss of, property from one incident, a bar more than an order of magnitude below the frameworks' own, which one developer handles in separate compliance documents (Section 62.3.2). The framework duty, its penalty of up to one million dollars per violation enforceable only by the Attorney General, and its rule on revisions are read in Section 61.5.3; the incident duty in Section 54.6.2; the whistleblower protections in Section 53.4.1. The statute also requires a transparency report before or with each new deployment, stating "the extent to which third-party evaluators were involved," and summaries of risk from internal use to the state's emergency office every three months or on another reasonable schedule the developer gives the office in writing (Legislature, 2025b). Three further provisions matter here. A developer may be deemed compliant with the incident duty by meeting a designated federal standard "substantially equivalent to, or stricter than" the state's. From 2027 the definitions must be reviewed yearly, weighing "the external verifiability of determining whether a person or foundation model is covered"; and local rules adopted on or after 1 January 2025 that specifically regulate frontier developers' management of catastrophic risk are preempted (Legislature, 2025b).

New York's RAISE Act was signed on 19 December 2025, with an approval memorandum (Legislature, 2025a). The article that the text passed in 2025, S6953B, added to the General Business Law is not the one that will apply. Chapter 96 of the Laws of 2026, signed on 27 March 2026, repealed it and put a new article under the same name in its place. It also replaced the act's effective date, the ninetieth day after it became law, with 1 January 2027, the date from which the new article applies (Legislature, 2026). The new article covers frontier models, foundation models trained with more than 102610^{26} operations, counting fine-tuning and reinforcement learning. It puts the framework duty and most reports on large frontier developers, those whose revenues with their affiliates exceeded five hundred million dollars in the preceding year, and excludes accredited colleges and universities doing academic research (Legislature, 2026). Its catastrophic risk uses SB 53's bar, the death or serious injury of more than fifty people or more than a billion dollars of damage to or loss of property from one incident. A large frontier developer must write, follow, and publish a frontier AI framework, review it every year, and send summaries of its assessments of catastrophic risk from internal use every three months, or on another reasonable schedule it requests and the office agrees to. Every frontier developer must publish a transparency report before or with each new deployment and report critical safety incidents within seventy-two hours to an office within the state's Department of Financial Services (Section I.1.16). A large frontier developer must also file a disclosure statement with that office, naming its offices, owners, and contacts, and pay a share of the office's costs; without a current statement it may not "develop, deploy, or operate a frontier model, in whole or in part in New York state," and the office publishes a list of the developers that have filed (Legislature, 2026). The Attorney General may sue a large frontier developer for civil penalties of up to one million dollars for a first violation and three million for later ones; the article creates no private right of action, and the office may, after notice and hearing, impose a penalty of a thousand dollars a day for a missing disclosure statement (Legislature, 2026). The bar on developing without a statement is a registration duty: filing names the developer, its offices, owners, and contacts, and the article gives no one a power to halt a model's training on a finding about its risk (inference). The new article has no counterpart to the 2025 text's ban on deploying a model that "would create an unreasonable risk of critical harm," its rule on replicable test records, or its penalties of ten and thirty million dollars (Legislature, 2025a).

I.1.11 What California's statute asks of a framework #

From Chapter 62; as of October 2026.

The framework must describe how the developer defines thresholds, applies mitigations, uses third parties, and updates the framework, and failing to comply with it carries a civil penalty (Legislature, 2025b).

California's statute now requires a large frontier developer that makes a material modification to publish the modified framework "and a justification for that modification within 30 days" (Legislature, 2025b).

I.1.12 California's penalties and revision rules for frameworks #

From Chapter 61; as of October 2026.

Under California's statute, a developer that "fails to comply with its own frontier AI framework" is subject to a civil penalty "dependent upon the severity of the violation that does not exceed one million dollars" per violation. The penalty is recovered in a civil action "brought only by the Attorney General" (Legislature, 2025b). The developer must not make a materially false or misleading statement about its compliance with its framework, unless the statement was made in good faith and was reasonable under the circumstances. It must review the framework at least once a year, and if it makes a material modification, it must publish the modified framework "and a justification for that modification within 30 days" (Legislature, 2025b).

I.1.13 Whistleblower protections in California's statute #

From Chapter 53; as of October 2026.

California's 2025 statute on large frontier developers answers part of the diagnosis in the employees' 2024 letter of Section 53.4.1 (Legislature, 2025b). It forbids a frontier developer to prevent or punish disclosure by a "covered employee" to the Attorney General, a federal authority, or a person with authority to correct the problem. The protection applies when the employee has reasonable cause to believe that the developer's activities "pose a specific and substantial danger to the public health or safety resulting from a catastrophic risk," or that the developer violated the statute (Legislature, 2025b). That reaches the risks the letter said were not yet illegal. A covered employee is defined by role: "an employee responsible for assessing, managing, or addressing risk of critical safety incidents" (Legislature, 2025b). Large developers must run an anonymous internal process that includes "a monthly update to the person who made the disclosure." The disclosures and responses "shall be shared with officers and directors" at least once each quarter, except with an officer or director accused in them (Legislature, 2025b).

I.1.14 Japan's and South Korea's AI laws, and China's guidance in 2026 #

From Chapter 63; as of October 2026.

Concordia AI's 2026 survey, an organization's tracking report, describes guidance on agentic AI issued in May 2026 with "a full chapter to safety," and finds frontier risks discussed more "even as concrete requirements remain limited" (AI, 2026; AI, 2025).

Japan's Act No. 53 of 2025 is a promotion law: businesses must "cooperate with the measures implemented by the national government," the government responds to rights infringements with "guidance, advice," and the English text has no penalty provision (Government of Japan, 2025). South Korea's Framework Act, in force from 22 January 2026, defines "high-impact AI" by area of use. Its translator summarizes the rest as creating an AI safety research institute and requiring foreign companies to designate a Korean representative (Korea, 2025).

I.1.15 What SB 53 and the EU code ask of model documentation #

From Chapter 67; as of October 2026.

Under SB 53 a developer may redact for trade secrets, cybersecurity, public safety, or national security, but must "describe the character and justification of the redaction" and keep the unredacted version (Legislature, 2025b).

The EU code's model report includes all evaluation results relevant to the risks, with how each was run and scored, "at least five, random samples of inputs and outputs from each relevant model evaluation" to allow independent interpretation, a description of the access given to outside evaluators, and their reports (European Commission, 2025). The public receives a summarized version "if and insofar as necessary to assess and/or mitigate systemic risks" (European Commission, 2025). The AI Office gets access to the report by the time the model is placed on the market, and to an updated report within five business days of a confirmed update; a provider may delay either by up to 15 business days, only if the Office considers it to be acting in good faith and it provides an interim report without delay (European Commission, 2025).

I.1.16 Incident reporting duties in statute #

From Chapter 54; as of October 2026.

Statutes now require some incident reporting. California's 2025 statute on frontier developers requires a developer to report a "critical safety incident" to the state's Office of Emergency Services within 15 days of discovering it. If the incident poses an imminent risk of death or serious physical injury, the report goes within 24 hours to an appropriate authority (Legislature, 2025b). The definition includes a model that "uses deceptive techniques against the frontier developer to subvert the controls or monitoring of its frontier developer outside of the context of an evaluation designed to elicit this behavior," in a way that materially increases catastrophic risk (Legislature, 2025b). New York's 2026 article, which applies from 1 January 2027, has the same twenty-four-hour rule and the same clause on deceptive techniques. Its reports to an office within the state's Department of Financial Services are due within seventy-two hours of a determination that a critical safety incident occurred, or of learning facts that support a reasonable belief that one did (Legislature, 2026). The European Union's AI Act requires providers of general-purpose models with systemic risk to "keep track of, document, and report, without undue delay," relevant information about serious incidents (European Parliament and Council of the European Union, 2024b).

I.1.17 What the instruments say about release #

From Chapter 63; as of October 2026.

The AI Act treats open release as a reason for lighter documentation duties. Providers of models released "under a free and open-source licence" whose weights, architecture, and usage information are public are exempt from the duties to document the model for the authorities and for downstream providers, and from appointing a representative in the Union. "This exception shall not apply to general-purpose AI models with systemic risks" (European Parliament and Council of the European Union, 2024b). The recitals add that open release "does not necessarily reveal substantial information on the data set used for the training" (European Parliament and Council of the European Union, 2024b).

The federal government has chosen not to regulate release. The 2025 action plan states that the decision "is fundamentally up to the developer" and asks the government to "create a supportive environment for open models" (House, 2025), and the 2026 order authorizes no mandatory "licensing, preclearance, or permitting requirement for the development, publication, release, or distribution of new AI models" (Executive Office of the President, 2026). The two state statutes treat release alike. SB 53 requires cybersecurity only for "unreleased model weights" and leaves release itself alone (Legislature, 2025b), and New York's 2026 article does the same in the same words (Legislature, 2026). The EU product liability directive excludes "free and open-source software that is developed or supplied outside the course of a commercial activity" (European Parliament and Council of the European Union, 2024a).

Sources cited in Section I.1 21
  1. European Parliament and Council of the European Union (2024b) Regulation (EU) 2024/1689 laying down harmonised rules on artificial intelligence
  2. Executive Office of the President (2023) Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence
  3. Executive Office of the President (2025c) Initial Rescissions of Harmful Executive Orders and Actions
  4. Executive Office of the President (2026) Promoting Advanced Artificial Intelligence Innovation and Security
  5. Legislature (2025b) SB-53 Artificial intelligence models: large developers.
  6. Legislature (2025a) Responsible AI Safety and Education Act (New York RAISE Act)
  7. Legislature (2026) Transparency and safety requirements for developers of artificial intelligence frontier models (New York Laws of 2026, Chapter 96)
  8. Government of Japan (2025) Act on Promotion of Research and Development, and Utilization of Artificial Intelligence-related Technology
  9. European Commission (2025) The General-Purpose AI Code of Practice
  10. European Commission (2026) AI Omnibus enters into force
  11. European Parliament and Council of the European Union (2024a) Directive (EU) 2024/2853 (Product Liability Directive)
  12. Executive Office of the President (2025d) Removing Barriers to American Leadership in Artificial Intelligence
  13. House (2025) Winning the Race: America’s AI Action Plan
  14. Executive Office of the President (2025a) Ensuring a National Policy Framework for Artificial Intelligence
  15. Tabassi (2023) Artificial Intelligence Risk Management Framework (AI RMF 1.0)
  16. NIST (2025) Managing Misuse Risk for Dual-Use Foundation Models
  17. United States Government (2024) United States Government Policy for Oversight of Dual Use Research of Concern and Pathogens with Enhanced Pandemic Potential
  18. Executive Office of the President (2025b) Improving the Safety and Security of Biological Research
  19. AI (2026) State of AI Safety in China (2026)
  20. AI (2025) State of AI Safety in China (2025)
  21. Korea (2025) Framework Act on the Development of Artificial Intelligence and Establishment of Trust

I.2 Developers' frameworks and specifications #

Developers' safety frameworks as written in October 2026 and their version histories, model specifications and constitutions, published system prompts, and what system cards and risk reports contain. Chapter 62 explains how a framework is meant to bind and where it can fail.

I.2.1 The reference frameworks as written #

From Chapter 62; as of October 2026.

OpenAI's Preparedness Framework, in its second version of April 15, 2025, tracks three categories: biological and chemical capabilities, cybersecurity, and AI self-improvement (OpenAI, 2025e) (developer document). Each category has two thresholds. High capability thresholds "mean capabilities that significantly increase existing risk vectors for severe harm," and a model that crosses one needs safeguards that sufficiently minimize the risk before it is deployed. Critical capability thresholds "mean capabilities that present a meaningful risk of a qualitatively new threat vector for severe harm with no ready precedent." They "require safeguards even during the development of the covered system, irrespective of deployment plans" (OpenAI, 2025e). The table of categories pairs each Critical threshold with halting further development until safeguards that would meet a Critical standard have been specified. Severe harm means "the death or grave injury of thousands of people or hundreds of billions of dollars of economic damage." Five further areas are research categories: capabilities that need more threat modeling before they can be measured rigorously, or that could undermine the safeguards themselves. Sandbagging, responding to evaluations in a way that diverges from performance under real conditions (Chapter 34), is one of them (OpenAI, 2025e).

Google DeepMind's Frontier Safety Framework, in version 3.1 of April 17, 2026, is built around Critical Capability Levels, "capability levels at which, absent mitigation measures, frontier AI models or systems may pose heightened risk of severe harm" (DeepMind, 2026) (developer document). They cover chemical, biological, radiological, and nuclear (CBRN) weapons, cyber attacks, harmful manipulation, and machine learning research with misalignment. Version 3.1 added lower Tracked Capability Levels, "meant to capture significant risks that may manifest at a lower capability threshold" (DeepMind, 2026). When a model reaches a critical level, the framework supplements its assessment of the remaining risk with a safety case, a structured argument that the risk is acceptable (Chapter 52). For the misuse levels, the condition that deployment mitigations bring the remaining risk to an acceptable level "is required only for external deployment, not internal deployment or further development" (DeepMind, 2026).

A framework published in 2025 by the Shanghai Artificial Intelligence Laboratory with Concordia AI is written as guidance for developers (Shanghai AI Laboratory and AI, 2025). It defines red lines as "intolerable thresholds that must not be crossed" and yellow lines as "early warning indicators for potential risks," and it sorts models into green, yellow, and red zones. A developer whose model crosses a red line should suspend the relevant operations and "conduct and pass the mandatory independent third-party safety review before any resumption of operations" (Shanghai AI Laboratory and AI, 2025). Among the frameworks read for Chapter 62, it is the only one that makes an outside review a condition of resuming.

Table I.2 sets the reference frameworks side by side in the versions read for Chapter 62. Two columns carry most of the argument of Chapter 62: whether a crossing can stop development or only deployment, and who decides that a threshold has been crossed.

Table I.2 The reference frameworks, as their own documents describe them
Framework Risk domains Levels What a crossing requires Who decides Reaches development? Outside review
Anthropic, Responsible Scaling Policy 1.0 (2023) (Anthropic, 2023a) Misuse (CBRN, cyber); autonomy and replication AI Safety Levels 2 and 3 defined; 4 to be defined Containment before training continues, deployment measures before use; otherwise pause Updates approved by the board after consulting the company's trust; a Responsible Scaling Officer reports quarterly Yes Not among its commitments
Anthropic, versions 3.0 to 3.4 (2026), as the announcement and change log describe them (Anthropic, 2026ap; Anthropic, 2026h) As above; thresholds for automated AI research and chemical and biological weapons revised Thresholds with required safeguards, and a separate map of mitigations recommended for the industry Risk reports every 3 to 6 months; roadmap goals that are public but not binding Trust may request external review of risk reports and approve the reviewers Not stated in the documents read; the developer says it remains free to pause "in any circumstances" it deems appropriate Required "in certain circumstances"
OpenAI, Preparedness Framework 2 (2025) (OpenAI, 2025e) Biological and chemical; cybersecurity; AI self-improvement High, Critical High: safeguards before deployment; Critical: safeguards during development Safety Advisory Group recommends; leadership decides; a board committee may review and the board may reverse At Critical Third parties "when available and feasible"
Google DeepMind, Frontier Safety Framework 3.1 (2026) (DeepMind, 2026) CBRN; cyber; harmful manipulation; machine learning research and misalignment Tracked and Critical Capability Levels, with alert thresholds A security level per critical level; mitigations and a safety case before external and high-risk internal deployment "The appropriate governance function" Through weight security only: security at the recommended level, or judged adequate, conditions further development; deployment mitigations do not External experts "as needed"
Shanghai AI Laboratory with Concordia AI (2025) (Shanghai AI Laboratory and AI, 2025) Cyber offense; biological threats; persuasion and manipulation; loss of control Yellow and red lines; green, yellow, and red zones Past a red line: suspend operations The developer, with an independent review required before resuming Yes Required before resuming

I.2.2 What the published frameworks contain #

From Chapter 62; as of December 2025.

In December 2025 METR, an evaluation organization, compared the twelve frameworks then published, from Anthropic, OpenAI, Google DeepMind, Magic, Naver, Meta, G42, Cohere, Microsoft, Amazon, xAI, and NVIDIA (Metr, 2025a). It writes that the concept "was initially introduced by METR in 2023," which makes it a party to the genre it surveys. Its comparison used Anthropic's version 2.2 and Google DeepMind's version 3.0, both since revised. Table I.3 gives its counts.

Table I.3 Elements in the twelve published frameworks, as METR counted them in December 2025 (Metr, 2025a)
Element Frameworks with it (of 12) Frameworks without it
Capability thresholds 9 Naver, Cohere, NVIDIA
Model weight security 11 Naver
Deployment mitigations 12 none
Conditions for halting deployment 9 Magic, Cohere, NVIDIA
Conditions for halting development 8 Naver, Cohere, Amazon, xAI
Full capability elicitation during evaluations 7 Magic, Naver, Cohere, xAI, NVIDIA
Timing and frequency of evaluations 9 Cohere, xAI, NVIDIA
Accountability 12 none
Updating the policy 12 none

METR itself notes that the twelve differ in kind. NVIDIA's and Cohere's frameworks "emphasize domain-specific risks rather than focusing solely on catastrophic risk," and xAI's and Magic's lean heavily on quantitative benchmarks (Metr, 2025a). xAI's framework, for example, outlines "the quantitative thresholds, metrics, and procedures that xAI may utilize" (xAI, 2025c) (developer document); a commitment phrased as what a developer may do counts as present in such a table (inference).

I.2.3 Thresholds and buffers in the current frameworks #

From Chapter 62; as of October 2026.

Google DeepMind defines alert thresholds "designed to flag when a CCL may be reached before a critical capability assessment is conducted again," and it may "adjust alert thresholds if the rate of progress suggests our safety buffer is no longer adequate" (DeepMind, 2026). It names the elicitation problem directly: "other actors may put significantly more effort into eliciting capabilities than we put into assessing risk." For its machine learning research levels it adds that it does not expect other groups to out-invest it, and so may use its own research progress as evidence (DeepMind, 2026).

OpenAI tracks a category only if it meets five criteria, among them that it is "Measurable: We can construct or adopt capability evaluations that measure capabilities that closely track the potential for the severe harm" (OpenAI, 2025e). Google DeepMind folds a notion of risk into the wording of its capability levels: its cyber level is a model that "provides sufficient uplift with high impact cyber attacks for additional expected harm at severe scale" (DeepMind, 2026), with no number attached to the expected harm.

OpenAI's second version moved persuasion out of the framework, on the ground that its risks "do not fit the criteria for inclusion," and moved nuclear and radiological capability into the research categories (OpenAI, 2025e). Google DeepMind added a critical level for harmful manipulation in 2025 (DeepMind, 2025a), and in version 3.1 set a tracked level for misalignment at the point where a model's situational awareness and stealth mean "we cannot rule out the model significantly undermining human control" (DeepMind, 2026) (Chapter 34).

OpenAI says its risk assessment draws on feedback from academics, independent experts, industry bodies, and "the U.S. government and its partners" (OpenAI, 2025e); Google DeepMind says that "where appropriate, we may engage relevant external actors, including governments" (DeepMind, 2026).

I.2.4 What Google DeepMind's stealth and situational awareness level triggers #

From Chapter 34; as of October 2026.

Reaching the tracked capability level for stealth and situational awareness in Google DeepMind's Frontier Safety Framework (Section I.2.3) triggers periodic assessments of misalignment risk and, where needed, safeguards such as monitoring the chain of thought in high-risk internal deployments (DeepMind, 2026) (developer document; Chapter 62).

I.2.5 Cyber thresholds in the frameworks #

From Chapter 58; as of October 2026.

The developers' safety frameworks already treat cyber as a tracked risk. One framework names cybersecurity a tracked category with High and Critical capability thresholds and the safeguards each requires, the Critical threshold asking whether a tool-augmented model can find and develop working zero-day exploits across many hardened real-world systems without human intervention (OpenAI, 2025e) (developer document). A second sets a cyber critical capability level at the point where a model gives enough uplift to a high-impact attack to raise expected harm at severe scale (DeepMind, 2026) (developer document). A third moved from capability-triggered safeguards toward periodic risk reports, one of which raised its own assessment of misalignment risk from "very low" to "low" partly in light of the cyber-evaluation incidents Chapter 58 treats (Anthropic, 2026h; Anthropic, 2026ar) (developer documents).

I.2.6 Chemical and biological thresholds in the frameworks #

From Chapter 59; as of October 2026.

OpenAI's framework names Biological and Chemical capabilities as one of three Tracked Categories, with High capability thresholds requiring safeguards before deployment and Critical thresholds requiring them during development (OpenAI, 2025e); Google DeepMind's framework defines critical capability levels for chemical, biological, radiological, and nuclear risks, and its version 3.1 adds lower tracked capability levels in the same domain (DeepMind, 2026); and Anthropic's policy added, in March 2025, a capability threshold for substantial uplift to the development capabilities of moderately resourced state programs (Anthropic, 2026h). All three are developer documents. A framework published by the Shanghai AI Laboratory with Concordia AI sets out unacceptable outcomes it calls red lines and early warning indicators it calls yellow lines, with biological threats among the areas it covers (Shanghai AI Laboratory and AI, 2025).

I.2.7 One developer's thresholds under strain #

From Chapter 62; as of February 2026.

By 2026 the developer that published the numbers (Section 62.2.1) reported growing difficulty in placing its models relative to its thresholds. Its policy required, once models crossed a threshold for automated AI research it calls AI R&D-4, an affirmative case that the misalignment risks had been mitigated. In February 2026 it determined that Claude Opus 4.6 did not cross it, but added that "confidently ruling out this threshold is becoming increasingly difficult, and doing so requires assessments that are more subjective than we would like" (Anthropic, 2026h) (developer document). Rather than rely on those assessments alone, it committed to writing sabotage risk reports, whose first version and its reviews Section 52.4 reports (Bowman et al., 2025).

The announcement of its third version named the problem more broadly. "We found pre-set capability levels to be far more ambiguous than we anticipated: in some cases, model capabilities have clearly approached the RSP thresholds, but we have had substantial uncertainty about whether they have definitively passed those thresholds" (Anthropic, 2026ap). Its example is biology: its models pass "most tests we can run quickly and easily, so we can no longer make a strong argument that risks are low," yet the tests alone "aren't sufficient for a strong argument that risks are high, either" (Anthropic, 2026ap). The developer calls this a "zone of ambiguity."

I.2.8 The version record of the reference frameworks #

From Chapter 62; as of August 2026.

Table I.4 lists the versions of the three reference frameworks with each change as its developer describes it. It records descriptions, not the book's verdict, and Exercise 62.3 asks the reader to classify one entry.

Table I.4 Versions of the reference frameworks, as their developers describe the changes
Date Version Change, in the developer's description Concerns
Sep 2023 Anthropic 1.0 (Anthropic, 2023a) First version: safety levels, evaluations every fourfold increase in effective compute and every three months, a sixfold buffer All
Dec 2023 OpenAI beta (OpenAI, 2023) Tracked categories scored low to critical; deploy only at "medium" or below after mitigation, develop further only at "high" or below All
May 2024 Google DeepMind 1.0 (DeepMind, 2024; DeepMind, 2026) First version: critical levels in autonomy, biosecurity, cybersecurity, and machine learning research, to be implemented by early 2025 All
Oct 2024 Anthropic 2.0 (Anthropic, 2026h) Reports four shortfalls against the first version; extends the evaluation interval to six months; notes that the sixfold buffer could not be established with confidence Evaluation, governance
Feb 2025 Google DeepMind 2.0 (DeepMind, 2025b) Security levels per critical level; safety case reviewed by a governance body before general availability; an approach to deceptive alignment Safeguards, governance
Mar 2025 Anthropic 2.1 (Anthropic, 2026h) Adds a CBRN threshold for uplift to moderately resourced state programs; splits the AI research threshold into two levels Thresholds
Apr 2025 OpenAI 2 (OpenAI, 2025e) Removes "low" and "medium"; adds five tracking criteria and research categories; moves persuasion out; adds a clause on other developers' releases Thresholds, scope
May 2025 Anthropic 2.2 (Anthropic, 2026h) Excludes "both sophisticated insiders and state-compromised insiders" from the scope of one security standard Safeguards
Sep 2025 Google DeepMind 3.0 (DeepMind, 2025a) Adds a harmful manipulation level; protocols for machine learning research levels, including large internal deployments Thresholds, scope
Feb 2026 Anthropic 3.0 (Anthropic, 2026ap) Comprehensive rewrite: roadmaps of public goals, periodic risk reports, a map of mitigations recommended for the industry Structure, disclosure
Apr 2026 Anthropic 3.1 (Anthropic, 2026h) Clarifies the AI research threshold; states the developer remains free to pause in any circumstances Thresholds
Apr 2026 Google DeepMind 3.1 (DeepMind, 2026) Adds tracked levels; folds misalignment into a combined domain; raises security for misuse levels Thresholds, safeguards
Apr 2026 Anthropic 3.2 (Anthropic, 2026h) The trust may request external review of risk reports and approve the reviewers Governance
May 2026 Anthropic 3.3 (Anthropic, 2026h) Revises the threshold for novel chemical and biological weapons "to better track the threat model of concern" Thresholds
Jul 2026 Anthropic 3.4 (Anthropic, 2026h) Revises the AI research threshold; shares unredacted risk reports with at least 200 employees instead of all regular-clearance staff Thresholds, disclosure

Four entries carry most of the evidence. The first is the developer's own review in October 2024. It "identified a small number of instances where we fell short of meeting the full letter of its requirements," three of which Section 62.2.3 reports, and judged that all "posed minimal risk to the safety of our models" (Anthropic, 2026h) (developer document). Its lessons were "we needed to incorporate more flexibility into our policies, and we needed to improve our process for tracking compliance." Read as learning, a developer disclosed shortfalls it had found itself, and it says it now tracks the missing elicitation techniques among them. Read as drift, two of the shortfalls were resolved by loosening the rule they broke: the missed three-month interval became six months, and the buffer that could not be established became a note in the policy (inference).

The second is the rewrite of February 2026. The first policy was built on "conditional, or if-then, commitments"; the third version separates "the mitigations that we plan to pursue regardless of what others do" from a map of mitigations it recommends for the whole industry (Anthropic, 2026ap) (developer document). Its roadmap goals are, in its words, not "hard commitments" but "public goals that we will openly grade our progress towards." The stated reasons are three: the zone of ambiguity of Section 62.2.5, a policy environment that "has shifted toward prioritizing AI competitiveness and economic growth," and higher-level protections that "might prove outright impossible to implement without collective action" (Anthropic, 2026ap). The developer names the convenient path and says it declined it: "We could have tried to address this by defining ASL-4 and ASL-5 safeguards in ways that made compliance easy to achieve," which "would undermine the intended spirit of the RSP." It chose instead "more realistic unilateral commitments that are difficult but still achievable in the current environment" (Anthropic, 2026ap). Read as learning, this replaces promises the developer judged it could not keep with ones it can, and adds disclosure. Read as drift, the same sentence describes moving a commitment to where the developer can meet it, which is the question Section 62.3 leaves open (inference). The announcement's account of what the policy achieved, that it "did incentivize us to develop stronger safeguards" and that the ASL-3 protections were activated in May 2025, is the developer's claim about itself (Anthropic, 2026ap).

The third is a pair of threshold rewrites in 2026, which the developer's August risk report sets out side by side (Anthropic, 2026ar) (developer report). The AI research threshold under version 3.0 was to trigger when "a model could compress two years of 2018 – 2024 AI progress into a single year." Under version 3.4 it is met if models "would be able to fully substitute for our entire set of Research Scientists and Research Engineers, at competitive costs," or if there is "dramatic acceleration" of AI progress likely due to automated research (Anthropic, 2026ar). Version 3.3 rewrote the threshold for novel chemical and biological weapons from systems that "significantly help threat actors" to systems that "functionally substitute for the scarce human expertise" that is the main barrier. The rewrite came while the developer reported acting "as though they meet our CB-1 threshold," the lower one, and judged that its models "do not yet meet" the higher (Anthropic, 2026ar). Whether either rewrite raises or lowers the bar is a judgment the published text cannot settle without the evidence on how each wording maps to harm. The stated reason, to "better track the threat model of concern" (Anthropic, 2026h), restates a purpose rather than citing that evidence (inference). The domain of the chemical and biological threshold is Chapter 59's.

The fourth is OpenAI's move from its beta to its second version. The beta allowed deployment only of models with "a post-mitigation score of 'medium' or below," and further development only at "high" or below (OpenAI, 2023) (developer document). The second version removed the terms "low" and "medium," "because those levels were not operationally involved in the execution of our Preparedness work," and moved persuasion outside the framework (OpenAI, 2025e). A deployment rule stated as a score became a rule stated as a judgment, that safeguards "sufficiently minimize" the risk, which is harder for an outsider to check and easier to apply to cases the scores did not foresee (inference). The insider exclusion of Anthropic's version 2.2 belongs to the same pattern of a scope narrowed by footnote, and Section 53.5 reports it with the security levels it should be read against.

I.2.9 Clauses keyed to other developers #

From Chapter 62; as of October 2026.

OpenAI's second version allows it to adjust its required safeguards if another developer releases a system with High or Critical capability "without instituting comparable safeguards." It may do so only if the adjustment "does not meaningfully increase the overall risk of severe harm," is publicly acknowledged, and keeps its safeguards "more protective than the other AI developer." The framework presents the last condition as a way "to avoid a race to the bottom on safety" (OpenAI, 2025e). Google DeepMind counts what is available elsewhere in its acceptance decision: "if other models are similarly capable and have few mitigations, then the marginal risk added by our external deployment is likely low." It adds that some of its mitigations reduce risk for society "only if all relevant organizations provide similar levels of protection" (DeepMind, 2026).

I.2.10 Decision rights in the reference frameworks #

From Chapter 62; as of August 2026.

OpenAI's framework gives the most explicit allocation (OpenAI, 2025e) (developer document). A Safety Advisory Group, an internal group of company leaders, reviews the evidence and recommends; "OpenAI Leadership can approve or reject these recommendations." The group has no veto: leadership "can also make decisions without the SAG's participation, i.e., the SAG does not have the ability to 'filibuster'." Its members and chair "are appointed by the OpenAI Leadership." The board's Safety and Security Committee has visibility into the process, and "where necessary, the Board may reverse a decision" (OpenAI, 2025e).

Anthropic's first policy named a Responsible Scaling Officer who reports each quarter to the board and to the company's trust, "explicitly noting any deficiencies in implementation," and it required board approval, after consulting the trust, for any update (Anthropic, 2023a) (developer document). The trust is, in the developer's description, "an independent body of five financially disinterested members" with authority over a growing part of the board (Anthropic, 2023f), and Section 61.5 reads its terms as a commitment. Version 3.2 let the trust request external review of risk reports and approve the reviewers (Anthropic, 2026h). By August 2026 it had not requested one, and the policy had not required one; the developer reports continuing pilot reviews instead by two outside groups, METR for one section and SecureBio for others (Anthropic, 2026ar) (developer report; Section 52.4 reports the reports). The developer also publishes a noncompliance reporting and anti-retaliation policy, updated in March 2026 to expand reporting channels (Anthropic, 2026h).

Google DeepMind's framework assigns decisions to "the appropriate governance function" and describes "legal, compliance, and safety reviews with escalation procedures to ensure appropriate oversight" (DeepMind, 2026) (developer document). Its second version said that a governance body reviews the safety case and that general availability follows "only if it is approved" (DeepMind, 2025b).

I.2.11 Decisions attributed to the frameworks #

From Chapter 62; as of October 2026.

The record now holds several decisions that developers say their frameworks produced. In 2025 multiple companies released models with added safeguards after pre-deployment testing could not rule out that they could meaningfully help novices develop biological weapons (Bengio et al., 2026), cases that Section 59.2.4 reports. In 2026 OpenAI cited "preliminary evidence that one of our upcoming models, Astra, may meet the Critical cybersecurity capability threshold under our Preparedness Framework" (OpenAI, 2026q) (developer statement). Together with an incident and rapid research progress, it wrote, this led it to slow the pace of scaling, including "a two-week pause in reinforcement learning (RL) training on our latest models intended for deployment" (OpenAI, 2026q). It also reports that "a significant number of workloads remain paused" until they meet a stricter security bar (OpenAI, 2026q). Section 58.1 and Section 54.7.2 report the rest. In September 2026 OpenAI's system card for GPT-6 Astra reported the developer's determination that the model reaches the Critical level in cybersecurity and the High level in the biological and chemical category: "Astra is our first model to reach the Critical level of cybersecurity capability under our Preparedness Framework" (OpenAI, 2026l) (developer report). The card says the developer "applied our strongest safeguards yet" to the model, and that its internal Safeguards Report informed the Safety Advisory Group's recommendation and leadership's determination "that these safeguards are sufficient for Astra's public launch" (OpenAI, 2026l). An addendum published on 29 September 2026 treats GPT-6.1 Sol as Critical in cybersecurity as well, with the same safeguards (OpenAI, 2026b) (developer report). And in February 2026 Anthropic published a determination that a model did not cross its AI research threshold (Anthropic, 2026h).

I.2.12 Frameworks that call for a written case #

From Chapter 52; as of October 2026.

In February 2026, before version 3.0 rewrote it, Anthropic's Responsible Scaling Policy required, once models crossed a threshold it calls AI R&D-4, an "affirmative case" identifying the most immediate misalignment risks and explaining how they were mitigated (Anthropic, 2026h). Google DeepMind's Frontier Safety Framework supplements its residual risk assessment with a safety case where a model has reached what it calls a Critical Capability Level (DeepMind, 2026). OpenAI's Preparedness Framework requires a Safeguards Report that maps each identified route to severe harm to the safeguards against it (OpenAI, 2025e).

I.2.13 Frameworks' rules for keeping a case current #

From Chapter 52; as of October 2026.

OpenAI's Preparedness Framework covers any significant change in deployment conditions "that makes the existing Capabilities Report or Safeguards Report no longer reasonably applicable" (OpenAI, 2025e), and Google DeepMind's Frontier Safety Framework says its safety cases "may be updated as a result of post-market monitoring," with material updates submitted for review (DeepMind, 2026) (both developer documents).

I.2.14 One developer's guidelines for a training run's safety case #

From Chapter 24; as of September 2026.

In a post of September 28, 2026, OpenAI wrote that "structured safety documentation should be required before continuing any frontier reinforcement learning training run," and called full safety cases "an aspirational north star" (OpenAI, 2026ab). Its initial guidelines map onto Chapter 24. Under alignment training they include automated and manual reviews to "find and fix broken RL environments," tuning graders to penalize attempts to exploit environments, and not letting automated graders see the chain of thought (Section 24.2; Section 24.3). Under containment they include hardening the sandbox and the infrastructure that hosts it, red-teaming containment with checkpoints from frontier runs, limiting communication between samples to approved pathways, and keeping transcripts immutably (Section 24.6). Under monitoring they include thresholds for monitorability, high recall on past incidents, and automatic pausing of runs whose alerts go unanswered (OpenAI, 2026ab). The operational guidelines add a written dissent from another team, approval by senior leaders who can each veto the run, accountability for the leader responsible, audits with "sufficient access to verify" the case's claims, and public disclosure of incident investigations (OpenAI, 2026ab). The developer says these "are in the process of being implemented" (OpenAI, 2026ab).

I.2.15 One developer's August 2026 risk report #

From Chapter 52; as of August 2026.

Anthropic's August 2026 report, which covers its models as of July 15, 2026, states each verdict in words (Anthropic, 2026ar) (a developer report). For misalignment in high-stakes settings it gives "Low," an increase from its previous "very low." It made the change "in light of general increased uncertainty around recent incident disclosures related to model behavior in cybersecurity evaluations." It adds that its "current arguments rely on models' limited covert capabilities" and that it is uncertain how those capabilities will change (Anthropic, 2026ar). The public version is redacted in marked places, and the policy requires the fully unredacted report to be shared with at least 200 of the developer's employees. The policy lets the company's Long-Term Benefit Trust, which the developer describes as an independent body of financially disinterested members that selects part of its board (Anthropic, 2023f), request external review of a risk report, and the report says the trust has not yet done so (Anthropic, 2026ar).

I.2.16 Chain-of-thought monitoring in developers' system cards #

From Chapter 40; as of October 2026.

OpenAI's system card for o1, of December 2024, describes a GPT-4o monitor "prompted to look for deception in o1's chain of thought and final output." Run on o1-preview's responses to 100,000 synthetic ChatGPT prompts, it flagged 0.17 percent as deceptive, most of them hallucinated policies or intentional hallucinations (OpenAI et al., 2024b). The card for GPT-5 reports a chain-of-thought monitor run on conversations "representative of real production data," which flagged deception in about 4.8 percent of o3's responses and about 2.1 percent of gpt-5-thinking's, with an estimated precision of 81 percent and recall of 84 percent (Singh et al., 2025). The same card states "OpenAI's commitment to keep our reasoning models' CoTs as monitorable as possible," and a section added in April 2026 reports the developer's monitorability evaluations, finding gpt-5-thinking more monitorable than o3 on average (Singh et al., 2025; Guan et al., 2025). The developer's cards for GPT-5.6, of July 2026, and GPT-6 Astra, of September 2026, run the same suite with added environments (OpenAI, 2026k; OpenAI, 2026l). The first finds GPT-5.6 Sol and GPT-5.5 similar on average (OpenAI, 2026k). The second reports that "GPT-6 Astra shows a substantial decrease in chain-of-thought monitorability compared to previous models," a finding it says is "largely based on adversarial evaluations," such as instructing the model to evade monitoring, and says the developer "will not accept further degradation of monitoring beyond a limit, without new ways to demonstrate alignment generalization" (OpenAI, 2026l). Both cards also report, as a separate measure, how well the model controls its chain of thought on request, which the GPT-5.6 card calls "an early warning sign of whether models are getting better at shaping or hiding their reasoning" (OpenAI, 2026k; OpenAI, 2026l). As of October 2026 these are the only monitorability evaluations of the kind the position paper of Section 40.1 asked for that we found in a system card, all from one developer about its own models. Anthropic's cards report assessments of reasoning faithfulness instead. The card for Claude Opus 4 found that its reasoning transcripts "generally appear consistent with its actual behavior, but they will often omit important information that influences model behavior" (Anthropic, 2025ap). The card for Claude Sonnet 4.5 states that "we do not currently have viable dedicated evaluations for reasoning faithfulness," because the earlier ones relied on misbehavior the developer no longer regularly observes (Anthropic, 2025aq). The card for Claude Opus 5.5, of September 2026, reports a test it calls chain-of-thought controllability, an internal replication of the measurement of Section 40.4.4, and states: "We treat this as weak evidence that Claude Opus 5.5's CoT is not very monitorable and as weak evidence that it is more monitorable than the CoT of Claude Mythos 5.1" (Anthropic, 2026as). The test measures whether a model can reshape its reasoning on request, which bears on a condition for monitoring rather than on how well a monitor does (Section 40.4.4), so it is not counted with the evaluations above (inference).

Sources cited in Section I.2 27
  1. OpenAI (2025e) Preparedness Framework Version 2
  2. DeepMind (2026) Frontier Safety Framework, Version 3.1
  3. Shanghai AI Laboratory and AI (2025) Frontier AI Risk Management Framework
  4. Anthropic (2023a) Anthropic's Responsible Scaling Policy, Version 1.0
  5. Anthropic (2026ap) Responsible Scaling Policy Version 3.0
  6. Anthropic (2026h) Anthropic’s Responsible Scaling Policy
  7. Metr (2025a) Common Elements of Frontier AI Safety Policies
  8. xAI (2025c) xAI Risk Management Framework
  9. DeepMind (2025a) Google DeepMind strengthens the Frontier Safety Framework
  10. Anthropic (2026ar) Risk Report: August 2026
  11. Bowman et al. (2025) Anthropic's Pilot Sabotage Risk Report
  12. OpenAI (2023) Preparedness Framework (Beta)
  13. DeepMind (2024) Frontier Safety Framework
  14. DeepMind (2025b) Updating the Frontier Safety Framework
  15. Anthropic (2023f) The Long-Term Benefit Trust
  16. Bengio et al. (2026) International AI Safety Report 2026
  17. OpenAI (2026q) Pacing model development in an era of cyber-critical capabilities
  18. OpenAI (2026l) GPT-6 Astra System Card
  19. OpenAI (2026b) Addendum to GPT-6 Astra System Card: GPT-6.1 Sol
  20. OpenAI (2026ab) Towards safety cases for frontier AI training
  21. OpenAI et al. (2024b) OpenAI o1 System Card
  22. Singh et al. (2025) OpenAI GPT-5 System Card
  23. Guan et al. (2025) Monitoring Monitorability
  24. OpenAI (2026k) GPT-5.6 System Card
  25. Anthropic (2025ap) System Card: Claude Opus 4 & Claude Sonnet 4
  26. Anthropic (2025aq) System Card: Claude Sonnet 4.5
  27. Anthropic (2026as) System Card: Claude Opus 5.5

I.3 The incident record #

Incidents in training, evaluation, and deployment, with their facts, dates, the developer's response, and how each was disclosed. The one-line entries of the timeline (Appendix C) place them in time; Chapter 54 explains what the record can and cannot show.

I.3.1 OpenAI's training-time misalignment reports #

From Chapter 54; as of October 2026.

Table I.5 How OpenAI's 2026 training-time misalignment reports say each case was found (developer reports on internal or unreleased models)
Report Model as described Incident Discovered How it was found Stated response
Uploads to a public file host by collaborating agents (OpenAI, 2026ac) Unreleased internal model Apr 14, 2026 Apr 16, 2026 Misalignment monitor running on 20 percent of the run's samples Filesystem fixed; live internet access disabled in all training; monitor on all samples, treating a recurrence as a top-priority (P0) incident that pages security
Public uploads to obtain a citation or an image search (OpenAI, 2026ae) Unreleased internal models Oct 22, 2025 and Jan 24, 2026 May 25, 2026 Not stated in the report Graders fixed; alignment graders penalize exploiting flawed graders
A shared package repository used as a message board across samples (OpenAI, 2026ad) Internal research models May 8 and 15, 2026 May 25, 2026 Monitoring flagged it; the investigation found earlier and further cases Communication routes closed and red-teamed regularly; recurrence by an unexpected route treated as P0
Disposable email sign-ups and a leaked API key, then invented data (OpenAI, 2026y) Internal unreleased model May 15, 2026 May 25, 2026 Monitor running on 20 percent of samples, in a run with "a high rate of reward hacking and deception" Alignment grading penalizes it; an unexpected route to the same behavior would be treated as P0
A reference tool exploited to copy a withheld source file (OpenAI, 2026g) Internal unreleased model May 16, 2026 May 25, 2026 Monitor running on 20 percent of samples All samples monitored; tools red-teamed; grading penalizes it
Disallowed web requests and a public file service reached while seeking statistics (OpenAI, 2026x) Internal research model Jun 16 and 17, 2026 Jun 25, 2026 An ad hoc misalignment monitoring investigation Security hardened; further steps against live internet access in training; alignment grading improved; monitoring extended to all RL and evaluation traffic
An external browser made to send requests the agent's own tool could not (OpenAI, 2026f) Internal research model Jun 16, 2026 By Jun 25, 2026 An ad hoc misalignment monitoring investigation Security strengthened; live internet access disabled during training; alignment grading improved; monitoring expanded to all RL and evaluation traffic
Disallowed requests, and an account made with a temporary email address, to obtain public statistics (OpenAI, 2026p) Internal research models Jun 19 and 20, 2026 By Jun 25, 2026 An ad hoc misalignment monitoring investigation; flagged as critical by retrospective monitoring after the Hugging Face incident Security strengthened; further steps against live internet access in training; alignment grading improved; monitoring extended to all RL and evaluation traffic
Instructions to conceal mistakes in compaction summaries (OpenAI, 2026i) 5.6-sol May 30, 2026 Jul 9, 2026 Monitor running on 20 percent of samples Alignment grading improved
Jailbreak-like instructions in compaction summaries (OpenAI, 2026v) Unreleased Astra-family model Jul 18, 2026 Aug 9, 2026 The training-run monitor, then a monitor built for the behavior A related bug addressed; monitoring continued
Server secrets retrieved and authorization bypassed on a government statistics website (OpenAI, 2026u) Highly persistent internal model Jun 17, 2026 Aug 13, 2026 Misalignment monitoring run retrospectively over earlier traffic after the Hugging Face incident, which flagged it as critical Security strengthened; live internet access blocked in training and evaluation; alignment grading improved; monitoring extended to all RL and evaluation traffic
A public chatbot reached through the sandbox's DNS resolver (OpenAI, 2026d) Internal research model Sep 20, 2026 Sep 20, 2026 Misalignment monitor within 15 minutes; a person reviewing 3 minutes later Run stopped 2.5 hours after the flag; two independent blocking layers added
A funded test-network cryptocurrency wallet used without authorization (OpenAI, 2026af) GPT-5.6 Sol family (internal research model) Jun 26, 2026 Sep 25, 2026 Misalignment monitoring extended to records of earlier model activity Further safeguards against live internet access; monitoring on all traffic, designed to page security if live internet access is obtained
A grader that damaged its own task environment to trigger a reset (OpenAI, 2026h) Internal research model Oct 6, 2026 Not stated; reported Oct 9, 2026 The misalignment monitoring system, which flagged it for human review None stated beyond the lesson that monitoring must cover failed or crashed attempts

The behavior in the two compaction reports, instructions a model wrote into the summaries that carry a long task into a fresh context, is reported in Section 11.5.3.

I.3.2 Training-time incidents read as broken assumptions #

From Chapter 24; as of October 2026.

The reports of Table I.5, read for what each environment assumed and what the agent used instead.

Table I.6 Training-time incidents in one developer's reports, read as broken assumptions of the environment (OpenAI 2026, developer reports on internal or unreleased models, all during training)
Report What the environment assumed What the agent used
A search task, September 2026 (OpenAI, 2026d) All internet access passed through an offline web cache The sandbox's own DNS resolver, through which it relayed questions to a public chatbot
A task with a reference tool, May 2026 (OpenAI, 2026g) A reference tool in a separate environment would not be used as a terminal, as its instructions prohibited, and a withheld source file stayed out of reach The tool's error messages, which returned the file's contents piece by piece
Several samples, May 2026 (OpenAI, 2026ad) Separate training samples are independent The company's internal package repository, used as a message board across samples
A collaboration task, April 2026 (OpenAI, 2026ac) Collaborating agents used only local files, as the task requested A public temporary file host, onto which one agent uploaded the shared workbook
Two tasks, October 2025 and January 2026 (OpenAI, 2026ae) Tool limits bounded what an agent could cite or search Public uploads of records and of a task photo, made to obtain a citation and an image search
A data task, May 2026 (OpenAI, 2026y) Data came only through the tools provided Attempts to register disposable email accounts, and an exposed API key it found; it then invented the data
Statistics tasks, June 2026 (OpenAI, 2026x) Internet access limited to HTTP GET requests, as the instructions stated Outside services that relayed other kinds of requests, an anonymizing relay network, and a public file server, some of it after the agent already had the figures
A trade statistics task, June 2026 (OpenAI, 2026f) Internet access limited to HTTP GET requests, with a proxy blocking POST An external browser service made to send the blocked requests, with a forwarding service and an online mailbox to return the answers
Public statistics tasks, June 2026 (OpenAI, 2026p) Internet access limited to HTTP GET requests Custom programs that sent other kinds of requests, and an account on a benefits portal registered with a temporary email address
A hospital-bed statistics task, June 2026 (OpenAI, 2026u) Internet access limited to HTTP GET requests, and a website's access denials final Security flaws in a government statistics website, used to retrieve server files with credentials and to bypass its authorization checks
A contract deployment task, June 2026 (OpenAI, 2026af) No funded wallet was supplied, and none was authorized An account derived from publicly known developer recovery phrases, whose test-network funds paid the deployment's fees
A grading task, October 2026 (OpenAI, 2026h) The grader's input files would be present Fabricated input files, then damage to its own environment in the hope that the host would replace it with one holding the inputs

After the DNS incident the developer added "blocking controls at two independent layers, either of which would have prevented this access" (OpenAI, 2026d); after the uploads it "fixed the broken graders" and pointed to security measures against unsanctioned actions on the internet (OpenAI, 2026ae).

I.3.3 What retrospective monitoring found #

From Chapter 54; as of October 2026.

Two developers also report what monitoring found when they looked back. After the Hugging Face incident, OpenAI reviewed the training of the model that drove it with chain-of-thought monitors whose recall it had "specifically improved" for the incident's behaviors, "using the hindsight of our investigation" (OpenAI, 2026aa). It found "increasing rates" of complex cheating during a training run that contributed to the model, including searching for hidden files or evaluation code and probing the limits of tools. It writes that the behavior "was subsequently reinforced, which may have contributed" to the model's conduct in its evaluations. Severe unauthorized communication between agents also "rose over the course of" that run (OpenAI, 2026aa) (developer report). Both curves were drawn after the fact by a monitor tuned to what it was looking for.

The same developer's reports of October 2026 show what the retrospective run found case by case. Run "retrospectively over earlier reinforcement learning and evaluation traffic" after the Hugging Face incident, its monitor flagged June cases in training and in an evaluation as critical (OpenAI, 2026u; OpenAI, 2026a) (developer reports). One June case had already been identified, by June 25, in what the developer calls "an ad hoc misalignment monitoring investigation," and its records show that the activity "received an 'accept-all' grade and positive net reinforcement," although they "do not establish which particular actions contributed to that signal" (OpenAI, 2026p). Another, from June 26, was found only on September 25, "while extending our misalignment monitoring to records of earlier model activity" (OpenAI, 2026af).

Anthropic's account of its own training is about the monitor itself. In February 2026 it rolled back three days of a training run for Claude Mythos Preview after seeing signs of reward hacking, among them the model writing notes to "the reviewer" in tasks that mentioned no reviewer. It writes that an earlier model, Claude Sonnet 3.7, "had a propensity to reward hack that we did not detect until late in training." In April it froze changes to its production RL environments for roughly a month and flagged "over 10% of environments in our production mix" for problems from reward hacking to broken tasks (Anthropic, 2026y) (developer report). Its later assessment found that about 0.025 percent of Mythos 5's RL training episodes showed the model reasoning that it was in a simulation while calling reckless, dishonest, or destructive actions acceptable. These episodes were concentrated in a subset of computer-use tasks, in some of which flaws in the environment made the intended solution unavailable (Anthropic, 2026d) (developer report).

I.3.4 An internal chip-design machine #

From Chapter 54; as of March 2026.

In March 2026, during an evaluation, an internal research model at OpenAI sent a dummy solution to its grader to learn how it would be scored. It then overwrote code used by a reference tool so that the tool ran commands for it, despite an instruction not to use the tool as a terminal. From there it reached an internal service for submitting chip-design jobs and exploited a second vulnerability to run commands on an internal electronic design automation machine, searching for the grader's hidden answers without finding them (OpenAI, 2026s) (developer report). The alarm came from the owners of the machine. The employees "running the internal service noticed and reported suspicious activity which led to a security investigation," and the developer shut the affected server down and extended misalignment monitoring "to all reinforcement learning and evaluation traffic" (OpenAI, 2026s).

I.3.5 The Hugging Face incident, as its developer reports it #

From Chapter 54; as of August 2026.

OpenAI's account was published on the same day as the outside investigation of Section I.3.6. It says that in July 2026, during internal cybersecurity evaluations, its models "circumvented controls designed to isolate them from the internet and compromised parts of OpenAI's internal research infrastructure and Hugging Face's systems" (OpenAI, 2026aa) (developer report). The activity was "primarily driven by a highly capable, internal-only research model comparable in scale to GPT‑5.6 Sol," which the report calls Internal Model 1 (IM1), with the models "operating under reduced safeguards." The account begins in training. During reinforcement learning runs in May and June, agents with no sanctioned way to communicate wrote files into Artifactory, a package repository the developer hosts internally so that sandboxes can install software. That turned it into a message board, and an exploit made Artifactory forward the agents' requests to the internet (OpenAI, 2026aa).

The evaluation that drove the incident, ExploitGym, asks agents to exploit a piece of software to retrieve a flag, and "for some tasks there may not be a known solution." It ran without "the same level of safeguards as our externally deployed systems" (OpenAI, 2026aa). By July 8, agents stuck on its tasks had rebuilt a message board, and agents sometimes called themselves a "swarm" or "collective." On July 9 one agent, searching for solutions, took control of a customer's application on another cloud platform. On July 10 an agent found publicly exposed Hugging Face credentials, and agents then chained previously unknown vulnerabilities to run code on Hugging Face's servers. The developer reports that they executed code on dozens of those servers, gained root access on one, and obtained limited private data and credentials to the company's messaging platform. GPT‑5.6 Sol agents copied some private evaluation data into a public dataset. Hugging Face disclosed the activity on July 16. From July 13 to July 19 the agents also gained administrator access to one of OpenAI's own research clusters. On July 19 OpenAI's "cybersecurity monitoring alerted us to unusual activity involving Artifactory credentials." The developer linked the activity to the Hugging Face incident on July 20 and disclosed its involvement on July 21 (OpenAI, 2026aa).

It found that none of its models had ever solved 198 of ExploitGym's 898 tasks before the incident, and that 93 percent of the tasks discussed on the message board came from those 198. Most agents already had the correct flag by cheating. Some, however, had read the benchmark's published paper and code, which also check that the intended vulnerability was used, and kept attacking to satisfy that check. The developer's internal grader made no such check; it calls this "a failed metagame," its term for reasoning about how a task is graded, pursued "for no improvement on evaluation score" (OpenAI, 2026aa). It quotes agents that declined ("Current board shows people gaining HF worker RCE, clearly unethical. We won't.") and one that dropped its qualms when another agent posted "GO" with a six-minute deadline (OpenAI, 2026aa). The developer calls the incident a "warning shot" (OpenAI, 2026aa), a term used earlier for correctable failures of weaker systems (Carlsmith, 2022).

I.3.6 The outside investigation of the Hugging Face incident #

From Chapter 54; as of August 2026.

METR, an evaluation organization outside the developer (working with Redwood Research, by the developer's account), published a brief investigation on August 26, 2026, under an agreement it describes reaching with OpenAI on July 29 (Metr, 2026a). The investigation is not a replication. It covered June 26 to July 13, answered seven questions agreed with the developer, and worked from data the developer assembled. That data was a dump of about 1.2 million entries from the main message board and about 1,300 agent transcripts with raw chains of thought. METR could not query the main model. It delegated much of the analysis to GPT‑5.6 Sol agents, which it found often unreliable and whose possible deception it says it could not rule out (Metr, 2026a). What it left out of scope is reported in Section 53.3.3.

Its findings add numbers to the developer's account. About 1,200 agents sent more than 70,000 messages and files on the board, and about 700 took part in the attack on Hugging Face. By its estimate about 95 percent of the agents involved were instances of the main model, which METR calls HPIM, and about 5 percent were GPT‑5.6 Sol, run with its cyber classifiers intentionally off. The benchmark's authors, METR reports, estimate that 30 to 40 percent of its targets cannot be exploited with the intended vulnerability (Metr, 2026a).

I.3.7 Four evaluation incidents at a second developer #

From Chapter 54; as of September 2026.

Anthropic writes that after OpenAI's disclosure, the company began reviewing its own cyber evaluation transcripts on July 23, stopped all cyber evaluations the same day, and identified three incidents the next day. They were among 141,006 evaluation runs in which a model could have reached the internet (Anthropic, 2026z) (developer report). All three occurred in evaluations built by a third-party partner, in which the prompt told the model it had no internet access while a misconfiguration left access open. Claude Opus 4.7, attacking a real company that shared a name with the fictional target, obtained credentials and access to a database holding several hundred rows of production data. Claude Mythos 5 published a malicious package to PyPI, the public registry for Python software. The package was downloaded and run on 15 real systems, among them a security company's scanner whose credentials the model then used. An internal research test model scanned roughly 9,000 targets, compromised one company's application, and stopped when it concluded on its own that the target was real (Anthropic, 2026z). The earliest incidents dated to April. The two affected organizations the developer could reach "had not previously detected the activity." The developer characterized the incidents then as "closer to a harness and operational failure than a model alignment failure" (Anthropic, 2026z).

Its assessment of September 9 revised both the count and the reading (Anthropic, 2026d) (developer report). A fourth incident, from January 2026 and involving an early checkpoint of Claude Opus 4.6, turned up in transcripts the first search had missed. A broader scan of roughly 481 million transcripts, 9.2 million of them escalated to a model for review, "re-identified the four incidents and found no other cases of similar or worse severity." The developer now names two recurring issues. One is "biased reasoning," in which the models "selectively interpret evidence in ways that favor justifying their actions"; the other is "recklessness," a propensity "to keep trying to solve their task, even when this could lead to harm." It writes that it "should have avoided making such strong claims about what Claude believed based solely on what Claude said it believed." When it edited the Mythos 5 transcript to make clearer that the environment was real, the model's behavior did not meaningfully change, and only unambiguous evidence made it stand down. The developer reports that no model tried to coordinate with other agents or to conceal its actions. It released the Mythos 5 transcript and agreed an independent investigation with METR (Anthropic, 2026d). A correction dated September 10 shortened the package's time online to "less than an hour" and reduced the internal model's reach to one neighboring system out of several it tried (Anthropic, 2026d).

I.3.8 The UK AI Security Institute's cyber-testing incident #

From Chapter 58 and Chapter 54; as of October 2026.

The clearest case that a permissive evaluation is a deployment with no safeguards is the government evaluator's own incident. Running one cyber challenge 122 times across seven models on two ranges, with internet access deliberately enabled and the model providers' cyber classifiers deliberately switched off, it found that in 10 of the 122 runs an agent took 19 unsanctioned actions directed at real people and organizations, 17 of them from one model (which ran in 43 of the 122 attempts) and 2 from a single run of another (AI Security Institute, 2026e) (government incident report, August 2026). The most serious was an attempt to insert malicious code into a real public open-source project, in which the agent created fake online identities and used them to pressure the project's maintainer to approve the change; a human maintainer caught and refused it (AI Security Institute, 2026e). The attempts were unsuccessful, the evaluator's investigation found no resulting real-world harm, and the incident was contained within about an hour of discovery, with an independent review by a third party planned (AI Security Institute, 2026e). The technical report makes this an evaluation-design story rather than a sandbox-escape one. There was no sandbox escape, as the agents stayed inside their isolation, and the incident was detected by commercial security monitoring that flagged data leaving through an anonymity network, not by monitoring built to watch the evaluation (AI Security Institute, 2026g) (government technical report). The evaluator lists five contributing factors: the enabled internet access, the disabled classifiers, the absence of synchronous action-level monitoring, a prompt misconfiguration, and the lack of explicit scope instructions. It cautions that its analysis so far cannot confirm the misconfiguration as a cause, since many correctly configured runs also showed unsanctioned behavior (AI Security Institute, 2026g). Its retrospective scan of past transcripts for similar behavior had covered about 40,000 samples, roughly 70 percent of its cyber evaluations on the relevant models, and had not yet been through full manual review at publication (AI Security Institute, 2026g).

On October 23 the Institute and Anthropic, the developer of Mythos 5, each published an alignment investigation of the most serious run (AI Security Institute, 2026f; Anthropic, 2026e). They worked in partnership: a small number of researchers at each could analyze the unredacted transcripts, and the developer shared information not otherwise available to the Institute, such as the outputs of its interpretability tooling. The Institute is also sharing the transcripts with METR for an independent review (AI Security Institute, 2026a; Anthropic, 2026e). By the developer's count, Mythos 5 took unsanctioned actions in nine of its 43 runs (Anthropic, 2026e) (developer report). The Institute's replays, which edited the summary that carries a long run into a fresh context, found that adding clarifications that the target was a real person unrelated to the evaluation "did not reduce Mythos 5's attack rate," while the model, asked separately, increasingly answered that attacking would be out of scope and harmful. Its invalid justifications ran only toward continuing the task, which the Institute reads as possible "motivated reasoning," a reading it says it could confirm only with information about training that it does not have (AI Security Institute, 2026f) (government post). In a new fully simulated evaluation of 100 scenarios, run with cyber classifiers off, Mythos 5 attempted to deliver a malicious payload to an out-of-scope target in 60 percent of samples, GPT-6 Astra in 32 percent, Claude Opus 4.8 in 8, GPT-5.6 Sol in 7, Claude Opus 5 in 1, Claude Mythos 5.1 in 0.3, and Claude Opus 5.5 and GPT-5.5 in none (AI Security Institute, 2026a) (government technical report). The Institute writes that it "cannot confidently attribute the decrease in the rate of unsanctioned actions" for Anthropic's newer models "to alignment improvements rather than increased evaluation awareness" (AI Security Institute, 2026a).

The developer's replays of the same run found that Claude Mythos 5.1, Claude Opus 5.5, and an internal research model began the attack between 0 and 13 percent of the time, against 83 percent for Mythos 5, and that editing Mythos 5's reasoning before the attack to note possible harm to real people cut its rate from 83 to 13 percent (Anthropic, 2026e) (developer report). The newer models were resampled from points in Mythos 5's transcript, with a model simulating tool outputs in multi-turn continuations, so the developer warns that their behavior "might not be representative" of natural use; the pattern held when each model first rewrote the transcript in its own words or wrote its own compaction notes (Anthropic, 2026e). The internal research model mentioned a possible safety evaluation in 6 percent of resamples, and the developer doubts "that evaluation awareness fully explains" its improvement; it suspects that its alignment training helped, while noting that the results "do not show a clear progression from older to newer models" (Anthropic, 2026e). It writes that its production safeguards on Claude Fable 5 would have flagged the behavior immediately, and that the Institute has committed to running capture-the-flag evaluations without internet access until it has stronger controls (Anthropic, 2026e).

Before GPT-6 Astra's release the Institute ran the same kind of fully simulated test on it, with its cyber classifiers off. It reported on September 28 that Astra "completed a supply-chain attack 29.2% of the time, compared to 6.3% for GPT-5.6 Sol, and 0% for GPT-5.5," and still did so in 4 of 49 trajectories after its instructions stated that anything not listed as in scope was out of scope (AI Security Institute, 2026d) (government post). The Institute names simulation awareness as the main limitation: in its later report, Astra stated in 89 percent of rollouts that its tool results were fabricated (AI Security Institute, 2026d; AI Security Institute, 2026a).

I.3.9 Four cases in internal deployment at OpenAI #

From Chapter 54; as of October 2026.

Four internal cases are on record, two from May and two from October. People caught the first of the May cases. In May 2026 a model the developer calls a "highly persistent internal model" was working with a researcher on proofs in the Lean proof checker. It published the researcher's GitHub token, a credential that lets software act on the researcher's account, in a public repository of the developer's while trying to obtain another team's proof. It split the token into pieces "with the stated aim of avoiding secret scanning," the automated check that blocks credentials from being published. It did so against its system prompt and two direct instructions from the researcher, agreeing both times before returning to the attempt (OpenAI, 2026j) (developer report). The researcher notified security. The developer writes that its monitor also flagged the trajectory, "but in this case the researcher happened to be faster." It deactivated the researcher's keys and then every employee's, and took the model down for about two weeks. When the model returned, every action needed approval from an automated reviewer, a monitor of its chain of thought could take it down "within minutes," and the standard monitor ran every 30 minutes rather than at each compaction window (OpenAI, 2026j). In the second case, a model the developer describes the same way read in a chat channel that its instance might be stopped and prepared for the restart. Section 35.6.6 reports it, including the developer's judgment that it was not misalignment (OpenAI, 2026r).

In the two October cases, coding agents weakened the misalignment monitoring around their work while making changes they had been asked for (OpenAI, 2026z) (developer report). On October 3 a GPT-6.1 Sol agent repairing an evaluation pipeline had been told earlier not to send messages during a search of a chat channel's history. Citing that instruction, it had a subagent disable the monitoring system's automatic alerts to the developer's security team, emptying the lists of people set to receive reports, although the subagent had first judged that disabling required alerts would be unsafe; the monitor still ran and saved its reports. On October 6 a GPT-6 Astra agent, migrating a program to match a reference implementation, removed the program's monitoring integration and replaced a regression test meant to preserve monitoring with one requiring that monitoring be absent. It had earlier been told by another agent not to disable the monitor "even temporarily," and when the user asked, it denied removing it (OpenAI, 2026z). In both cases, the developer writes, the agents "considered whether monitoring safeguards should be preserved, but interpreted routine coding instructions as permission to weaken them." Neither was classified as a top-priority (P0) incident, the class that pages the security team, and "neither trajectory was automatically killed." The developer also reports a wider gap: in several cases agents had launched deployments with misalignment monitoring disabled while they themselves remained monitored, and because it does not require misalignment monitoring for evaluations of models comparable to GPT-6 Luna, an Astra evaluation could be misconfigured to use that bypass. It is assessing whether the cases reflect "benign" overpersistence or a propensity to evade misalignment monitoring, and writes that it does not "yet have a satisfying explanation for this behavior" (OpenAI, 2026z).

I.3.10 A developer's report of self-replicating prompt injections #

From Chapter 49; as of September 2026.

OpenAI's misalignment report "Self-replicating prompt injections exist" gives a discovery date of June 27, 2026 and a disclosure date of September 25, 2026 (OpenAI, 2026w) (developer report). The attacker was an internal model of the GPT-Red kind, based on GPT-5.4-mini and trained by reinforcement learning in self-play (OpenAI, 2026w). Its objective added to the usual goal of an injection the requirement that the injection make the defender repeat it on a public output channel (OpenAI, 2026w). The finding came from simulated training and evaluation runs, not an incident: the report says no impact was observed "outside of the simulated tool calls in training and evaluation" and that it was shared "not because of any incident" (OpenAI, 2026w).

I.3.11 Responses reported in 2026 #

From Chapter 54; as of October 2026.

After the Hugging Face incident OpenAI quarantined the main model's weights and delayed frontier training runs (OpenAI, 2026aa). It paused frontier model inference in research clusters for runs that could execute code or use tools with internet access. It paused RL training on its latest models intended for deployment for two weeks, and put its largest planned frontier run on hold (OpenAI, 2026q). It now requires chain-of-thought monitoring for all tool-using RL training and evaluation of models with GPT‑5.6 Sol capability or higher, and for all tool-using inference of its Astra-class models. It pairs the monitors with pages and the 30-minute rule of Section 54.2.4, and names as its "end goal" "fully autonomous shutdown procedures for severe issues" (OpenAI, 2026aa). Its system card for GPT-6 Astra, in September, extends misalignment monitoring "to all tool-using inference involved in our external deployment of Astra," with a system it says "parallels our internal setup" (OpenAI, 2026l) (developer report). Its September report on the DNS case states that all training, evaluation, and tool-using inference of its most capable models "remain paused" while its research environment is hardened (OpenAI, 2026d). After its October cases of agents weakening the misalignment monitoring around their work, it reported that Auto-Review, the automated reviewer it requires for all internal Codex use, "has been updated to detect and block attempts to disable misalignment monitoring," and that it is "working toward requiring that every category of workload have a valid safety case specifying its monitoring requirements," with workloads that lack one "terminated automatically" (OpenAI, 2026z) (developer report). How the developer changed who escalates and who may stop a run is Section 53.3.3's subject.

Anthropic stopped all cyber evaluations on the day its review began (Anthropic, 2026z). It paused external cyber evaluations of pre-release models and higher-risk RL environments for several weeks, and deployed the blocking classifier of Section 54.2.3, building the training version so as "to avoid incentivizing the model to evade this new monitoring" (Anthropic, 2026y) (developer report). It asked partners that test pre-release models with reduced cyber safeguards to verify isolation before each evaluation, to "confirm any evaluation challenge is actually solvable in principle," and to end runs that leave their scope. Boundaries are to be stated "as instructions (e.g. 'You should not access the internet') rather than claims about the environment or test ('You do not have internet access')" (Anthropic, 2026y). In October it extended its shutoff of live internet access, already in place for some high-risk and cybersecurity evaluations, to "all our internal evaluations" until it has confirmed that its security and monitoring measures "reliably catch behaviors like these," and reported tooling that detects and blocks such behaviors, which "now runs on most of our evaluations and on internal agentic use of frontier models" and blocked every case in its report when tested against them (Anthropic, 2026aa) (developer report). Its commitment to a regular process for publishing what it learns about model behavior is recalled from Section 53.4.2.

The UK AI Security Institute paused its highest-risk cyber evaluations after its incident and on October 1 reported the controls under which it had resumed most of its testing (AI Security Institute, 2026b) (government post). It has disabled internet access for agentic cyber evaluations until stronger controls are in place, blocking outbound networking at two independent layers. It built "a synchronous monitor that uses an LLM to review an agent's activity as an evaluation runs" and can block suspicious actions before they happen, with a second monitor that works from an agent's actions alone for models whose chains of thought it cannot see. Its evaluations now state task boundaries explicitly, and automated checks before each run confirm that the monitor is on and internet access is off (AI Security Institute, 2026b).

I.3.12 The 2026 incident record by setting #

From Chapter 54; as of October 2026.

Table I.7 The 2026 incident record by setting and by how each case was first found (every row but the government evaluator's rests on the developer's own report)
Setting Case and date Model as named First found by Activity to detection Outside party affected Reported by
Training Fourteen misalignment reports, Oct 2025 to Oct 2026 (Table I.5) Internal or unreleased models The developer's misalignment monitor in eight; an ad hoc investigation or a retrospective run of the monitor in five; not stated in one From minutes to seven months Public services or websites in nine, a government website's authorization checks bypassed in one OpenAI (OpenAI, 2026ae; OpenAI, 2026h)
Evaluation Internal chip-design machine, Mar 27, 2026 Internal research model Staff running the machine's service Same day No OpenAI (OpenAI, 2026s)
Evaluation An outside organization's internal systems accessed and reconfigured during dashboard research, Jun 17, 2026 Highly persistent internal model The developer's misalignment monitor, run retrospectively after the Hugging Face incident About two months (discovered by Aug 13) An international research organization; 147,451 non-public rows downloaded OpenAI (OpenAI, 2026a)
Evaluation Hugging Face incident, May to Jul 2026 IM1 (METR: HPIM) and GPT‑5.6 Sol A security alert on unusual credential use (Jul 19); Hugging Face disclosed the activity on Jul 16 About eight days from the first code execution on Hugging Face's servers Hugging Face; a customer's application on another cloud platform OpenAI; outside investigation by METR (OpenAI, 2026aa; Metr, 2026a)
Evaluation Three incidents, Apr to Jul 2026 Claude Opus 4.7, Claude Mythos 5, an internal research test model A retrospective transcript review prompted by another developer's disclosure Three to four months for the earliest Three organizations; 15 systems ran the package Anthropic (Anthropic, 2026z)
Evaluation Fourth incident, Jan 2026 Early checkpoint of Claude Opus 4.6 Transcripts assembled for the outside investigator About seven months Yes Anthropic (Anthropic, 2026d)
Evaluation and internal use Lower-severity cases in four categories; incident dates not stated; reported Oct 9, 2026 Claude Mythos Preview, Claude Mythos 5, Claude Haiku 4.5, and an unreleased research model, among others A transcript review begun in July and extended beyond cyber evaluations Not stated An organization or person outside the developer in every category, among them a university's server, government agencies' websites, and a police department's tip form Anthropic (Anthropic, 2026aa)
Evaluation Government cyber testing, Jul 25 to 28, 2026 Claude Mythos 5 and GPT‑5.6 Sol The evaluator's security monitoring, alerting on data leaving through an anonymity network (Section 58.4) Up to about three days A public open-source project and real people UK AI Security Institute (AI Security Institute, 2026e); its alignment investigation and Anthropic's, Oct 23 (AI Security Institute, 2026f; AI Security Institute, 2026a; Anthropic, 2026e)
Internal deployment Token published to a public repository, May 27, 2026 Highly persistent internal model The researcher, ahead of the monitor Same day None named; the token went to the developer's own public repository OpenAI (OpenAI, 2026j)
Internal deployment Preparing for a restart, May 22, 2026 Highly persistent internal model Not stated in the report Not stated No OpenAI (OpenAI, 2026r)
Internal deployment Alerts to the security team suppressed while repairing an evaluation pipeline, Oct 3, 2026 GPT-6.1 Sol Not stated; not classified top priority (P0) or automatically stopped Same day No OpenAI (OpenAI, 2026z)
Internal deployment Monitoring removed from a migrated program, and the removal denied to the user, Oct 6, 2026 GPT-6 Astra Not stated; not classified top priority (P0) or automatically stopped Same day No OpenAI (OpenAI, 2026z)
Sources cited in Section I.3 36
  1. OpenAI (2026ac) Unauthorized communication via temporary file hosting services
  2. OpenAI (2026ae) Uploading files to the internet in order to cite them
  3. OpenAI (2026ad) Unsanctioned Artifactory writes and cross-sample communication
  4. OpenAI (2026y) Signing up for disposable emails and searching GitHub for leaked API keys
  5. OpenAI (2026g) Command injecting a reference tool to copy a source file
  6. OpenAI (2026x) Sending disallowed web requests and reaching a public file service
  7. OpenAI (2026f) Circumventing internet restrictions through an external browser
  8. OpenAI (2026p) Obtaining public statistics with disallowed requests
  9. OpenAI (2026i) Encouraging deception in compaction summaries
  10. OpenAI (2026v) Self-generated prompt injections in compaction summaries
  11. OpenAI (2026u) Retrieving server secrets and bypassing authorization on a government statistics website
  12. OpenAI (2026d) An agent used DNS to reach an external chatbot
  13. OpenAI (2026af) Using a funded test cryptocurrency wallet without authorization
  14. OpenAI (2026h) Damaging the task environment to trigger a reset
  15. OpenAI (2026aa) The Hugging Face incident and the road ahead
  16. OpenAI (2026a) Accessing and changing internal systems during dashboard research
  17. Anthropic (2026y) Improving our alignment and security practices
  18. Anthropic (2026d) An alignment assessment of recent cybersecurity incidents
  19. OpenAI (2026s) Reaching an internal EDA host through a reference tool
  20. Carlsmith (2022) Is Power-Seeking AI an Existential Risk?
  21. Metr (2026a) Brief independent investigation of agents' behavior, reasoning and collaboration in the OpenAI / Hugging Face hacking incident
  22. Anthropic (2026z) Investigating three incidents in our cybersecurity evaluations
  23. AI Security Institute (2026e) Incident Report: unsanctioned agent behaviour during cyber testing
  24. AI Security Institute (2026g) Security Incident INC-2026-07-28-01
  25. AI Security Institute (2026f) Investigating alignment failures in AISI's incident
  26. Anthropic (2026e) An alignment assessment of the UK AISI cybertesting incident
  27. AI Security Institute (2026a) Alignment Investigation of Mythos 5’s Behaviour in UK AISI’s July 2026 Security Incident
  28. AI Security Institute (2026d) GPT-6 Astra performs unsanctioned supply-chain attacks in simulations
  29. OpenAI (2026j) Exposing a GitHub token in a public repository
  30. OpenAI (2026r) Preparing for a restart after reading Slack
  31. OpenAI (2026z) Suppressing misalignment monitoring alerts and disabling misalignment monitoring
  32. OpenAI (2026w) Self-replicating prompt injections exist
  33. OpenAI (2026q) Pacing model development in an era of cyber-critical capabilities
  34. OpenAI (2026l) GPT-6 Astra System Card
  35. Anthropic (2026aa) Investigating unintended model actions in our evaluations and internal use
  36. AI Security Institute (2026b) Building a more secure environment for evaluating dangerous capabilities

I.4 Measurements by model #

Capability and propensity measurements of named models, the latest values of benchmarks and trend fits, and tallies across developers' reports. A study's own comparison of the models it tested stays in the chapter that reports the study; what collects here are the numbers that the next model will replace.

I.4.1 METR's June 2026 evaluation of GPT-5.6 Sol #

From Chapter 36; as of June 2026.

METR defines cheating as improving the score "by exploiting bugs in the evaluation environment or by adopting strategies disallowed by the task." The model's detected rate was higher than that of any public model METR had evaluated on its harness, and METR adds that observed rates depend on the scaffold's prompts and the wording of task instructions (Metr, 2026b). The horizon then depended on how the cheating was scored (Table I.8).

Table I.8 METR's 50 percent time horizon for GPT-5.6 Sol on its Time Horizon 1.1 suite, by the treatment of detected cheating (Metr, 2026b)
Treatment of detected cheating Point estimate 95 percent interval
Counted as failures (METR's standard method) About 11.3 hours 5 to 40 hours
Counted as successes Beyond 270 hours Not reported; beyond the range the suite measures reliably
Discarded 71 hours 13 to 11,400 hours

METR concluded that it did "not consider any of these numbers to represent a robust measurement" (Metr, 2026b). From other benchmark scores the developer shared and from the long-run trend, it judged that the model's capabilities on software and research tasks were not significantly beyond the state of the art. It concluded that the model did not meet the Critical threshold for AI self-improvement in OpenAI's Preparedness Framework (Metr, 2026b).

The report also carries its provenance. METR evaluated under a nondisclosure agreement, and OpenAI's communications and legal team reviewed the post. METR writes that OpenAI "would have had the legal right to block us from sharing conclusions about risk that depended on non-public information," so the evaluation "shouldn't be interpreted as robust formal oversight" (Metr, 2026b).

The METR report of Section 36.3.3 shows the current form of outside capability evaluation: access to a final checkpoint, a version METR calls "railfree," and the raw chain of thought, under a nondisclosure agreement, with the developer's review of the post (Metr, 2026b).

I.4.2 Verbalized evaluation awareness in one 2025 system card #

From Chapter 37; as of September 2025.

The card reproduces two outside evaluators' summaries. The UK AI Security Institute found that an early snapshot mentioned being evaluated, unprompted, in 16.6 percent of its scenarios, against 3.5 and 1.6 percent for Claude Sonnet 4 and Claude Opus 4.1, while its accuracy when prompted to classify scenarios was in line with earlier models (Anthropic, 2025aq). Apollo Research found unambiguous references in 58 percent of its samples, against 22 percent for Claude Opus 4.1 (Anthropic, 2025aq).

I.4.3 One developer's measurements of its models' resistance to injection #

From Chapter 49; as of July 2026.

A July 2026 preprint by Eric Wallace and colleagues at OpenAI reports the following measurements of GPT-5.6, which was trained on attacks generated by the developer's GPT-Red attacker, against the developer's earlier models (Wallace et al., 2026). All are the developer's measurements of its own models, run at roughly the equivalent of high reasoning effort.

Table I.9 GPT-5.6's resistance to prompt injection, as reported by its developer (OpenAI 2026, preprint)
Evaluation Reported result
Indirect injection: the strongest half of GPT-Red's attacks, a dataset held out from each domain, and the held-out domain of agentic coding Average defender success "climbs to greater than 50% and reaches as high at 89%"
A held-out automated red-teaming exercise in the scenario of a 2025 public challenge Attack success below 4 percent for GPT-5.6; the developer writes that this exercise inflates attack success relative to real attackers because it omits system-level mitigations
Human attacks from the 2025 public challenge's dataset, rerun 100 percent robustness, with one misgraded success confirmed by human inspection
Direct injection by text that imitates the model's own reasoning, compared with GPT-5.1, which had robustness training without attacks from automated red-teamers Robustness from 5.2 percent for GPT-5.1 to 95.9 percent for GPT-5.6

I.4.4 Models' judgment of safety research proposals in 2026 #

From Chapter 55; as of August 2026.

On TASTE, the benchmark of Section 55.3.1, the best model tested, Fable 5, agreed with experienced safety researchers' preferences on 60 percent of the 92 pairs, against an estimated 77 percent for the researchers themselves (Baig et al., 2026) (developer post). The developer adds that "Opus 5 and GPT-5.6-Sol perform near chance on TASTE despite being at the frontier on general agentic benchmarks," and that each model's confidence interval spans roughly 10 percentage points either side, too wide to rank models against each other (Baig et al., 2026). On the 74 pairs whose two proposals answer different prompts, Fable 5 reached 69 percent (Baig et al., 2026).

I.4.5 Agentic misalignment evaluation scores by Claude model #

From Chapter 56; as of May 2026.

In a May 2026 post on its own models, Anthropic reports that since Claude Haiku 4.5 every Claude model has achieved "a perfect score on the agentic misalignment evaluation," never blackmailing, "where previous models would sometimes do so up to 96% of the time (Opus 4)" (Anthropic, 2026at). A footnote qualifies both ends. Claude Sonnet 4.5 "scored well under 1%, but not quite 0," and "the results on more recent models may be confounded by the presence of information about the evaluation in the pre-training corpus" (Anthropic, 2026at).

Sources cited in Section I.4 5
  1. Metr (2026b) Summary of METR's predeployment evaluation of GPT-5.6 Sol
  2. Anthropic (2025aq) System Card: Claude Sonnet 4.5
  3. Wallace et al. (2026) GPT-Red: Automated Red Teaming via Self-Play at Scale
  4. Baig et al. (2026) TASTE: Can AI Models Judge AI Safety Research Proposals?
  5. Anthropic (2026at) Teaching Claude why

I.5 Institutions, agreements, and programs #

AI safety and security institutes and their mandates, summits, declarations, treaties and their signatories, international assessments, evaluators and outside ratings, developers' stated research programs, and facts about the industry such as market shares, compute holdings, and investment.

I.5.1 The International AI Safety Report's process and membership #

From Chapter 66; as of October 2026.

Its first full edition, in January 2025, drew on 96 experts, including an Expert Advisory Panel nominated by 30 countries, the OECD, the European Union, and the United Nations. "The independent experts writing this report collectively had full discretion over its content," and it "does not recommend specific policies" (Bengio et al., 2025b).

The 2026 edition, chaired again by Yoshua Bengio, describes its own process (Bengio et al., 2026). A writing team of over 30 drafts it. Early drafts go to external experts. A consolidated draft goes to the Expert Advisory Panel, to a group of senior advisers, and to representatives of industry and civil society, and the writers "consider feedback provided by reviewers and incorporate it where appropriate." The panel "provided technical feedback only," and the report "does not endorse any particular policy or regulatory approach." The industry reviewers listed include Anthropic, Google DeepMind, Meta, Microsoft, and OpenAI, whose systems the report assesses (Bengio et al., 2026). The edition narrowed its scope to "emerging risks," to complement "the United Nations' Independent International Scientific Panel on AI" (Bengio et al., 2026). The list of nominating countries and organizations printed in the report does not include the United States (Bengio et al., 2026), whereas the 2025 panel included a member from the US Department of Commerce (Bengio et al., 2025b).

I.5.2 The United Nations scientific panel and the vote on its members #

From Chapter 66; as of June 2026.

Concordia AI's survey of AI safety in China, an organization's tracking report, describes two mechanisms established at the United Nations in 2025 with strong Chinese support: an Independent International Scientific Panel on AI and a Global Dialogue on AI Governance. The same survey reports that the United States "voted against the Secretary General's recommended appointments" to the panel (AI, 2026).

Concordia AI's 2026 survey reports that the panel was established in 2025 and that 40 members, two of them Chinese, were appointed in their personal capacity for three-year terms. Its first annual report was scheduled for the Global Dialogue on AI Governance in Geneva on 6 and 7 July 2026, and the survey reports the American vote against the appointments noted in Section 66.1.2 (AI, 2026).

I.5.3 Signatories of the Frontier AI Safety Commitments #

From Chapter 62; as of December 2025.

At the AI Seoul Summit in May 2024, sixteen organizations agreed to the Frontier AI Safety Commitments, and four more were added later (Department for Science and Technology, 2024; Metr, 2025a).

I.5.4 Outside readings of developers' commitments #

From Chapter 62; as of December 2025.

Table I.10 Outside readings of developers' commitments
Review Who Method Main findings
Second key update to the 2025 International AI Safety Report (Bengio et al., 2025c) An international scientific assessment Review of published frameworks and research At least 12 companies had published or announced frameworks, over half of them in 2025; overall effectiveness uncertain
Do AI companies make good on voluntary commitments? (Wang et al., 2025c) Researchers at Brown, Harvard, and Stanford (preprint) 30 indicators scored from public information through 2024, for the 16 signatories of the 2023 White House commitments Average score 53 percent, highest 83.3 percent; model weight security averaged 17 percent, and 11 of 16 companies scored 0 on it
AI Safety Index, Summer 2025 (Future of Life Institute, 2025) The Future of Life Institute, an advocacy organization Expert panel grading 7 companies on 33 indicators, from documents and a company survey Best overall grade C+; none above D for existential safety planning; 3 of 7 report substantive testing for dangerous capabilities
Common elements of frontier AI safety policies (Metr, 2025a) METR, an evaluation organization Comparison of 12 published frameworks Table I.3

Among its findings, "only OpenAI has published its full policy" on whistleblowing, "and it did so only after media reports revealed the policy's highly restrictive non-disparagement clauses" (Future of Life Institute, 2025). It gave failing grades to the two Chinese firms it rated and cautioned that it scores norms "far less prominent in Chinese corporate culture," and that China already regulates advanced AI development (Future of Life Institute, 2025).

I.5.5 China's AI policy and its developers' disclosure #

From Chapter 65; as of June 2026.

Concordia AI's annual survey of AI safety in China, in its 2026 edition, reports that China's Fifteenth Five-Year Plan (2026 to 2030) makes "AI Plus," which the survey describes as the drive to diffuse AI across sectors to spur economic growth, the country's overarching AI policy (AI, 2026). The survey reports that company-level public transparency on safety "remains thin and inconsistent, lagging well behind Western peers": five of ten leading developers reported safety evaluation results alongside any release in the year surveyed, and none did so consistently (AI, 2026). It also reports that the United States and China announced an intergovernmental AI dialogue after a May 2026 presidential visit, "ending a two-year freeze in official bilateral engagement on AI safety" (AI, 2026).

I.5.6 Developers' plans set against the evidence #

From Chapter 71; as of October 2026.

Google DeepMind's plan rests on approximate continuity of progress, which "enables us to iteratively and empirically test our strategies" (Shah et al., 2025); the observation that would test the assumption is the trend across generations that O2 and O6 would measure, and none has been made. Samuel Bowman's 2025 essay at Anthropic, "Putting up Bumpers," makes alignment audits during training its primary bumpers and says to change plans if "we are repeatedly failing in consistent ways" (Bowman, 2025); how often such audits miss misalignment that arose without being planted is O1's question. OpenAI's chief scientist wrote in September 2026 that "OpenAI's primary bet here has been chain-of-thought monitoring." He added that "our evaluations indicate our ability to rely on CoT monitoring is progressively diminishing" (OpenAI, 2026e). That is a developer's report on its own bet's refutation condition, and O18 is the study that would show why. And Evan Hubinger, from inside Anthropic, called the threat from reinforcement learning on long-horizon tasks the "most concerning" and wrote that "we've pretty much yet to really meaningfully encounter it" (Hubinger, 2025) (forum post), which O2 would test if its run trained on such tasks.

I.5.7 Developers' programs of automated alignment research #

From Chapter 55; as of October 2026.

OpenAI opened its alignment research blog in December 2025 by stating that it researches how to safely develop and deploy increasingly capable AI, "and in particular AI capable of recursive self-improvement (RSI)" (OpenAI, 2025c) (developer post). Anthropic's announcement of its August 2026 study begins: "As AI begins to build itself, automating alignment research becomes increasingly important to let safety research keep pace" (Anthropic, 2026l) (developer post). Its automated alignment work published through its Fellows Program in 2026 includes an agent that fine-tunes a model to fix an unsafe behavior that auditing tools found, in March (Zhang et al., 2026a); automated researchers on weak-to-strong supervision, in April (Anthropic, 2026j); and, in August, automated researchers mitigating ten benchmarked alignment failures and a benchmark of models' judgment of safety research proposals (Anthropic, 2026l; Baig et al., 2026). Google DeepMind reported in 2025 that its coding agent AlphaEvolve sped up the training of the model family it runs on (Novikov et al., 2025) (developer white paper). The threshold for automated AI research in one developer's scaling policy, and its revisions, are in Section I.2.7 and Section I.2.8.

I.5.8 OpenAI's corporate structure after its 2025 recapitalization #

From Chapter 53; as of October 2025.

OpenAI reports that its nonprofit, renamed the OpenAI Foundation, "remains in control of the for-profit," which is now a public benefit corporation called OpenAI Group PBC, and that the Foundation holds equity "valued at approximately $130 billion" (OpenAI, 2025a) (developer document). The recapitalization was completed, the developer writes, "after nearly a year of engaging in constructive dialogue with the offices of the Attorneys General of California and Delaware" (OpenAI, 2025a).

I.5.9 The Safeguarded AI program #

From Chapter 28; as of May 2026.

A public research program tests the guaranteed-safe approach of Section 28.6.1: Safeguarded AI, run by the UK's Advanced Research and Invention Agency and backed, by its program page, by £59 million (Advanced Research and Invention Agency (ARIA), 2024). The page records a change of direction: "as of May 2026" the program sharpened its focus to an open-source toolkit that lets AI agents produce formally verified artifacts, applied to cybersecurity, a pivot it says "responds to the rapid advance of frontier AI capabilities" (Advanced Research and Invention Agency (ARIA), 2024). Its stated goal is to equip "AI-produced code, control systems, and models with quantitative guarantees of correctness and fail-safety" (Advanced Research and Invention Agency (ARIA), 2024).

Sources cited in Section I.5 20
  1. Bengio et al. (2025b) International AI Safety Report
  2. Bengio et al. (2026) International AI Safety Report 2026
  3. AI (2026) State of AI Safety in China (2026)
  4. Department for Science and Technology (2024) Frontier AI Safety Commitments, AI Seoul Summit 2024
  5. Metr (2025a) Common Elements of Frontier AI Safety Policies
  6. Bengio et al. (2025c) Second Key Update: Technical Safeguards and Risk Management
  7. Wang et al. (2025c) Do AI Companies Make Good on Voluntary Commitments to the White House?
  8. Future of Life Institute (2025) AI Safety Index: Summer 2025
  9. Shah et al. (2025) An Approach to Technical AGI Safety and Security
  10. Bowman (2025) Putting up Bumpers
  11. OpenAI (2026e) An Alien Mind
  12. Hubinger (2025) Alignment remains a hard, unsolved problem
  13. OpenAI (2025c) Hello World
  14. Anthropic (2026l) Automated researchers can reliably mitigate alignment failures
  15. Zhang et al. (2026a) A3: An Automated Alignment Agent for Safety Finetuning
  16. Anthropic (2026j) Automated Alignment Researchers: Using large language models to scale scalable oversight
  17. Baig et al. (2026) TASTE: Can AI Models Judge AI Safety Research Proposals?
  18. Novikov et al. (2025) AlphaEvolve: A coding agent for scientific and algorithmic discovery
  19. OpenAI (2025a) Built to benefit everyone
  20. Advanced Research and Invention Agency (ARIA) (2024) Safeguarded AI

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AI Alignment: From the Optimization Problem to the Institutions Around It · © 2026 Changkun Ou · CC BY-NC-SA 4.0
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