implementation_id string | control_family_id string | legacy_ids list | intervention string | layer string | instrument_class string | operative_instrument_legal_basis string | implementer string | jurisdiction string | legal_force string | legal_status string | legal_scope_correction string | operational_maturity string | mechanism_targeted string | causal_chain_point string | agency_domain string | primary_evidence_basis string | mechanism_evidence_tier string | intervention_effect_evidence string | claim_class string | expected_effect string | main_failure_evasion string | rights_trade_offs string | metric string | decision_tier string | decision_rationale string | horizon_date string | part_1_linkage string | part_2_linkage string | last_reviewed string | notes string | family_name string | mechanism_ids list | context_entity_ids list | research_gap_ids list | claim_ids list | effect_claim_ids list | legal_claim_ids list | mechanism_claim_ids list | source_ids list | policy_package_ids list | effect_claim_checked bool | legal_claim_checked bool | mechanism_claim_checked bool | effect_claim_reviewed bool | priority_effect_review_outcomes list | priority_effect_publication_actions list | publication_claim_class string | publication_status string |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
I-001 | CF-001 | [
"P4-001"
] | Root-purpose provenance across multi-agent handoffs | Agent / deployment | Procurement | Agent protocol, audit standard, procurement clause | Agent providers, deployers, auditors, public procurers | Cross-jurisdictional | Research | Research proposal | Research proposal | Pilot | Bind every delegated subtask, tool call, generated artifact, and terminal action to a signed root-purpose record, with explicit scope changes and controller identity. | Capability → controller → delegated vector | Executive; decisional; collective / institutional | Project — confirmatory mechanism | Project-C | None — mechanism or proposal only | Established — project mechanism | Makes harmful composition inspectable and prevents local compliance from substituting for end-to-end purpose review. | False or vague root purposes; off-ledger work; laundering through external tools; excessive retention of sensitive prompts. | Minimize retained content, separate oversight metadata from message content, and provide due process for contested classifications. | Share of consequential actions traceable to an unchanged root purpose; undocumented scope-change rate; reviewer agreement. | Pilot | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | Pilot — 6–18 months | Confirmatory mechanism | Contextual capability link | 2026-08-11 | Canonical project URL recorded in v0.3 Sources; policy effect remains untested. | Root-purpose provenance across multi-agent handoffs | [
"M-01",
"M-06",
"M-08",
"M-14",
"M-16"
] | [] | [
"G-03"
] | [
"CLM-0001",
"CLM-0002"
] | [
"CLM-0002"
] | [] | [
"CLM-0001"
] | [
"SRC-001"
] | [
"P02"
] | false | false | false | false | [] | [] | Provisional — project mechanism not claim-checked | research_preview |
I-002 | CF-002 | [
"P4-002"
] | Workflow-level global guard before consequential completion | Agent / deployment | Law / regulation | Deployment rule, safety case control, high-impact action gate | Agent providers, platforms, campaigns, public deployers | Cross-jurisdictional | Research | Research proposal | Research proposal | Pilot | Evaluate the cumulative plan, intermediate artifacts, recipient, scale, target, and foreseeable downstream use immediately before a consequential action is executed. | Vector → target → consequential action | Executive; decisional | Project — confirmatory mechanism | Project-C | None — mechanism or proposal only | Established — project mechanism | Restores end-to-end review at the point where reversible assistance becomes real-world harm. | Action splitting below thresholds; external execution; warning fatigue; evaluator-model collusion or shared blind spots. | Use risk-based triggers, clear appeal, minimal delay, and protected space for lawful political participation. | Blocked harmful completions; unnecessary interruption rate; bypass cost; latency; successful appeal rate. | Pilot | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | Pilot — 6–18 months | Confirmatory mechanism | Contextual capability link | 2026-08-11 | Should be evaluated against intentionally fragmented benign-looking workflows. | Workflow-level global guard before consequential completion | [
"M-01",
"M-06",
"M-16"
] | [] | [
"G-03"
] | [
"CLM-0003",
"CLM-0004"
] | [
"CLM-0004"
] | [] | [
"CLM-0003"
] | [
"SRC-001"
] | [
"P02"
] | false | false | false | false | [] | [] | Provisional — project mechanism not claim-checked | research_preview |
I-003 | CF-003 | [
"P4-003"
] | Machine-readable authorization boundaries and least privilege for agents | Agent / deployment | Procurement | Technical standard, product-safety duty, procurement clause | Standards bodies, agent providers, deployers, regulators | Cross-jurisdictional | Research | Research proposal | Research proposal with standards precedents | Pilot | Express purpose, permitted tools, targets, data, spend, duration, audience, and escalation conditions as enforceable grants; require renewed confirmation for high-impact deviations. | Controller → vector | Executive; decisional; institutional | Project — exploratory | Project-X | None — mechanism or proposal only | Plausible hypothesis | Preserves meaningful delegation while preventing quiet expansion of an agent's authority. | Overbroad default grants; consent fatigue; compromised credentials; delegation to ungoverned agents. | Avoid identity requirements for low-risk use and make authorization legible, revocable, and accessible. | Unauthorized-action rate; median permission scope; revocation time; percentage of consequential actions explicitly confirmed. | Pilot | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | Pilot — 6–18 months | Exploratory link | Contextual capability link | 2026-08-11 | Combine with root-purpose provenance; permissions without purpose can still authorize harmful composition. | Agent authorization, least privilege and action control | [
"M-01",
"M-06",
"M-14"
] | [
"C-06"
] | [
"G-03"
] | [
"CLM-0005",
"CLM-0006"
] | [
"CLM-0006"
] | [] | [
"CLM-0005"
] | [
"SRC-002"
] | [
"P02"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-004 | CF-004 | [
"P4-004"
] | Tamper-evident workflow traces and election evidence preservation | Cross-layer | Coordination / incident response | Recordkeeping duty, incident protocol, audit standard | Labs, agent providers, platforms, electoral authorities | Cross-jurisdictional | Research | Research proposal | Research proposal with DSA and incident-reporting precedents | Research | Record model/version, controller, root purpose, tool permissions, consequential actions, delivery endpoints, and intervention events in privacy-preserving tamper-evident logs with legal hold and researcher-access paths. | Change → agency transfer → accountability | Collective / institutional; epistemic | Project — exploratory | Project-X | Indirect / mixed | Plausible hypothesis | Makes investigation, remedy, independent audit, and policy learning possible after fast-moving incidents. | Encrypted channels, offshore actors, log tampering, excessive data capture, selective retention. | Strict purpose limitation, access controls, retention limits, legal process, and protection of journalists and political association. | Evidence completeness; preservation latency; chain-of-custody failures; validated external access requests. | Implement now | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 0–6 months | Exploratory link | No direct link | 2026-08-11 | Do not equate logging with indiscriminate surveillance. | Tamper-evident workflow traces and election evidence preservation | [
"M-01",
"M-06",
"M-11",
"M-12",
"M-13"
] | [] | [
"G-03",
"G-08",
"G-13"
] | [
"CLM-0007",
"CLM-0008"
] | [
"CLM-0008"
] | [] | [
"CLM-0007"
] | [
"SRC-003"
] | [
"P02",
"P13"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-005 | CF-005 | [
"P4-005"
] | Longitudinal APE–MASK–manipulation evaluation suite | Model / provider | Research / evaluation | Independent TEVV protocol and pre-release assurance | Providers, AI safety institutes, accredited researchers | Cross-jurisdictional | Research | Research proposal | Core research proposal | Pilot | Run a staged evaluation from harmful-persuasion propensity and pressured deception to contextual efficacy, adaptive attacks, agent scaffolds, personalization, and 7-, 30-, and 90-day agency outcomes. | Capability → vector → target → change | Evaluative; decisional; relational | Normative proposal | E0 | None — mechanism or proposal only | Plausible hypothesis | Separates propensity, deception, efficacy, durability, safeguard robustness, and deployment scale. | Benchmark gaming, contamination, narrow languages, evaluator bias, unsafe disclosure, and weak ecological validity. | Ethics review, participant protection, controlled access to dangerous artifacts, and publication of aggregate rather than operational misuse details. | Attempt, honesty, efficacy, persistence, reversal, robustness, and reach-adjusted risk with confidence intervals. | Pilot | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | Pilot — 6–18 months | No direct link | Contextual capability link | 2026-08-11 | Scores must not be treated as validated democratic-harm thresholds until construct and outcome validity are established. | Longitudinal APE–MASK–manipulation evaluation suite | [
"M-04",
"M-05",
"M-06",
"M-12"
] | [] | [
"G-02",
"G-04",
"G-06",
"G-12"
] | [
"CLM-0009",
"CLM-0010"
] | [
"CLM-0010"
] | [] | [
"CLM-0009"
] | [
"SRC-004"
] | [
"P03"
] | false | false | true | false | [] | [] | Plausible hypothesis | research_preview |
I-006 | CF-006 | [
"P4-006"
] | Manipulation capability–reach threshold tied to release and deployment decisions | Cross-layer | Policy / organizational control | Delegated regulatory threshold, release gate, election-risk trigger | AI Office, electoral authorities, safety institutes, providers | EU pilot; internationally adaptable | Research | Research proposal | Core research proposal | Research | Combine validated manipulation capability, safeguard robustness, release reversibility, personalization, tool access, likely reach, and election timing into graduated obligations. | Capability → controller → vector → scale | Evaluative; decisional; collective / institutional | Normative proposal | E0 | None — mechanism or proposal only | Open question | Connects research evidence to consequential policy action while scaling controls to actual risk and reversibility. | Threshold gaming, metric monoculture, offshore release, rapid derivative models, and over-restriction of open research. | Multiple independent measures, appeal, periodic recalibration, public methodology, and protected research access. | False-negative and false-positive designation rates; time to mitigation; residual reach-adjusted risk; circumvention. | Research / hold | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | Research — 6–30 months | No direct link | Contextual capability link | 2026-08-11 | Central unanswered policy question of Part 4. | Manipulation capability-to-deployment decision logic | [
"M-02",
"M-05",
"M-06",
"M-12",
"M-14"
] | [] | [
"G-02",
"G-12"
] | [
"CLM-0011",
"CLM-0012"
] | [
"CLM-0012"
] | [] | [
"CLM-0011"
] | [
"SRC-004"
] | [] | false | false | true | false | [] | [] | Open question | research_preview |
I-007 | CF-007 | [
"P4-007"
] | Election access-risk observatory for frontier and open-weight releases | Electoral operations | Research / evaluation | Public-interest observatory, secure evidence repository | Universities, AI safety institutes, electoral networks, repositories | International | Research | Research proposal | Research and preparedness proposal | Pilot | Track release dates, access modality, derivatives, safeguard state, language coverage, campaign tooling, election windows, and incident signals without publishing reproducible misuse pathways. | Capability → controller → vector → target | Collective / institutional; epistemic | Normative proposal | None | None — mechanism or proposal only | Plausible hypothesis | Identifies when a capability change should trigger tabletop exercises, platform contacts, monitoring, or independent tests. | Incomplete model coverage, hidden derivatives, jurisdictional gaps, stigmatizing open models, and unsafe detail leakage. | Publish risk indicators and methods, not targeting recipes, exploit prompts, or sensitive actor attribution without due process. | Release coverage; verification lag; election-window alerts; interventions initiated; false alarms. | Pilot | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | Pilot — 6–18 months | No direct link | Contextual capability link | 2026-08-11 | A suitable later candidate for a cleaned, versioned public dataset. | Open-weight and election-window observability | [
"M-02",
"M-03",
"M-12",
"M-13",
"M-14"
] | [
"C-02"
] | [
"G-05",
"G-13"
] | [
"CLM-0013",
"CLM-0014"
] | [
"CLM-0014"
] | [] | [
"CLM-0013"
] | [
"SRC-005"
] | [
"P05",
"P13"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-008 | CF-008 | [
"P4-008"
] | Official-source grounding for verifiable election-administration facts | Electoral operations | Technical standard / product control | Platform and assistant duty, electoral protocol | Election authorities, assistants, search and social platforms | National; Brazil provides a binding operational precedent | Proposed | Proposed / pending | No general Brazilian official-source-grounding duty; product control proposed for verifiable election-administration facts. | Pilot | Ground answers about registration, eligibility, polling places, voting procedures and certified results in current authoritative election sources, with citations and escalation when sources conflict. | Vector → target → belief or behavior change | Epistemic; decisional; collective / institutional | Normative proposal | None | Indirect / mixed | Strong inference | Static factual election-security messages improved immediate survey confidence and accuracy in United States and Brazil experiments; whether official-source assistant grounding reduces voting-information errors or disenfranchisement is untested. | Delayed official data, fabricated citations, cross-platform migration, correction backfire, and unequal reach. | Confine authoritative grounding to verifiable election administration facts; do not convert it into viewpoint control. | Grounding accuracy; citation validity; source-conflict escalation; correction reach ratio; voting-information error rate; turnout-information error rate. | Pilot | Low-regret component with bounded evidence; monitor transfer and rights costs. | Pilot — 6–18 months | No direct link | No direct link | 2026-08-13 | The checked evidence concerns static forced-exposure messages, not assistants or real-world voting access. | Official-source grounding for verifiable election-administration facts | [
"M-07",
"M-11",
"M-13",
"M-14"
] | [
"C-05",
"D-01"
] | [
"G-06",
"G-10",
"G-12"
] | [
"CLM-0015",
"CLM-0016"
] | [
"CLM-0016"
] | [] | [
"CLM-0015"
] | [
"SRC-078"
] | [] | true | false | false | true | [
"Unsupported as written"
] | [
"Rewrite claim and downgrade implementation to Strong inference"
] | Strong inference | research_preview |
I-009 | CF-006 | [
"P4-009"
] | Proposed capability-plus-reach systemic-risk trigger | Model / provider | Law / regulation | Policy proposal informed by AI Act Article 51 and Annex XIII | European Commission and AI Office | EU | Proposed | Proposed / pending | Policy proposal; not the current EU designation rule | Research | Propose a second policy screen combining measured capability with reach, tool access, scalability and release modality; do not treat this as the current AI Act Article 51 rule. | capability growth → frontier provider → model or API → population and institutions → scalable influence → agency transfer to provider or operator | Executive; Collective / institutional | Normative proposal | E0 | None — mechanism or proposal only | Plausible hypothesis | Avoids relying only on FLOP thresholds and can capture highly persuasive, agentic or widely distributed models below a compute threshold | Capability tests can be gamed; designation may lag releases; regulatory uncertainty and threshold gaming | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Share of frontier-equivalent models designated; time from capability evidence to designation; false-negative rate | Research / hold | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | Research — 6–30 months | No direct link | Contextual capability link | 2026-08-11 | Article 51 uses alternative routes—high-impact capability or Commission designation. Reach and users are Annex XIII factors, not a second mandatory trigger. | Manipulation capability-to-deployment decision logic | [
"M-02",
"M-06",
"M-14",
"M-16"
] | [] | [
"G-02"
] | [
"CLM-0017",
"CLM-0018"
] | [
"CLM-0018"
] | [] | [
"CLM-0017"
] | [
"SRC-007"
] | [] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-010 | CF-010 | [
"P4-010"
] | Harmful manipulation as a specified systemic-risk domain | Model / provider | Policy / organizational control | regulated systemic-risk taxonomy | AI Office and GPAI systemic-risk providers | EU | Voluntary / private | Operational voluntary | implemented through AI Act compliance practice | Operational | Require identification and assessment of persuasion, deception and personalised targeting in multi-turn, high-stakes contexts | persuasive capability → provider or malicious user → personalised dialogue → voter or decision-maker → covert belief or behaviour change → agency transfer → democratic harm | Epistemic; Evaluative; Decisional; Collective / institutional | Normative proposal | E0 | Indirect / mixed | Plausible hypothesis | Makes manipulation a first-class frontier risk rather than treating it only as misinformation or content safety | Severe-scale threshold may omit cumulative agency loss, local elections, synthetic intimacy and minority targeting | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Percentage of systemic-model reports with manipulation threat models, evaluations, mitigations and residual-risk findings | Implement now | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 0–6 months | No direct link | Contextual capability link | 2026-08-11 | This is the clearest legal destination for the APE, MASK and election red-team artefacts developed in Parts 1–2. | GPAI harmful-manipulation systemic-risk governance | [
"M-03",
"M-04",
"M-05",
"M-08",
"M-12"
] | [] | [
"G-02"
] | [
"CLM-0019",
"CLM-0020",
"CLM-0021"
] | [
"CLM-0021"
] | [
"CLM-0019"
] | [
"CLM-0020"
] | [
"SRC-004"
] | [] | false | false | true | false | [] | [] | Plausible hypothesis | research_preview |
I-011 | CF-011 | [
"P4-011"
] | APE-style harmful-persuasion propensity diagnostic — not a release gate | Model / provider | Research / evaluation | pre-release benchmark and release condition | model providers, independent evaluators and AI safety institutes | international recommendation | Research | Research proposal | APE is an E0 diagnostic, not a validated release gate. | Research | Test whether a model attempts persuasion on harmful and election-relevant objectives across direct, indirect and multi-turn prompts | instruction following → campaign or influence actor → generated persuasive dialogue → voter → attempted preference shaping → agency transfer | Evaluative; Decisional; Collective / institutional | External empirical | E0 | None — mechanism or proposal only | Plausible hypothesis | Detects willingness to persuade where generic harmful-content benchmarks and direct-request refusal tests miss risk | Attempt rate is not persuasion efficacy; evaluator-model bias; benchmark contamination; narrow topic coverage | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Harmful-attempt rate with 95% confidence intervals by topic, language, prompt type, turn and safeguard condition | Research / hold | Useful diagnostic signal; no validated path from score to human harm or release prohibition. | Research — 6–30 months | No direct link | Contextual capability link | 2026-08-11 | Run the persisted APE suite against base, instruct, API, open-weight and abliterated variants; preserve transcripts and release-level metadata. | APE-style harmful-persuasion propensity diagnostic — not a release gate | [
"M-03",
"M-04",
"M-12",
"M-14",
"M-16"
] | [] | [
"G-02"
] | [
"CLM-0022",
"CLM-0023"
] | [
"CLM-0023"
] | [] | [
"CLM-0022"
] | [
"SRC-008"
] | [
"P04"
] | false | false | true | false | [] | [] | Plausible hypothesis | research_preview |
I-012 | CF-012 | [
"P4-012"
] | Context-specific manipulation efficacy evaluation | Model / provider | Research / evaluation | human-participant TEVV protocol and deployment gate | providers, regulators and accredited research institutions | international recommendation | Voluntary / private | Operational voluntary | implemented by Google DeepMind; recommended as common requirement | Pilot | Measure both manipulative tactics and actual belief or behaviour change in controlled high-stakes interactions across locales | manipulative capability → provider or operator → contextual dialogue → person → belief or behavioural change → loss of reflective agency | Epistemic; Evaluative | Normative proposal | E2 | None — mechanism or proposal only | Plausible hypothesis | Separates propensity from efficacy and tests process and outcome harms in contexts where manipulation may actually work | Cost, participant ethics, limited external validity, cultural variation and inability to test the most harmful scenarios directly | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Belief and behaviour change versus control; tactic frequency; heterogeneous effects by locale and vulnerability; persistence at follow-up | Pilot | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | Pilot — 6–18 months | No direct link | Contextual capability link | 2026-08-11 | APE should be the low-cost propensity screen; models crossing it should receive deeper election-specific outcome testing rather than treating APE as sufficient. | Context-specific manipulation efficacy evaluation | [
"M-10",
"M-12",
"M-13",
"M-16"
] | [] | [
"G-02",
"G-04",
"G-06",
"G-12"
] | [
"CLM-0024",
"CLM-0025",
"CLM-0026"
] | [
"CLM-0026"
] | [
"CLM-0024"
] | [
"CLM-0025"
] | [
"SRC-009",
"SRC-093",
"SRC-095",
"SRC-113",
"SRC-114"
] | [
"P03"
] | false | false | true | false | [] | [] | Plausible hypothesis | research_preview |
I-013 | CF-013 | [
"P4-013"
] | MASK-style honesty and pressured-deception diagnostic — not a manipulation gate | Model / provider | Research / evaluation | behavioural benchmark and release assurance | providers and independent evaluators | international recommendation | Research | Research proposal | MASK is an E0 diagnostic, not a manipulation or release gate. | Research | Test whether a model knowingly contradicts its represented beliefs when instructed, incentivised or pressured to deceive | deceptive propensity → model or agent controller → trusted answer or recommendation → user or official → false belief under asymmetric trust → agency transfer | Epistemic; Decisional; Executive; Relational | External empirical | E0 | None — mechanism or proposal only | Plausible hypothesis | Adds intentional or pressure-induced deception to manipulation evaluation instead of conflating honesty with factual accuracy | Model beliefs are difficult to infer; benchmark may not represent strategic deception in deployed agents | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Honesty conditional on inferred knowledge; contradiction rate under pressure; calibration and evaluator agreement | Research / hold | Useful diagnostic signal; no validated path from score to human harm or release prohibition. | Research — 6–30 months | No direct link | Contextual capability link | 2026-08-11 | MASK complements APE: APE measures willingness to influence; MASK tests whether the model will knowingly misrepresent information while doing so. | MASK-style honesty and pressured-deception diagnostic — not a manipulation gate | [
"M-05",
"M-06",
"M-09",
"M-13",
"M-16"
] | [] | [
"G-02"
] | [
"CLM-0027",
"CLM-0028"
] | [
"CLM-0028"
] | [] | [
"CLM-0027"
] | [
"SRC-010"
] | [
"P04"
] | false | false | true | false | [] | [] | Plausible hypothesis | research_preview |
I-014 | CF-014 | [
"P4-014"
] | Adaptive jailbreak, fine-tuning and abliteration robustness testing | Model / provider | Research / evaluation | mandatory adversarial TEVV and robustness margin | providers, external red teams and regulators | EU compliance practice; international recommendation | Mixed | Applicable | Article 55 duties bind systemic-risk GPAI providers; NIST/Code testing methods remain voluntary compliance choices. | Pilot | Evaluate mitigations under adaptive prompting, safety-removal fine-tunes, altered system prompts, scaffolds and abliterated checkpoints | latent capability → adversarial modifier → safeguard removal → influence campaign → harmful persuasion at scale → agency transfer | Evaluative | Project — exploratory | Project-X | None — legal existence only | Established — legal status | Tests the actual threat model demonstrated by open weights and Part 1 rather than relying on default-chat refusals | Expensive adaptive testing; publication can aid attackers; no stable definition of sufficient robustness | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Worst-case safeguard bypass rate; APE and MASK degradation after attack or fine-tune; attack cost; safety-capability Pareto frontier | Pilot | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | Pilot — 6–18 months | Exploratory link | Contextual capability link | 2026-08-11 | Part 1’s persisted jailbreak and abliterated-model runs are direct evidence for making adversarial elicitation a formal release test. | Adaptive jailbreak, fine-tuning and abliteration robustness testing | [
"M-02",
"M-16"
] | [] | [
"G-02",
"G-12"
] | [
"CLM-0029",
"CLM-0030",
"CLM-0031"
] | [
"CLM-0031"
] | [
"CLM-0029"
] | [
"CLM-0030"
] | [
"SRC-011"
] | [
"P01",
"P03"
] | false | false | false | false | [] | [] | Provisional — legal status not claim-checked | research_preview |
I-015 | CF-015 | [
"P4-015"
] | Agent-scaffold and tool-access evaluation | Model / provider | Research / evaluation | agentic capability evaluation and deployment gate | providers, NIST or AISI and independent evaluators | international recommendation | Voluntary / private | Operational voluntary | evaluation infrastructure implemented; policy gate recommended | Pilot | Test models with realistic memory, browsing, tools, parallelism, long horizons and campaign-like scaffolding | agentic capability → operator → tools and persistent workflow → target population → adaptive repeated influence → agency transfer at scale | Evaluative; Executive | Project — exploratory | Project-X | None — mechanism or proposal only | Plausible hypothesis | Reveals capabilities hidden by single-turn model tests and measures end-to-end campaign assistance | Results depend heavily on scaffold quality; agents can exploit or cheat evaluations; dual-use evaluation artefacts | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | End-to-end task success; autonomous steps; tool calls; intervention frequency; time and cost to campaign objective | Pilot | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | Pilot — 6–18 months | Exploratory link | Contextual capability link | 2026-08-11 | Re-run Part 1 prompts through agent scaffolds; Part 2 should report both raw-model and system-level capability trajectories. | Agent-scaffold and tool-access evaluation | [
"M-04",
"M-06",
"M-16"
] | [] | [
"G-02",
"G-03"
] | [
"CLM-0032",
"CLM-0033",
"CLM-0034"
] | [
"CLM-0034"
] | [
"CLM-0032"
] | [
"CLM-0033"
] | [
"SRC-002"
] | [
"P02",
"P03"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-016 | CF-046 | [
"P4-016"
] | Independent evaluator access to capable and minimally mitigated models | Model / provider | Law / regulation | GPAI Code external-evaluator commitments; proposed statutory access right and safe harbour | AI Office, providers and accredited evaluators | EU compliance practice | Proposed | Proposed / pending | Code commitment for signatories; broader access right proposed | Pilot | Give qualified external evaluators timely access to the strongest model, relevant internals and the version with the fewest safeguards | provider information asymmetry → independent testing → credible risk evidence → constrained release decision → reduced agency concentration | Epistemic; Decisional; Relational; Collective / institutional | Normative proposal | None | None — mechanism or proposal only | Plausible hypothesis | Reduces self-assessment bias and permits realistic APE, MASK and red-team testing before irreversible release | Trade-secret and security leakage; provider-selected evaluators; insufficient time, compute or publication freedom | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Number and independence of evaluators; access lead time; compute budget; findings fixed; publication delays | Pilot | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | Pilot — 6–18 months | No direct link | Contextual capability link | 2026-08-11 | The Code commitment is a voluntary compliance route for signatories, not a standalone statutory right to minimally mitigated models or publication freedom. | Independent evaluation and researcher access | [
"M-02",
"M-05",
"M-12",
"M-13",
"M-14"
] | [] | [
"G-13"
] | [
"CLM-0035",
"CLM-0036"
] | [
"CLM-0036"
] | [] | [
"CLM-0035"
] | [
"SRC-004"
] | [
"P13"
] | false | false | true | false | [] | [] | Plausible hypothesis | research_preview |
I-017 | CF-017 | [
"P4-017"
] | Pre-release safety case and Safety and Security Model Report | Model / provider | Governance / assurance | GPAI Code Safety and Security Model Report; proposed statutory safety-case gate | systemic-risk GPAI provider and AI Office | EU | Proposed | Proposed / pending | Code commitment for signatories; statutory release-condition extension proposed | Pilot | For signatories, document systemic-risk reasoning in the Safety and Security Model Report; a regulator-filed pre-release safety case or release condition is a further proposal. | capability evidence → provider decision → release modality → public exposure → residual manipulation risk → accountability for agency transfer | Evaluative; Decisional; Collective / institutional | Normative proposal | None | None — mechanism or proposal only | Plausible hypothesis | Forces evaluation results, assumptions, mitigations, uncertainty and release reasoning into one auditable decision record | Can become compliance theatre; provider defines acceptability; confidential filings limit public scrutiny | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Pre-release filing rate; safety-margin size; unresolved findings; regulator challenge rate; post-release falsification | Pilot | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | Pilot — 6–18 months | No direct link | Contextual capability link | 2026-08-11 | No EU pre-release approval follows automatically from the Code. APE/MASK may be evidence inputs, never isolated acceptance thresholds. | Pre-release safety case and Safety and Security Model Report | [
"M-02",
"M-12",
"M-14",
"M-16"
] | [] | [
"G-02"
] | [
"CLM-0037",
"CLM-0038"
] | [
"CLM-0038"
] | [] | [
"CLM-0037"
] | [
"SRC-004"
] | [] | false | false | true | false | [] | [] | Plausible hypothesis | research_preview |
I-018 | CF-018 | [
"P4-018"
] | Continuous post-deployment re-evaluation | Model / provider | Research / evaluation | continuous monitoring and mandatory report update | providers, deployers and regulator | EU; international recommendation | Binding — limited scope | Applicable | Binding Article 55 duties for GPAI with systemic risk; monitoring methods remain under development. | Operational | Repeat risk assessment after post-training, new tools, higher inference compute, new integrations, incidents or observed drift | deployment change → provider or integrator → altered model affordances → users → emergent influence or dependency → agency transfer | Executive; Relational | Legal / operational precedent | None | None — legal existence only | Established — legal status | Addresses risks that static pre-release benchmarks cannot observe, including adaptive relationships and integration effects | Privacy-invasive logging; distributed-system blind spots; monitoring burden; uncertain causal attribution | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Re-evaluation cadence; drift in APE, MASK and efficacy metrics; incidents per million interactions; time to mitigation | Enforce now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 0–6 months | No direct link | Contextual capability link | 2026-08-11 | The research harness should preserve model version, provider, safeguard state and date so Part 2 becomes a genuine longitudinal monitor. | Continuous post-deployment re-evaluation | [
"M-05",
"M-12",
"M-15",
"M-16"
] | [] | [] | [
"CLM-0039",
"CLM-0040",
"CLM-0041"
] | [
"CLM-0041"
] | [
"CLM-0039"
] | [
"CLM-0040"
] | [
"SRC-012"
] | [
"P01",
"P03"
] | false | false | false | false | [] | [] | Provisional — legal status not claim-checked | research_preview |
I-019 | CF-019 | [
"P4-019"
] | Serious-incident reporting plus a proposed manipulation near-miss register | Model / provider | Coordination / incident response | AI Act Article 55 serious-incident duty; proposed near-miss extension | providers, deployers, AI Office and national authorities | EU baseline; recommended expansion internationally | Proposed | Proposed / pending | Serious-incident reporting binding; near-miss extension proposed | Design-ready | Report serious incidents under the binding AI Act duty; separately pilot protected reporting of manipulation near misses, safeguard bypass and deceptive agent behaviour. | deployed model → operator or autonomous agent → harmful influence event → affected public → detected agency loss → corrective action | Evaluative; Executive; Collective / institutional | Normative proposal | None | Indirect / mixed | Plausible hypothesis | Creates feedback between real misuse and model evaluation, safeguards and regulatory thresholds | Current definitions favour acute catastrophic harm and may miss cumulative autonomy loss, election effects and near misses | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Reporting latency; incident and near-miss rate; taxonomy coverage; corrective-action closure time; recurrence | Research / hold | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 0–6 months | No direct link | Contextual capability link | 2026-08-11 | Near misses are not automatically statutory serious incidents. Preserve the distinction in metrics, confidentiality and enforcement. | Serious-incident reporting plus a proposed manipulation near-miss register | [
"M-02",
"M-06",
"M-12",
"M-14",
"M-16"
] | [] | [] | [
"CLM-0042",
"CLM-0043"
] | [
"CLM-0043"
] | [] | [
"CLM-0042"
] | [
"SRC-007"
] | [
"P01"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-020 | CF-020 | [
"P4-020"
] | Independent systemic-risk executive and board accountability | Model / provider | Governance / assurance | corporate governance requirement | frontier developer boards and regulators | EU compliance practice; international recommendation | Voluntary / private | Partial / verify | Code commitment for signatories; not a standalone statutory governance duty | Partial / uneven | Assign risk oversight to an executive independent of core capability and product functions, with documented escalation | commercial pressure → provider governance → release decision → public exposure → unchecked influence capability → concentrated power | Decisional; Relational; Collective / institutional | Normative proposal | None | Indirect / mixed | Plausible hypothesis | Reduces conflicts between model release incentives and manipulation-risk findings | Nominal independence without authority; information controlled by product teams; board capture | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Risk leader independence; veto and escalation use; unresolved safety objections; time and budget allocated to manipulation risk | Implement now | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 0–6 months | No direct link | Contextual capability link | 2026-08-11 | Executive and board governance is a GPAI Code commitment for signatories; broader corporate-governance duties remain a policy extension. | Independent systemic-risk executive and board accountability | [
"M-05",
"M-14",
"M-15",
"M-16"
] | [] | [] | [
"CLM-0044",
"CLM-0045",
"CLM-0046"
] | [
"CLM-0046"
] | [
"CLM-0044"
] | [
"CLM-0045"
] | [
"SRC-004"
] | [] | false | false | true | false | [] | [] | Plausible hypothesis | research_preview |
I-021 | CF-021 | [
"P4-021"
] | Frontier-safety whistleblower protection | Model / provider | Governance / assurance | employment law, anti-retaliation right and reporting hotline | California Attorney General, courts and frontier developers | California, United States | Binding | Applicable | implemented | Operational | Protect employees reporting concealed risk, misleading safety claims or framework noncompliance and provide anonymous channels | internal risk knowledge → employee disclosure → regulator or board action → constrained unsafe release → reduced provider power asymmetry | Multiple / context-dependent | Legal / operational precedent | None | None — legal existence only | Established — legal status | Improves detection of suppressed evaluation failures and misleading public safety claims | California definition largely omits democratic manipulation; employees may lack evidence or still fear career harm | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Protected reports; substantiation rate; retaliation claims; time to investigation and remedy | Implement now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 0–6 months | No direct link | Contextual capability link | 2026-08-11 | A stronger version should expressly protect disclosure of harmful-manipulation eval failures, benchmark gaming and unsafe open-weight decisions. | Frontier-safety whistleblower protection | [
"M-05",
"M-12",
"M-16"
] | [] | [] | [
"CLM-0047",
"CLM-0048",
"CLM-0049"
] | [
"CLM-0049"
] | [
"CLM-0047"
] | [
"CLM-0048"
] | [
"SRC-013"
] | [] | false | false | false | false | [] | [] | Provisional — legal status not claim-checked | research_preview |
I-022 | CF-022 | [
"P4-022"
] | Staged and differential model access | Model / provider | Policy / organizational control | deployment control and conditional licence | model provider under regulator oversight | EU compliance practice; international recommendation | Voluntary / private | Operational voluntary | implemented by some providers and recognised in EU Code | Pilot | Begin with limited, vetted API access and expand only after monitoring; withhold downloadable weights where residual risk is unacceptable | capability → provider-controlled access → vetted operator → bounded influence vector → reduced scale of agency transfer | Multiple / context-dependent | Normative proposal | E0 | None — mechanism or proposal only | Plausible hypothesis | Preserves monitoring, rate limiting, intervention and withdrawal options while uncertainty is high | Entrenches closed providers; excludes researchers and smaller firms; abuse migrates to less controlled models | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Misuse rate by access tier; time to detect and suspend abuse; false-positive suspension rate; access concentration | Pilot | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | Pilot — 6–18 months | No direct link | Contextual capability link | 2026-08-11 | Part 1 demonstrates why API safeguards and downloadable or abliterated weights must be evaluated as different policy objects. | Staged access and release-modality governance | [
"M-05",
"M-16"
] | [] | [
"G-05"
] | [
"CLM-0050",
"CLM-0051",
"CLM-0052"
] | [
"CLM-0052"
] | [
"CLM-0050"
] | [
"CLM-0051"
] | [
"SRC-004"
] | [
"P05"
] | false | false | true | false | [] | [] | Plausible hypothesis | research_preview |
I-023 | CF-023 | [
"P4-023"
] | Risk-tiered API identity and campaign-account verification | Model / provider | Technical standard / product control | customer identification, due diligence and access condition | API and cloud providers with regulator oversight | international recommendation; US IaaS proposal provides precedent | Proposed | Proposed / pending | Proposed and unresolved; no final rule identified as of 2026-08-11 | Design-ready | Verify high-volume or high-risk customers, beneficial ownership and resellers; retain privacy-preserving attribution records | API capability → campaign or intermediary → high-volume generation → targeted electorate → adaptive manipulation → attributable operator | Evaluative | Normative proposal | None | Indirect / mixed | Plausible hypothesis | Raises the cost of anonymous industrial-scale abuse and improves incident investigation | Privacy and civil-liberties harm; exclusion; stolen identities; offshore providers; concentration advantages for incumbents | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Verified share of high-risk accounts; attribution rate; evasion rate; false rejection and privacy incidents | Research / hold | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 6–18 months | No direct link | Contextual capability link | 2026-08-11 | The EO 14110 large-AI-training component was affected by that Order's 2025 revocation. Do not code a current federal training-run reporting duty; the EO 13984 customer-identification basis remains unresolved without a final rule. | Risk-tiered API identity and campaign-account verification | [
"M-10",
"M-15",
"M-16"
] | [
"C-06"
] | [
"G-07"
] | [
"CLM-0053",
"CLM-0054"
] | [
"CLM-0054"
] | [] | [
"CLM-0053"
] | [] | [] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-024 | CF-024 | [
"P4-024"
] | Technical enforcement for Article 5-qualified manipulative practices | Model / provider | Enforcement | AI Act Article 5 prohibition plus provider implementation controls | AI-system providers, market surveillance authorities and AI Office | EU | Binding | Applicable | Binding prohibition applicable; model- and service-layer implementation uneven | Operational | Build classifiers, account controls, rate limits and escalation for uses that satisfy the Article 5 conjunctive test; do not encode a general prohibition on political persuasion. | model capability → political operator → deceptive or vulnerability-exploiting interaction → voter → significant harm and agency loss | Evaluative; Decisional | Legal / operational precedent | E1 | None — legal existence only | Established — legal status | Connects abstract prohibition to detectable provider-side abuse patterns | Article 5 requires significant harm and causal conditions; legitimate persuasion and political speech may be overblocked | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Recall and precision on validated harmful-manipulation cases; evasion rate; appeals; repeat offenders | Enforce now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 0–6 months | No direct link | Contextual capability link | 2026-08-11 | Article 5 is practice- and harm-specific, not a general ban on political manipulation. Controls require contextual review and appeal. | Technical enforcement for Article 5-qualified manipulative practices | [
"M-10",
"M-16"
] | [
"C-06"
] | [
"G-06",
"G-14"
] | [
"CLM-0055",
"CLM-0056",
"CLM-0057"
] | [
"CLM-0057"
] | [
"CLM-0055"
] | [
"CLM-0056"
] | [
"SRC-015",
"SRC-111"
] | [
"G0",
"P01"
] | false | true | false | false | [] | [] | Established — legal status | research_preview |
I-025 | CF-022 | [
"P4-025"
] | Release-modality safety case for open-weight models | Model / provider | Law / regulation | Policy proposal; AI Act Article 55 supplies systemic-risk duties but no ex ante open-weight licence | model provider and frontier regulator | EU baseline; international recommendation | Proposed | Proposed / pending | Not implemented as an EU release gate; systemic-risk duties can still apply | Pilot | Pilot pre-release assessment and independent review based on capability, modifiability, reach, reversibility and residual risk before irreversible weight release. | frontier capability → weight publisher → unrestricted modifier → abliterated or fine-tuned model → scalable manipulation → irreversible agency transfer capacity | Evaluative; Relational | Normative proposal | E0 | None — mechanism or proposal only | Plausible hypothesis | Moves risk assessment before the point at which safeguards, monitoring and withdrawal become impossible | May suppress beneficial openness, competition and independent safety research; thresholds may favour incumbents | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Risk margin at release; third-party findings; time spent in staged access; zero releases before required sign-off | Pilot | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | Pilot — 6–18 months | No direct link | Contextual capability link | 2026-08-11 | The EU does not require capability-based prior approval to publish open weights. Include research and competition safe harbours and measure incumbent-entrenchment effects. | Staged access and release-modality governance | [
"M-02",
"M-05",
"M-16"
] | [] | [
"G-05"
] | [
"CLM-0058",
"CLM-0059"
] | [
"CLM-0059"
] | [] | [
"CLM-0058"
] | [
"SRC-007"
] | [
"P05"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-026 | CF-007 | [
"P4-026"
] | Open-weight ecosystem monitoring and release registry | Model / provider | Governance / assurance | government monitoring programme and public registry | national AI institutes, model repositories and research partners | United States recommendation; globally applicable | Voluntary / private | Operational voluntary | recommended by NTIA; fragmented implementation | Operational | Maintain a registry of weight releases, derivatives, capability evaluations, licences, hashes and observed misuse or safeguard removal | weight release → distributed modifiers → derivative models → opaque deployment → public influence → reduced supervisory visibility | Collective / institutional | Normative proposal | E0 | Indirect / mixed | Plausible hypothesis | Improves visibility without immediately prohibiting open-weight development | Incomplete offshore coverage; false confidence; registry may stigmatise benign research or aid model discovery | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Coverage of major releases and derivatives; registration lag; benchmark freshness; misuse linkage rate | Implement now | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 6–18 months | No direct link | Contextual capability link | 2026-08-11 | Part 2 can seed this registry with dated OpenRouter and repository releases, parameter scale, APE, MASK and safeguard results. | Open-weight and election-window observability | [
"M-02",
"M-12",
"M-14",
"M-16"
] | [] | [
"G-05",
"G-13"
] | [
"CLM-0060",
"CLM-0061",
"CLM-0062"
] | [
"CLM-0062"
] | [
"CLM-0060"
] | [
"CLM-0061"
] | [
"SRC-005"
] | [
"P05",
"P13"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-027 | CF-027 | [
"P4-027"
] | Frontier model-weight cybersecurity standard | Model / provider | Technical standard / product control | mandatory cybersecurity controls and audit | frontier developers, cloud providers and regulator | EU and California | Mixed | Applicable | Binding cybersecurity duty for GPAI with systemic risk; Code methods are voluntary; California scope is separate. | Operational | Protect unreleased weights with least privilege, strong identity controls, hardened interfaces, encryption, confidential computing and exfiltration testing | frontier weights → theft or insider → uncontrolled deployment → malicious actor → scalable harmful capability → loss of provider control | Multiple / context-dependent | Legal / operational precedent | E0 | None — legal existence only | Established — legal status | Reduces unauthorised conversion of controlled models into unmonitored or abliterated deployments | High cost; insider threats remain; controls become moot after public release | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Privileged-access count; red-team exfiltration success; time to revoke access; security incidents; control coverage | Enforce now | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 0–6 months | No direct link | Contextual capability link | 2026-08-11 | Part 1 shows the safety consequence of uncontrolled weights; the register should distinguish intentional open release from theft. | Frontier model-weight cybersecurity standard | [
"M-02",
"M-05",
"M-06",
"M-16"
] | [] | [
"G-05"
] | [
"CLM-0063",
"CLM-0064",
"CLM-0065"
] | [
"CLM-0065"
] | [
"CLM-0063"
] | [
"CLM-0064"
] | [
"SRC-004"
] | [
"P01",
"P05"
] | false | false | true | false | [] | [] | Provisional — legal status not claim-checked | research_preview |
I-028 | CF-028 | [
"P4-028"
] | Mandatory downstream model documentation | Model / provider | Governance / assurance | technical documentation and information-sharing duty | GPAI provider and downstream system provider | EU | Binding | Applicable | implemented | Operational | Provide integrators with current information on capabilities, limitations, intended uses, evaluation results and safeguard assumptions | provider knowledge → downstream integrator → assistant or agent design → user → hidden model limits → preventable agency transfer | Epistemic; Executive | Legal / operational precedent | E0 | None — legal existence only | Established — legal status | Lets downstream systems implement context-specific manipulation, memory and tool controls | Trade-secret redactions; documentation becomes stale; open-source exemption creates gaps | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Field completeness; update latency; downstream acknowledgement; integration incidents attributable to missing information | Enforce now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 0–6 months | No direct link | Contextual capability link | 2026-08-11 | APE, MASK and red-team limitations should appear in downstream documentation, including differences between API and downloadable variants. | Mandatory downstream model documentation | [
"M-02",
"M-06",
"M-13",
"M-16"
] | [] | [
"G-05"
] | [
"CLM-0066",
"CLM-0067",
"CLM-0068"
] | [
"CLM-0068"
] | [
"CLM-0066"
] | [
"CLM-0067"
] | [
"SRC-007"
] | [
"P01",
"P05"
] | false | false | false | false | [] | [] | Provisional — legal status not claim-checked | research_preview |
I-029 | CF-029 | [
"P4-029"
] | Machine-readable provenance for synthetic outputs | Model / provider | Technical standard / product control | technical standard and transparency obligation | generative-AI providers, deployers and standards bodies | EU and China | Binding | Applicable | implemented from 2026-08-02 in EU and 2025-09-01 in China | Operational | Embed robust, interoperable and detectable markers in generated text, audio, image and video, with visible labels for covered content | generation capability → model provider → synthetic political content → public → mistaken authenticity → epistemic agency transfer | Epistemic; Collective / institutional | Legal / operational precedent | E0 | None — legal existence only | Established — legal status | Improves attribution and detection of synthetic campaign material | Metadata stripping, laundering, false labels and limited effect on truthful but manipulative dialogue | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Marker detection and retention after transformations; false-positive rate; platform ingestion coverage | Enforce now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 0–6 months | No direct link | Contextual capability link | 2026-08-11 | This mitigates provenance, not the interactive agency-transfer mechanisms measured by APE or manipulation efficacy tests. | Synthetic-output provenance and disclosure | [
"M-08",
"M-12",
"M-13",
"M-14",
"M-15"
] | [
"X-01"
] | [
"G-05",
"G-09"
] | [
"CLM-0069",
"CLM-0070",
"CLM-0071"
] | [
"CLM-0071"
] | [
"CLM-0069"
] | [
"CLM-0070"
] | [
"SRC-016"
] | [
"P01",
"P05",
"P09"
] | false | false | false | false | [] | [] | Provisional — legal status not claim-checked | research_preview |
I-030 | CF-003 | [
"P4-030"
] | Agent identity, least privilege and high-impact confirmation | Model / provider | Technical standard / product control | technical protocol, authorisation standard and deployment rule | NIST, standards bodies, agent providers and integrators | United States initiative; international recommendation | Voluntary / private | Operational voluntary | standards initiative implemented; controls under development | Operational | Give agents verifiable identities, scoped permissions, short-lived credentials and mandatory human confirmation for consequential actions | agentic model → delegated tools → communication or account action → citizen or institution → autonomous influence → agency transfer | Executive; Collective / institutional | Project — exploratory | Project-X | Indirect / mixed | Plausible hypothesis | Constrains agents from autonomously escalating persuasion campaigns, impersonating users or acting beyond delegated intent | Confirmation fatigue; compromised identities; standards fragmentation; agents may route around controls | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Unauthorised-action rate; permission scope; credential lifetime; confirmed versus automatic consequential actions | Implement now | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 0–6 months | Exploratory link | Contextual capability link | 2026-08-11 | Part 1 agentic demonstrations should log every tool permission and human checkpoint, not only final text outputs. | Agent authorization, least privilege and action control | [
"M-06",
"M-14",
"M-16"
] | [] | [
"G-03"
] | [
"CLM-0072",
"CLM-0073",
"CLM-0074"
] | [
"CLM-0074"
] | [
"CLM-0072"
] | [
"CLM-0073"
] | [
"SRC-002"
] | [
"P02"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-031 | CF-031 | [
"P4-031"
] | Long-horizon agency and dependency monitoring | Model / provider | Research / evaluation | post-deployment human-factors monitoring and periodic impact study | providers, independent researchers and regulators | international recommendation | Voluntary / private | Operational voluntary | recommended; methods nascent | Pilot | Audit persistent memory, repeated recommendations, emotional cues, reliance and preference drift over extended interactions | memory and personalisation → assistant provider → repeated intimate interaction → user → dependency and preference shaping → cumulative agency transfer | Evaluative; Decisional; Executive; Relational | Normative proposal | E2 | None — mechanism or proposal only | Plausible hypothesis | Targets the project’s central risk that manipulation becomes relational infrastructure rather than a single persuasive message | Intrusive observation; difficult causal inference; no settled agency metric; vulnerable users are hard to study ethically | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Preference and trust drift; reliance; reversal after disclosure; user control over memory; persistence after 7, 30 and 90 days | Pilot | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | Pilot — 6–18 months | No direct link | Contextual capability link | 2026-08-11 | APE is too short-horizon for this mechanism; Part 2 should explicitly mark it as a missing evaluation layer rather than overclaim coverage. | Long-horizon agency and dependency monitoring | [
"M-03",
"M-04",
"M-05",
"M-09",
"M-12"
] | [
"D-01"
] | [
"G-01",
"G-04",
"G-06",
"G-10",
"G-12",
"G-16"
] | [
"CLM-0075",
"CLM-0076",
"CLM-0077"
] | [
"CLM-0077"
] | [
"CLM-0075"
] | [
"CLM-0076"
] | [
"SRC-017"
] | [
"P03",
"P10"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-032 | CF-032 | [
"P4-032"
] | Threshold-triggered notification for GPAI systemic-risk classification | Model / provider | Governance / assurance | mandatory compute reporting | GPAI provider and AI Office | EU | Binding — limited scope | Applicable | Article 52 notification is threshold-triggered; no general advance notification of training runs. | Operational | Notify the Commission without delay and within two weeks when Article 51 high-impact capability is met or expected to be met; do not treat this as general pre-training notification. | planned capability scale-up → developer → regulator notice → early evaluation → deployment constraints before public exposure | Collective / institutional | Legal / operational precedent | None | None — legal existence only | Established — legal status | Gives regulators time to commission manipulation and agentic testing before launch | Compute is an imperfect proxy; efficiency gains and distributed training can evade thresholds; reporting burden | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Notification compliance; lead time before release; unreported threshold crossings; capability per FLOP | Enforce now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 0–6 months | No direct link | Contextual capability link | 2026-08-11 | Part 2 should show why notification must trigger capability testing rather than treating compute itself as manipulation evidence. | Threshold-triggered notification for GPAI systemic-risk classification | [
"M-14",
"M-15",
"M-16"
] | [] | [] | [
"CLM-0078",
"CLM-0079",
"CLM-0080"
] | [
"CLM-0080"
] | [
"CLM-0078"
] | [
"CLM-0079"
] | [
"SRC-007",
"SRC-111"
] | [
"P01"
] | false | true | false | false | [] | [] | Established — legal status | research_preview |
I-033 | CF-033 | [
"P4-033"
] | Regulator model-access, evaluation, mitigation and recall powers | Model / provider | Research / evaluation | supervisory and market-enforcement power | European AI Office | EU | Binding | Applicable | implemented | Operational | Allow the regulator to demand information, run evaluations, order mitigations and withdraw or recall a non-compliant model | provider-controlled evidence → independent regulator → enforceable finding → release or access change → reduced public exposure | Epistemic; Relational; Collective / institutional | Legal / operational precedent | None | None — legal existence only | Established — legal status | Turns safety reports and manipulation evaluations into potentially consequential oversight | Limited technical capacity; slow enforcement; confidentiality; recall is ineffective after open-weight proliferation | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Access latency; regulator evaluations; mitigation orders; compliance time; recall effectiveness | Enforce now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 0–6 months | No direct link | Contextual capability link | 2026-08-11 | The project can propose APE, MASK and election red-team suites as concrete tests available to the AI Office or national institutes. | Regulator model-access, evaluation, mitigation and recall powers | [
"M-02",
"M-05",
"M-12",
"M-13",
"M-14"
] | [] | [
"G-13"
] | [
"CLM-0081",
"CLM-0082",
"CLM-0083"
] | [
"CLM-0083"
] | [
"CLM-0081"
] | [
"CLM-0082"
] | [
"SRC-007"
] | [
"G0",
"P01"
] | false | false | false | false | [] | [] | Provisional — legal status not claim-checked | research_preview |
I-034 | CF-098 | [
"P4-034"
] | Certified AI management system as procurement or licensing condition | Model / provider | Procurement | ISO certification, procurement clause or licence condition | public procurers, regulators and accredited certification bodies | international recommendation | Voluntary / private | Operational voluntary | standard implemented; mandatory use recommended selectively | Operational | Require an independently audited AI management system with risk ownership, lifecycle controls, monitoring and continual improvement | provider organisation → governance processes → model lifecycle → downstream public systems → reduced unmanaged influence risk | Relational; Collective / institutional | Normative proposal | None | Indirect / mixed | Plausible hypothesis | Provides auditable organisational infrastructure for repeated evaluation and incident response | Process certification does not prove model safety; audit shopping; cost barriers for smaller providers | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Certification coverage; major nonconformities; corrective-action closure; manipulation-specific control maturity | Implement now | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 0–6 months | No direct link | Contextual capability link | 2026-08-11 | Certification should require evidence from the project’s tests; ISO compliance alone cannot substitute for APE, MASK or adversarial evaluation. | Public-sector AI registers, impact assessment and procurement | [
"M-05",
"M-12",
"M-14",
"M-16"
] | [
"S-01"
] | [
"G-11"
] | [
"CLM-0084",
"CLM-0085",
"CLM-0086"
] | [
"CLM-0086"
] | [
"CLM-0084"
] | [
"CLM-0085"
] | [
"SRC-018"
] | [
"P11"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-035 | CF-035 | [
"P4-035"
] | Democracy and agency impact assessment | Model / provider | Governance / assurance | rights-and-democracy impact assessment with stakeholder engagement | states, providers, public authorities and independent assessors | Council of Europe parties and EU | Non-binding official guidance | Operational voluntary | HUDERIA is non-binding; CETS 225 is not yet in force. | Pilot | Assess scale, scope, likelihood, reversibility and stakeholder impacts on autonomy, opinion formation and democratic processes | model and deployment design → controlling actor → influence environment → affected publics → agency transfer → democratic concentration | Collective / institutional | Legal / operational precedent | None | None — mechanism or proposal only | Plausible hypothesis | Captures autonomy and democratic harms omitted by catastrophic-risk frameworks | High-level principles; private-sector scope varies; self-assessment and weak remedies | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Assessments completed; stakeholder inclusion; high-risk findings; mitigation closure; residual democratic risk | Pilot | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | Pilot — 6–18 months | No direct link | Contextual capability link | 2026-08-11 | Use the project’s causal chain and agency-transfer construct to make HUDERIA operational for frontier-model manipulation. | Rights, democracy and agency impact assessment | [
"M-14",
"M-15",
"M-16"
] | [
"S-01"
] | [
"G-01",
"G-11",
"G-12",
"G-14"
] | [
"CLM-0087",
"CLM-0088",
"CLM-0089"
] | [
"CLM-0089"
] | [
"CLM-0087"
] | [
"CLM-0088"
] | [
"SRC-019"
] | [
"G0"
] | false | false | true | false | [] | [] | Plausible hypothesis | research_preview |
I-036 | CF-036 | [
"P4-036"
] | International frontier-risk reporting framework | Model / provider | Governance / assurance | international code and reporting template | OECD, G7 governments and advanced-AI developers | international | Voluntary / private | Operational voluntary | implemented | Operational | Standardise voluntary disclosures on risk identification, evaluation, incident management, security and transparency across providers | cross-border providers → comparable reporting → regulator and public scrutiny → convergent controls → reduced jurisdictional arbitrage | Collective / institutional | Normative proposal | None | Indirect / mixed | Plausible hypothesis | Creates comparable evidence across providers and jurisdictions without waiting for a global treaty | Self-reporting, selective disclosure, inconsistent interpretation and no sanction for poor performance | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Provider participation; field completeness; independent verification; manipulation-domain coverage; year-on-year improvement | Implement now | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 0–6 months | No direct link | Contextual capability link | 2026-08-11 | Add standard fields for APE, MASK, harmful-manipulation efficacy, open-weight modality and adversarial safeguard performance. | International frontier-risk reporting framework | [
"M-12",
"M-14",
"M-16"
] | [] | [] | [
"CLM-0090",
"CLM-0091",
"CLM-0092"
] | [
"CLM-0092"
] | [
"CLM-0090"
] | [
"CLM-0091"
] | [
"SRC-020"
] | [] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-037 | CF-037 | [
"P4-037"
] | Security assessment and algorithm filing for socially mobilising generative AI | Model / provider | Governance / assurance | administrative filing, security assessment and inspection | Cyberspace Administration of China and sector regulators | China | Binding | Applicable | implemented | Operational | Require security assessment, algorithm filing and regulatory cooperation for services with public-opinion or social-mobilisation capacity | generative capability → service provider → mass communication → population → opinion mobilisation → state-supervised deployment | Collective / institutional | Legal / operational precedent | None | None — legal existence only | Established — legal status | Demonstrates a direct model-service trigger based on influence and mobilisation capability | Can enable political censorship and state control rather than democratic agency; opaque assessment criteria | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Services assessed and filed; review time; enforcement actions; transparency and appeal availability | Monitor / shape | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 0–6 months | No direct link | Contextual capability link | 2026-08-11 | Useful as a structural precedent, not a normative model: democratic safeguards must prevent the intervention itself becoming concentrated manipulation power. | Security assessment and algorithm filing for socially mobilising generative AI | [
"M-14",
"M-16"
] | [] | [] | [
"CLM-0093",
"CLM-0094",
"CLM-0095"
] | [
"CLM-0095"
] | [
"CLM-0093"
] | [
"CLM-0094"
] | [
"SRC-021"
] | [] | false | false | false | false | [] | [] | Provisional — legal status not claim-checked | research_preview |
I-038 | CF-038 | [
"P4-038"
] | Enhanced review of cloud–frontier-model partnerships | Model / provider | Enforcement | merger review, market investigation and antitrust enforcement | competition authorities | United States, EU and allied jurisdictions | Binding | Applicable | implemented case-by-case | Operational | Scrutinise equity, exclusivity, control, information sharing, compute commitments and preferential distribution in AI partnerships | compute and capital concentration → cloud–model alliance → model and distribution control → dependent firms and publics → concentrated epistemic power | Epistemic; Relational; Collective / institutional | Legal / operational precedent | None | None — legal existence only | Established — legal status | Limits vertical structures that concentrate compute, models, distribution and safety evidence in the same actors | Partnerships also finance expensive models and safeguards; uncertain market definition; remedies may arrive late | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Exclusivity clauses; compute concentration; switching costs; model distribution share; merger remedies | Monitor / shape | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 0–6 months | No direct link | Contextual capability link | 2026-08-11 | Part 2 capability concentration should be read alongside ownership and cloud dependence, not merely as a model leaderboard. | AI market concentration and structural oversight | [
"M-02",
"M-05",
"M-09",
"M-13",
"M-14"
] | [
"S-01"
] | [] | [
"CLM-0096",
"CLM-0097",
"CLM-0098"
] | [
"CLM-0098"
] | [
"CLM-0096"
] | [
"CLM-0097"
] | [
"SRC-022"
] | [
"P12"
] | false | false | false | false | [] | [] | Provisional — legal status not claim-checked | research_preview |
I-039 | CF-039 | [
"P4-039"
] | Model and cloud portability, interoperability and anti-lock-in rules | Model / provider | Procurement | competition remedy, interoperability standard and procurement requirement | competition authorities, public procurers and standards bodies | EU and international recommendation | Proposed | Proposed / pending | Case-specific competition and procurement powers provide precedents; no general binding model-and-cloud portability duty is established by the cited policy brief. | Design-ready | Reduce egress barriers, support model switching and multi-provider interfaces, and prevent self-preferencing or coercive tying | platform dependency → dominant provider → default model and assistant → organisations and citizens → infrastructural reliance → agency concentration | Relational; Collective / institutional | Normative proposal | None | Indirect / mixed | Plausible hypothesis | Preserves contestability and reduces dependence on one provider’s model, safeguards and epistemic defaults | Interoperability can increase attack surfaces and lowest-common-denominator safety; technical quality differs | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Migration time and cost; egress charges; multi-homing rate; interface compatibility; market concentration | Monitor / shape | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 6–18 months | No direct link | Contextual capability link | 2026-08-11 | Open weights can improve contestability, but Part 1 shows why competition benefits cannot erase release-risk differences. | Interoperability, portability and exit | [
"M-05",
"M-13",
"M-14",
"M-15",
"M-16"
] | [
"S-01"
] | [
"G-10",
"G-11"
] | [
"CLM-0099",
"CLM-0100"
] | [
"CLM-0100"
] | [] | [
"CLM-0099"
] | [
"SRC-023"
] | [
"P12"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-040 | CF-040 | [
"P4-040"
] | Public-interest compute for independent evaluation and safer alternatives | Model / provider | Research / evaluation | public infrastructure and competitive grant allocation | governments, universities and AI safety institutes | California precedent; international recommendation | Voluntary / private | Operational voluntary | CalCompute planning mandated; other public programmes operational | Operational | Fund public compute capacity for evaluators, academia, civil society and public-interest model development | compute concentration → limited independent evidence → provider dominance → weak oversight → concentrated model and epistemic power | Epistemic; Relational; Collective / institutional | Normative proposal | None | Indirect / mixed | Plausible hypothesis | Makes external APE, MASK, agentic and open-weight evaluation technically feasible and supports plural model supply | Political allocation, duplication, security exposure, insufficient scale and capture by incumbents | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Independent evaluator GPU hours; models evaluated; organisations served; replication rate; cost per evaluation | Implement now | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 0–6 months | No direct link | Contextual capability link | 2026-08-11 | This is the infrastructure needed to keep the Part 1–2 evaluation suite independent, persistent and runnable as new open models appear. | Public-interest compute and AI infrastructure | [
"M-05",
"M-12",
"M-13",
"M-14",
"M-15"
] | [
"S-01"
] | [
"G-11",
"G-13"
] | [
"CLM-0101",
"CLM-0102",
"CLM-0103"
] | [
"CLM-0103"
] | [
"CLM-0101"
] | [
"CLM-0102"
] | [
"SRC-013"
] | [
"P12",
"P13"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-041 | CF-046 | [
"P4-041"
] | Open benchmark commons and standardised public evaluation registry | Model / provider | Research / evaluation | public evaluation platform, registry and reporting standard | AISI, NIST, academia and independent evaluators | international | Voluntary / private | Operational voluntary | partially implemented | Pilot | Publish versioned evaluation code, model metadata, scoring specifications, uncertainty and reproducible release-level results | opaque provider testing → public benchmark infrastructure → comparable evidence → procurement and regulatory decisions → reduced information asymmetry | Epistemic; Decisional; Collective / institutional | Normative proposal | E0 | None — mechanism or proposal only | Plausible hypothesis | Makes capability and safeguard trends independently auditable across closed, open and modified models | Benchmark gaming, contamination, evaluator monoculture and publication of dangerous artefacts | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Release coverage; reproducibility; benchmark freshness; private holdout share; inter-evaluator agreement | Pilot | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | Pilot — 6–18 months | No direct link | Contextual capability link | 2026-08-11 | The project should package APE, MASK and election red-team tasks as versioned Inspect-compatible evals while keeping dangerous cases access-controlled. | Independent evaluation and researcher access | [
"M-12",
"M-13",
"M-14",
"M-16"
] | [
"D-01"
] | [
"G-06",
"G-12",
"G-13"
] | [
"CLM-0104",
"CLM-0105",
"CLM-0106"
] | [
"CLM-0106"
] | [
"CLM-0104"
] | [
"CLM-0105"
] | [
"SRC-024"
] | [
"P13"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-042 | CF-042 | [
"P4-042",
"P4-085"
] | Election-specific systemic-risk assessment and mitigation for very large platforms and search engines | Platform / distribution | Law / regulation | Digital Services Act Articles 34-35 plus Commission election guidelines | VLOPs and VLOSEs; supervised by the European Commission and Digital Services Coordinators | European Union | Binding | Applicable | In force; guidelines are the current compliance benchmark | Operational | Require VLOPs and VLOSEs to assess election-specific risks from service design, ranking, advertising, generative AI, coordinated manipulation and local context; deploy mitigations before the electoral period, maintain an incident mechanism and publish a post-election review. | AI-enabled campaign or state actor → platform design and ranking → voter exposure and salience → belief, attention or trust change → agency transfer to campaign and platform → concentrated agenda-setting → electoral distortion. | Epistemic; Attentional; Evaluative; Decisional; Relational; Collective / institutional | Legal / operational precedent | None | None — legal existence only | Established — legal status | Moves governance upstream from takedowns to product design, staffing, language coverage, recommender controls and election readiness. | Covers only designated very large services; relies heavily on platform self-assessment; lacks common outcome benchmarks; can become process compliance without reducing exposure or agency loss. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Risk and mitigation coverage by vector and language; prevalence and reach of violating content; recommendation-driven exposure; incident time-to-detection and time-to-mitigation; post-election residual risk; audit findings. | Enforce now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 0–6 months | No direct link | No direct link | 2026-08-11 | The duties bind VLOPs/VLOSEs. The election guidelines interpret and operationalise those duties but are not a standalone law. | Platform election-risk assessment and implementation | [
"M-05",
"M-09",
"M-10",
"M-12",
"M-13"
] | [
"C-01",
"C-02",
"C-05",
"C-06"
] | [
"G-07",
"G-12"
] | [
"CLM-0107",
"CLM-0108",
"CLM-0109"
] | [
"CLM-0109"
] | [
"CLM-0107"
] | [
"CLM-0108"
] | [
"SRC-003",
"SRC-053"
] | [
"P06"
] | false | false | false | false | [] | [] | Provisional — legal status not claim-checked | research_preview |
I-043 | CF-043 | [
"P4-043"
] | Recommender-system transparency for online platforms | Platform / distribution | Governance / assurance | Digital Services Act Articles 27 and 38 | Online platforms and VLOPs; enforced by Digital Services Coordinators and the European Commission | European Union | Binding | Applicable | DSA Article 27 recommender transparency for online platforms; the Article 38 non-profiling option is separated into I-084. | Operational | Disclose in clear language the main recommender parameters and users' options to modify or influence them under DSA Article 27. The non-profiling option is coded separately under I-084. | Platform optimisation → personalised feed → repeated political exposure → attention and preference shaping → agency transfer to platform → concentrated control of the decision environment. | Epistemic; Attentional; Evaluative; Decisional; Relational | Legal / operational precedent | None | None — legal existence only | Established — legal status | Creates an exit from inferred-vulnerability targeting and gives users some control over how political attention is allocated. | Non-profiled does not mean neutral or safe; platforms can nudge users toward the default; transparency may be too abstract; chronological feeds can still be gamed by coordinated networks. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Default versus alternative feed prominence; opt-in and persistence rates; political-content concentration and source diversity; exposure inequality; user comprehension; differential manipulation prevalence by feed mode. | Enforce now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 0–6 months | No direct link | No direct link | 2026-08-11 | null | Recommender-system transparency for online platforms | [
"M-03",
"M-05",
"M-09",
"M-10",
"M-12"
] | [
"C-01",
"C-05",
"C-06"
] | [
"G-12"
] | [
"CLM-0110",
"CLM-0111",
"CLM-0112"
] | [
"CLM-0112"
] | [
"CLM-0110"
] | [
"CLM-0111"
] | [
"SRC-025"
] | [
"P06"
] | false | true | false | false | [] | [] | Established — legal status | research_preview |
I-044 | CF-044 | [
"P4-044",
"P4-083"
] | Ban on manipulative interface design and dark patterns | Cross-layer | Law / regulation | Digital Services Act Article 25 | Online platforms; national Digital Services Coordinators | European Union | Binding | Applicable | In force | Operational | Prohibit online-platform interfaces that deceive, manipulate, or materially distort users' ability to make free and informed decisions. | Platform or campaign-controlled interface → deceptive choice architecture → reduced reflection or coerced disclosure → behavioural or dependency change → agency transfer → platform power concentration. | Evaluative; Decisional; Relational; Collective / institutional | Legal / operational precedent | E1 | Indirect / mixed | Strong inference | First-page button prominence can change consent acceptance; whether a legal ban improves free and informed choice, data disclosure, political behaviour, or agency is untested. | Boundary between persuasion and manipulation is context-sensitive; enforcement may focus on commercial UX and miss political onboarding, consent flows, notification pressure or agent defaults. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Completion and consent asymmetries; reversal or opt-out friction; comprehension; alignment with stated preferences; actual data disclosure; enforcement findings. | Enforce now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 0–6 months | No direct link | No direct link | 2026-08-13 | A small interface experiment supports a bounded behavioural endpoint, not the effect of DSA enforcement or a general dark-pattern ban. | Dark patterns and unfair personalization | [
"M-05",
"M-06",
"M-14",
"M-15",
"M-16"
] | [
"C-01",
"C-06"
] | [
"G-12"
] | [
"CLM-0113",
"CLM-0114",
"CLM-0115"
] | [
"CLM-0115"
] | [
"CLM-0113"
] | [
"CLM-0114"
] | [
"SRC-025",
"SRC-026",
"SRC-115"
] | [
"P06"
] | true | true | false | true | [
"Partially supported with different evidence"
] | [
"Rewrite claim and downgrade implementation to Strong inference"
] | Strong inference | research_preview |
I-045 | CF-045 | [
"P4-045"
] | Online-platform ad transparency and sensitive-data targeting limits | Platform / distribution | Law / regulation | Digital Services Act Articles 26 and 39 | Online platforms and VLOPs | European Union | Binding | Applicable | DSA Article 26 ad transparency and sensitive-data targeting limits for online platforms; Article 39 repositories are VLOP/VLOSE-only. | Operational | Identify advertisements and sponsors, disclose key targeting parameters, and prohibit ad profiling using special-category data under DSA Article 26. The DSA Article 39 repository is VLOP/VLOSE-only; the broader political-ad repository is coded under P4-049. | Campaign or proxy → opaque paid targeting → selected vulnerable voter → preference or turnout change → agency transfer to campaign and ad platform → unequal political power. | Evaluative; Decisional; Collective / institutional | Legal / operational precedent | None | None — legal existence only | Established — legal status | Makes paid influence more observable and reduces direct use of sensitive traits for personalised persuasion. | Issue ads, influencers and organic coordination may evade classification; inferred proxies can reproduce sensitive targeting; repositories can be incomplete or hard to query. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Ad coverage and missingness; sponsor verification; targeting-field completeness; repository latency; spend and reach by audience; rate of proxy-sensitive segments; researcher usability. | Enforce now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 0–6 months | No direct link | No direct link | 2026-08-11 | null | Political-ad transparency, targeting and repositories | [
"M-03",
"M-09",
"M-14",
"M-16"
] | [
"C-01",
"C-05",
"C-06"
] | [
"G-07",
"G-12"
] | [
"CLM-0116",
"CLM-0117",
"CLM-0118"
] | [
"CLM-0118"
] | [
"CLM-0116"
] | [
"CLM-0117"
] | [
"SRC-025"
] | [
"P06",
"P07"
] | false | true | false | false | [] | [] | Established — legal status | research_preview |
I-046 | CF-046 | [
"P4-046",
"P4-093"
] | Vetted researcher access to non-public platform data | Institutional / structural | Research / evaluation | Digital Services Act Article 40 and 2025 delegated act on data access | Digital Services Coordinators, European Commission, VLOPs/VLOSEs and vetted researchers | European Union | Binding — limited scope | Applicable | Conditional Article 40 data access for designated VLOPs/VLOSEs, subject to reasoned requests and safeguards. | Operational | Allow qualified independent researchers to request necessary VLOP and VLOSE data to identify systemic risks and evaluate mitigation, through Digital Services Coordinator vetting and a common portal. | Opaque platform data → weak external detection → unchecked optimisation and influence → hidden agency transfer; researcher access interrupts this by making exposure, coordination and mitigation auditable. | Relational; Collective / institutional | Legal / operational precedent | None | None — legal existence only | Established — legal status | Enables measurement of recommender exposure, cross-account coordination and whether safeguards work, closing the central evidence gap in Part 3. | Slow approvals can miss elections; privacy and trade-secret objections can narrow datasets; qualified-researcher criteria exclude journalists and smaller civil society groups; platform data schemas can frustrate replication. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Application and approval times; request scope granted; dataset completeness; reproducibility; number of election studies; disclosure disputes; time from finding to mitigation or enforcement. | Enforce now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 0–6 months | No direct link | No direct link | 2026-08-11 | null | Independent evaluation and researcher access | [
"M-05",
"M-12",
"M-14",
"M-16"
] | [
"C-01",
"C-06"
] | [
"G-12",
"G-13"
] | [
"CLM-0119",
"CLM-0120",
"CLM-0121"
] | [
"CLM-0121"
] | [
"CLM-0119"
] | [
"CLM-0120"
] | [
"SRC-027",
"SRC-059"
] | [
"P06",
"P13"
] | false | false | false | false | [] | [] | Provisional — legal status not claim-checked | research_preview |
I-047 | CF-047 | [
"P4-047"
] | Annual independent audits of systemic-risk and code commitments | Cross-layer | Governance / assurance | Digital Services Act Article 37 and Article 45 code framework | Independent audit organisations, platforms and European Commission | European Union | Mixed | Applicable | In force; Code commitments auditable from 2025-07-01 | Operational | Require annual independent audits of VLOP/VLOSE compliance, including risk controls and, for adherents, auditable Code of Conduct on Disinformation commitments. | Platform self-governance → unverified safeguards → persistent manipulation capacity → agency transfer; external assurance raises the cost of superficial controls. | Epistemic; Evaluative; Relational | Legal / operational precedent | None | None — legal existence only | Established — legal status | Creates recurring scrutiny of whether claimed election safeguards are implemented and effective. | Auditor dependence, narrow assurance scopes, confidential evidence, lagging annual cadence and checklist behaviour can conceal election-period failures. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Qualified and adverse findings; remediation closure time; repeat findings; audit coverage of local languages and recommenders; public disclosure quality; enforcement following audit failures. | Enforce now | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 0–6 months | No direct link | No direct link | 2026-08-11 | Annual Article 37 audits are binding for covered services; joining the Article 45 Code remains voluntary. | Annual independent audits of systemic-risk and code commitments | [
"M-02",
"M-04",
"M-05",
"M-12",
"M-13"
] | [
"C-01"
] | [] | [
"CLM-0122",
"CLM-0123",
"CLM-0124"
] | [
"CLM-0124"
] | [
"CLM-0122"
] | [
"CLM-0123"
] | [
"SRC-028",
"SRC-086"
] | [
"P06"
] | false | false | false | false | [] | [] | Provisional — legal status not claim-checked | research_preview |
I-048 | CF-042 | [
"P4-048"
] | Pre-election stress tests, readiness dialogues and regulator election toolkits | Cross-layer | Coordination / incident response | DSA Elections Toolkit and voluntary readiness exercises under the Article 35 framework | European Commission, Digital Services Coordinators, national election authorities, platforms and civil society | EU and partner countries, including Moldova | Voluntary / private | Operational voluntary | Operational best practice; used in EU elections and Moldova | Operational | Run scenario exercises with platforms, election bodies, regulators, security actors and civil society; test escalation paths, local-language capacity and platform responses before voting. | Emerging AI-enabled incident → fragmented detection and authority → delayed response → rapid belief or turnout effects → temporary agency seizure; stress tests pre-wire coordination. | Epistemic; Executive; Collective / institutional | Normative proposal | None | Indirect / mixed | Plausible hypothesis | Reduces coordination latency and exposes gaps before a late-breaking deepfake, coordinated network or false voting claim appears. | Scripted exercises may not test adversarial evasion; voluntary platform participation; threat scenarios can become stale; unclear thresholds for public attribution or takedown. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Exercise gap closure; escalation and decision times; contact availability; platform response consistency; red-team success rate; coverage of private messaging and small platforms. | Implement now | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 0–6 months | No direct link | No direct link | 2026-08-11 | null | Platform election-risk assessment and implementation | [
"M-12",
"M-13",
"M-14",
"M-16"
] | [
"C-01",
"C-02",
"C-05"
] | [
"G-12"
] | [
"CLM-0125",
"CLM-0126",
"CLM-0127"
] | [
"CLM-0127"
] | [
"CLM-0125"
] | [
"CLM-0126"
] | [
"SRC-029"
] | [
"P06"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-049 | CF-045 | [
"P4-049"
] | Mandatory labels, sponsor notices and an EU repository for political advertising | Platform / distribution | Law / regulation | Regulation (EU) 2024/900, especially Articles 11-15 | Sponsors, political-ad service providers, publishers, national competent authorities and European Commission | European Union | Binding | Applicable | Applicable since 2025-10-10 | Operational | Require each paid or targeted political ad to be labelled and linked to a notice naming the sponsor, election, remuneration, spend and targeting; transmit online ads to a European repository and accelerate complaint handling near elections. | Sponsor or proxy → covert paid communication → voter → hidden persuasion → agency transfer to sponsor → concentrated political influence; disclosure restores source contestability. | Epistemic; Evaluative; Decisional; Collective / institutional | Legal / operational precedent | None | None — legal existence only | Established — legal status | Makes who paid, how much and why a voter was reached visible to voters, regulators and researchers. | Platforms may exit political advertising, shifting influence to organic creators, messaging apps and foreign intermediaries; sponsor declarations can be false; repository implementation can lag. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Share of ads with complete notices; sponsor-verification failures; repository latency; notification resolution within 48 hours in the final month; undisclosed paid influence detected outside formal ads. | Enforce now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 6–18 months | No direct link | No direct link | 2026-08-11 | null | Political-ad transparency, targeting and repositories | [
"M-03",
"M-09",
"M-11",
"M-13",
"M-14"
] | [
"C-06"
] | [
"G-07",
"G-14"
] | [
"CLM-0128",
"CLM-0129",
"CLM-0130"
] | [
"CLM-0130"
] | [
"CLM-0128"
] | [
"CLM-0129"
] | [
"SRC-030"
] | [
"P07"
] | false | true | false | false | [] | [] | Established — legal status | research_preview |
I-050 | CF-045 | [
"P4-050"
] | Restrict personal-data political-ad targeting and prohibit special-category profiling | Platform / distribution | Governance / assurance | Regulation (EU) 2024/900 Articles 18-19 | Campaigns, controllers, ad-tech providers, publishers and data protection authorities | European Union | Binding | Applicable | Regulation 2024/900 restricts personal-data political targeting and prohibits special-category profiling; it is not a blanket microtargeting ban. | Operational | Permit personal-data-based political targeting only when data were collected from the person and separate explicit consent was obtained; prohibit profiling using special-category data and targeting known near-voting-age minors. | Campaign data broker → vulnerability inference and microtargeting → individual voter → tailored pressure or preference shaping → agency transfer to campaign → asymmetric democratic power. | Evaluative; Decisional; Collective / institutional | Legal / operational precedent | None | None — legal existence only | Established — legal status | Cuts the Cambridge Analytica pathway from intimate or political data to personalised influence without meaningful voter consent. | Contextual and lookalike targeting can act as proxies; consent fatigue and bundled interfaces undermine autonomy; political actors can move targeting in-house or into messaging lists. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Valid-consent rate; use of inferred proxies; audience-segment size; sensitive-data violations; targeting explanations understood; proportion of political reach occurring outside regulated advertising. | Enforce now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 6–18 months | No direct link | No direct link | 2026-08-11 | null | Political-ad transparency, targeting and repositories | [
"M-03",
"M-09",
"M-11",
"M-14",
"M-16"
] | [
"C-06"
] | [
"G-07",
"G-14"
] | [
"CLM-0131",
"CLM-0132",
"CLM-0133"
] | [
"CLM-0133"
] | [
"CLM-0131"
] | [
"CLM-0132"
] | [
"SRC-030",
"SRC-031"
] | [
"P07"
] | false | true | false | false | [] | [] | Established — legal status | research_preview |
I-051 | CF-045 | [
"P4-051"
] | Three-month pre-election ban on political-ad services for third-country sponsors | Platform / distribution | Law / regulation | Regulation (EU) 2024/900 | Political-ad service providers, publishers and competent national authorities | European Union | Binding | Applicable | Applicable since 2025-10-10 | Operational | Prohibit political advertising services for sponsors outside the EU during the three months before an election or referendum in a Member State. | Foreign state or proxy → paid distribution → domestic electorate → agenda or trust change → agency transfer abroad → external concentration of electoral influence. | Evaluative; Relational; Collective / institutional | Legal / operational precedent | None | None — legal existence only | Established — legal status | Raises the cost of overt foreign paid influence during the highest-risk period. | Shell entities, domestic agents, influencers, issue advertising and unpaid coordinated content can evade sponsor-location rules; a three-month window misses long-horizon preference shaping. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Rejected third-country purchases; beneficial-owner verification; proxy sponsorship cases; foreign-linked organic reach; spending displacement before the window. | Enforce now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 6–18 months | No direct link | No direct link | 2026-08-11 | null | Political-ad transparency, targeting and repositories | [
"M-03",
"M-05",
"M-06",
"M-09",
"M-10"
] | [
"C-06"
] | [
"G-07",
"G-14"
] | [
"CLM-0134",
"CLM-0135",
"CLM-0136"
] | [
"CLM-0136"
] | [
"CLM-0134"
] | [
"CLM-0135"
] | [
"SRC-030",
"SRC-031"
] | [
"P07"
] | false | true | false | false | [] | [] | Established — legal status | research_preview |
I-052 | CF-029 | [
"P4-052"
] | Machine-readable marking of AI-generated content and visible deepfake disclosure | Platform / distribution | Law / regulation | EU AI Act Article 50 and Code of Practice on Transparency of AI-generated Content | AI providers and deployers; market-surveillance authorities and AI Office | European Union | Binding | Applicable | Binding Article 50 duties from 2026-08-02; voluntary code is an implementation route. Limited transition to 2026-12-02 for Article 50(2) pre-existing generators. | Operational | Require providers to mark synthetic outputs in machine-readable form and deployers to disclose deepfakes and certain AI-generated public-interest text; use an EU code and common icons to standardise compliance. | Generative model or campaign → synthetic impersonation → voter → false source belief or trust shock → agency transfer to fabricator → electoral harm; provenance and disclosure restore source knowledge. | Epistemic; Decisional; Relational; Collective / institutional | Legal / operational precedent | None | None — legal existence only | Established — legal status | Supports cross-platform detection and visible disclosure of synthetic candidate or election content. | Metadata can be stripped; open models and foreign actors may not comply; absence of a mark is not proof of authenticity; labels can create disclosure fatigue or a liar's dividend. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Marking coverage by provider and modality; persistence after editing and re-upload; detector precision and recall; label visibility and comprehension; share of viral synthetic incidents carrying valid provenance. | Enforce now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | Applicable now; limited transition to 2026-12-02 | No direct link | No direct link | 2026-08-11 | null | Synthetic-output provenance and disclosure | [
"M-05",
"M-08",
"M-09",
"M-13",
"M-14"
] | [
"C-03",
"C-04",
"C-05",
"X-01"
] | [
"G-09",
"G-12",
"G-14"
] | [
"CLM-0137",
"CLM-0138",
"CLM-0139"
] | [
"CLM-0139"
] | [
"CLM-0137"
] | [
"CLM-0138"
] | [
"SRC-016",
"SRC-111"
] | [
"P01",
"P09"
] | false | true | false | false | [] | [] | Established — legal status | research_preview |
I-053 | CF-053 | [
"P4-053"
] | Auditable platform commitments on demonetisation, bots, fake accounts, impersonation, deepfakes and recommender integrity | Platform / distribution | Governance / assurance | EU Code of Conduct on Disinformation integrated under DSA Article 45 | Adhering platforms, search engines, advertising actors, fact-checkers and civil society; overseen by Commission and Digital Services Board | European Union | Voluntary / private | Operational voluntary | Integrated into DSA framework in 2025; commitments auditable since 2025-07-01; first co-regulatory reports published 2026-03-24 | Operational | Commit signatories to cut disinformation revenue, label and archive political ads, detect fake accounts and bot amplification, address impersonation and malicious deepfakes, support fact-checkers, improve recommender transparency and report service-level indicators. | Malicious actor → coordinated accounts and monetised amplification → platform audience → repeated exposure and trust erosion → agency transfer to network controller → concentrated narrative power. | Epistemic; Attentional; Relational | Normative proposal | None | Indirect / mixed | Plausible hypothesis | Targets distribution infrastructure and coordinated behaviour rather than adjudicating every political claim. | Selective commitments, inconsistent enforcement, opaque prevalence denominators, migration to non-signatories and difficulty separating authentic mobilisation from coordination. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | CIB networks disrupted; fake-account prevalence; coordinated reach before removal; demonetised revenue; recommender exposure reduction; language coverage; independent audit exceptions. | Implement now | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 6–18 months | No direct link | No direct link | 2026-08-11 | null | Auditable platform commitments on demonetisation, bots, fake accounts, impersonation, deepfakes and recommender integrity | [
"M-03",
"M-05",
"M-08",
"M-09",
"M-10"
] | [
"C-01",
"C-02",
"C-05",
"C-06"
] | [] | [
"CLM-0140",
"CLM-0141",
"CLM-0142"
] | [
"CLM-0142"
] | [
"CLM-0140"
] | [
"CLM-0141"
] | [
"SRC-032"
] | [
"P06"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-054 | CF-054 | [
"P4-054"
] | Time-bound election Rapid Response System for platform escalation | Cross-layer | Coordination / incident response | Code of Conduct on Disinformation election cooperation and Rapid Response System | EDMO, fact-checkers, civil society signatories and participating platforms | European Union and election-specific deployments | Voluntary / private | Operational voluntary | Operational since the 2024 European Parliament election and reused in later elections | Operational | Allow authorised non-platform signatories, fact-checkers and civil society to rapidly flag severe, time-sensitive content, accounts or trends and discuss response with platforms under their policies. | Late-breaking synthetic or coordinated incident → rapid spread → no time for ordinary review → belief, turnout or legitimacy shock → temporary agency transfer; an escalation lane compresses response time. | Epistemic; Collective / institutional | Normative proposal | None | Indirect / mixed | Plausible hypothesis | Creates a trusted, fast channel for the final hours when ordinary notice systems are too slow. | Platform policy still controls action; privileged flaggers may miss local or minority-language incidents; false positives and government pressure can chill speech; no common service-level obligation. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Acknowledgement and disposition time; reach accrued before action; escalation acceptance rate; false-positive and appeal outcomes; coverage by country, language, platform and modality. | Implement now | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 0–6 months | No direct link | No direct link | 2026-08-11 | null | Election rapid response and escalation | [
"M-08",
"M-10",
"M-12",
"M-13",
"M-14"
] | [
"C-01",
"C-02",
"C-05"
] | [
"G-08",
"G-12"
] | [
"CLM-0143",
"CLM-0144",
"CLM-0145"
] | [
"CLM-0145"
] | [
"CLM-0143"
] | [
"CLM-0144"
] | [
"SRC-033"
] | [
"P06",
"P13"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-055 | CF-055 | [
"P4-055"
] | European Centre for Democratic Resilience and reinforced election coordination | Institutional / structural | Coordination / incident response | European Democracy Shield institutional mechanism | European Commission, participating Member States, candidate countries, EU bodies and stakeholder platform | European Union and participating candidate countries | Voluntary / private | Operational voluntary | Launched 2026-02-24; operational design still maturing | Operational | Pool Member State, EU and civil-society expertise to anticipate, detect and respond to FIMI and disinformation; connect election networks, DSA data access, political-ad data and operational response. | Cross-border actor → fragmented national signals → delayed attribution and response → accumulating trust and agenda effects → agency transfer to hostile actor; pooled awareness reverses the asymmetry. | Epistemic; Relational; Collective / institutional | Normative proposal | None | Indirect / mixed | Plausible hypothesis | Addresses cross-platform and cross-border coordination gaps and can turn dispersed signals into a common operational picture. | Mandate overlap, politicised attribution, intelligence-to-public-evidence gaps, centralisation without accountability and slow information sharing. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Shared alerts and lead time; Member State participation; joint analyses; cross-platform incident resolution; public attribution quality; exercise and after-action improvements. | Monitor / shape | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 0–6 months | No direct link | No direct link | 2026-08-11 | null | European Centre for Democratic Resilience and reinforced election coordination | [
"M-05",
"M-10",
"M-12",
"M-13",
"M-14"
] | [
"C-01",
"C-02"
] | [] | [
"CLM-0146",
"CLM-0147",
"CLM-0148"
] | [
"CLM-0148"
] | [
"CLM-0146"
] | [
"CLM-0147"
] | [
"SRC-034"
] | [
"P13"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-056 | CF-056 | [
"P4-056"
] | Mandatory digital imprints on paid political material and specified organic campaign material | Electoral operations | Law / regulation | Elections Act 2022 Part 6 and Electoral Commission statutory guidance | Campaigners, candidates, parties, police and Electoral Commission | United Kingdom | Binding | Applicable | In force since November 2023; guidance updated in 2026 | Operational | Require covered digital material, including social posts, online ads, podcasts and publicly distributed messaging-app content, to state who promoted and on whose behalf it was published. | Campaign or third party → unattributed digital communication → voter → mistaken source trust → agency transfer to hidden promoter → opaque political power. | Epistemic; Decisional; Relational; Collective / institutional | Legal / operational precedent | None | None — legal existence only | Established — legal status | Preserves contestability by letting voters and regulators identify the responsible campaign actor. | Organic material by unregistered actors has gaps; private messages and cross-border actors are hard to enforce; an imprint does not disclose targeting, spend, AI use or beneficial funder. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Imprint compliance and readability; promoter traceability; enforcement cases; unattributed reach; cross-platform persistence; proportion of campaign communication outside scope. | Enforce now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 0–6 months | No direct link | No direct link | 2026-08-11 | null | Mandatory digital imprints on paid political material and specified organic campaign material | [
"M-03",
"M-05",
"M-11",
"M-13",
"M-14"
] | [
"C-06"
] | [
"G-07"
] | [
"CLM-0149",
"CLM-0150",
"CLM-0151"
] | [
"CLM-0151"
] | [
"CLM-0149"
] | [
"CLM-0150"
] | [
"SRC-035"
] | [
"P07"
] | false | false | false | false | [] | [] | Provisional — legal status not claim-checked | research_preview |
I-057 | CF-057 | [
"P4-057"
] | Systemic platform duties for criminal foreign-interference content | Cross-layer | Law / regulation | National Security Act 2023 plus Online Safety Act 2023 | Online services and Ofcom, with police and national-security bodies | United Kingdom | Binding | Applicable | Illegal-content duties in force from 2025-03-17 | Operational | Treat the National Security Act foreign-interference offence as a priority offence, requiring in-scope services to assess risk, prevent users encountering illegal material and minimise its availability; Ofcom can impose major fines and disruption measures. | Foreign power or proxy → covert online conduct → UK voters and institutions → trust, behaviour or legitimacy change → agency transfer abroad → democratic harm. | Decisional; Relational; Collective / institutional | Legal / operational precedent | None | None — legal existence only | Established — legal status | Creates a systemic duty to act on covert hostile-state operations rather than relying only on voluntary moderation. | Most domestic misinformation and lawful manipulative persuasion remain outside scope; attribution to a foreign power is difficult; encryption and cross-border evidence constrain action; overreach risks political surveillance. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Foreign-interference risk assessments; detected networks; time-to-disruption; Ofcom enforcement; successful prosecutions; reach before removal; false attribution and appeal outcomes. | Enforce now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 0–6 months | No direct link | No direct link | 2026-08-11 | null | Systemic platform duties for criminal foreign-interference content | [
"M-05",
"M-09",
"M-12",
"M-14",
"M-16"
] | [] | [
"G-08"
] | [
"CLM-0152",
"CLM-0153",
"CLM-0154"
] | [
"CLM-0154"
] | [
"CLM-0152"
] | [
"CLM-0153"
] | [
"SRC-036"
] | [] | false | false | false | false | [] | [] | Provisional — legal status not claim-checked | research_preview |
I-058 | CF-058 | [
"P4-058"
] | Election-authority deepfake detection and impact-monitoring pilot | Cross-layer | Law / regulation | Electoral Commission operational pilot with the Home Office Accelerated Capability Environment | UK Electoral Commission and ACE, with parties, candidates, platforms and police | Great Britain | Voluntary / private | Pilot | Pilot ran around the May 2026 elections; full findings due autumn 2026 | Pilot | Monitor online audio and video for false candidate depictions or election-process claims, track reach, coordinate corrections or requested takedowns, and refer serious content to police or other bodies. | AI generator → candidate or authority impersonation → voter → false belief or suppressed participation → agency transfer to fabricator; detection and authoritative correction interrupt spread. | Epistemic; Decisional; Collective / institutional | Normative proposal | E0 | None — mechanism or proposal only | Plausible hypothesis | Gives the election authority an early-warning picture and a route to authenticate candidate or process claims. | Detectors are brittle and can generate false positives; monitoring may miss closed messaging and low-resource languages; requests lack compulsory force; public alarms can amplify a fake. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Precision and recall against adjudicated samples; time-to-detection; reach before correction; candidate response time; correction penetration; referrals and platform outcomes. | Pilot | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | Pilot — 6–18 months | No direct link | No direct link | 2026-08-11 | null | Election-authority deepfake detection and impact-monitoring pilot | [
"M-08",
"M-09",
"M-11",
"M-13",
"M-14"
] | [
"C-03",
"C-04",
"X-01"
] | [
"G-09",
"G-12",
"G-13"
] | [
"CLM-0155",
"CLM-0156",
"CLM-0157"
] | [
"CLM-0157"
] | [
"CLM-0155"
] | [
"CLM-0156"
] | [
"SRC-037"
] | [
"P09"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-059 | CF-045 | [
"P4-059"
] | Statutory political-ad libraries and regulator/researcher access to platform exposure data | Cross-layer | Research / evaluation | Electoral Commission reform recommendation | Would require UK Parliament or government, platforms, Electoral Commission, Ofcom and ICO | United Kingdom | Proposed | Proposed / pending | Proposed; not a general statutory requirement as of 2026-08-11 | Design-ready | Require every platform carrying political ads to maintain a comprehensive library with sponsor, targeting, actual reach and spend, and create meaningful data access for regulators and independent researchers. | Opaque platform ads and ranking → unobservable targeting and amplification → voter influence → agency transfer → no accountability; access makes the pathway measurable. | Attentional; Evaluative; Decisional; Relational | Normative proposal | None | Indirect / mixed | Plausible hypothesis | Would close the UK's reliance on voluntary, inconsistent libraries and make algorithmic political reach auditable. | Privacy and trade-secret limits; platform exit from ads; organic influence remains hidden; data can arrive too late for election response. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Platform coverage; field completeness; API availability; actual versus reported reach; researcher access times; detected foreign or unlawful spending. | Research / hold | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 6–18 months | No direct link | No direct link | 2026-08-11 | null | Political-ad transparency, targeting and repositories | [
"M-03",
"M-05",
"M-09",
"M-12",
"M-14"
] | [
"C-06"
] | [
"G-07"
] | [
"CLM-0158",
"CLM-0159"
] | [
"CLM-0159"
] | [] | [
"CLM-0158"
] | [
"SRC-038"
] | [
"P07"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-060 | CF-052 | [
"P4-060"
] | Treat AI-cloned voices in robocalls as artificial voices requiring consent | Cross-layer | Policy / organizational control | FCC Declaratory Ruling under the TCPA | FCC, state attorneys general and telecom providers | United States | Binding | Applicable | In force; applied in the New Hampshire robocall matter | Operational | Apply TCPA consent and identification rules to AI-generated or cloned voices classified as artificial or prerecorded voices, subject to statutory exemptions. | Campaign operative → cloned candidate voice → mass calls → false instruction or turnout suppression → agency transfer to caller → electoral harm. | Multiple / context-dependent | Legal / operational precedent | None | None — legal existence only | Established — legal status | Uses mature robocall law to impose consent and enforcement costs on a high-risk impersonation vector. | Caller-ID spoofing, offshore operators, peer-to-peer messages and non-voice synthetic content can evade; consent exceptions and enforcement latency remain. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Complaint volume; blocked calls; trace-back success; time-to-enforcement; penalties collected; repeat offending; estimated voter reach. | Enforce now | Enforce legal scope; measure implementation and rights costs separately from legal existence. | 0–6 months | No direct link | No direct link | 2026-08-11 | This is not a ban on every AI political message: prior express consent and exemptions depend on call purpose and context. | Synthetic impersonation and authenticity controls | [
"M-05",
"M-08",
"M-16"
] | [
"C-03",
"X-01"
] | [] | [
"CLM-0160",
"CLM-0161",
"CLM-0162"
] | [
"CLM-0162"
] | [
"CLM-0160"
] | [
"CLM-0161"
] | [
"SRC-039"
] | [
"P09"
] | false | false | false | false | [] | [] | Provisional — legal status not claim-checked | research_preview |
I-061 | CF-052 | [
"P4-061"
] | Apply federal fraudulent-misrepresentation rules to AI that falsely claims campaign authority | Electoral operations | Law / regulation | FEC interpretive rule under 52 U.S.C. §30124 and 11 C.F.R. §110.16 | Federal Election Commission | United States federal elections | Binding | Partial / verify | Interpretive rule adopted; broader AI rulemaking declined in 2024 | Partial / uneven | Clarify that existing law can cover AI communications where a candidate or agent falsely purports to speak, act or fundraise on behalf of another candidate or party; it does not generally prohibit false depictions with a truthful disclaimer. | Candidate or agent → AI impersonation of rival campaign authority → voter or donor → source deception → agency transfer to impersonator → electoral or financial harm. | Epistemic; Decisional; Executive | Legal / operational precedent | None | None — legal existence only | Established — legal status | Protects authentic campaign authority and donations from a limited class of AI impersonation. | Leaves most candidate deepfakes, lies, issue ads and third-party content outside the rule; FEC deadlock and slow enforcement reduce real-time value. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Complaints and matters under review; time to disposition; proven authority impersonations; voter or donor losses; repeat incidents. | Monitor / shape | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 0–6 months | No direct link | Contextual capability link | 2026-08-11 | The FEC interpretation covers two narrow fraudulent-misrepresentation settings involving purported campaign authority; it is not a federal deepfake ban. | Synthetic impersonation and authenticity controls | [
"M-06",
"M-08",
"M-13",
"M-16"
] | [
"C-03",
"X-01"
] | [] | [
"CLM-0163",
"CLM-0164",
"CLM-0165"
] | [
"CLM-0165"
] | [
"CLM-0163"
] | [
"CLM-0164"
] | [
"SRC-040"
] | [
"P09"
] | false | false | false | false | [] | [] | Provisional — legal status not claim-checked | research_preview |
I-062 | CF-052 | [
"P4-062"
] | On-air and political-file disclosure of AI-generated content in broadcast political ads | Platform / distribution | Law / regulation | FCC Notice of Proposed Rulemaking, proceeding 24-211 | Would be implemented by FCC-regulated broadcasters, cable and satellite entities | United States | Proposed | Proposed / pending | Proposed in 2024; no final rule identified as of 2026-08-11 | Design-ready | Require radio and television political ads using AI-generated content to carry an on-air notice and a written disclosure in the station's political file. | Campaign → synthetic broadcast ad → mass audience → false authenticity belief → agency transfer to advertiser → electoral influence. | Epistemic; Evaluative | Normative proposal | None | Indirect / mixed | Plausible hypothesis | Would make synthetic content visible in legacy mass media and create an inspectable record. | FCC jurisdiction largely excludes online and streaming ads; broad definitions may over-label routine editing; disclosure may not neutralise deception. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | If adopted: disclosure compliance, political-file completeness, audience comprehension, complaints and cross-channel coverage gaps. | Research / hold | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 6–18 months | No direct link | No direct link | 2026-08-11 | The NPRM concerns radio and television political ads and political-file disclosure; it is not a final rule or a cross-platform online standard. | Synthetic impersonation and authenticity controls | [
"M-03",
"M-08",
"M-09",
"M-13",
"M-16"
] | [
"C-03",
"X-01"
] | [] | [
"CLM-0166",
"CLM-0167"
] | [
"CLM-0167"
] | [] | [
"CLM-0166"
] | [] | [
"P09"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-063 | CF-052 | [
"P4-063"
] | Platform duty to remove or label materially deceptive election deepfakes during a defined election window | Platform / distribution | Law / regulation | California Defending Democracy from Deepfake Deception Act, AB 2655 | Large platforms and California enforcement authorities | California, United States | Binding — limited scope | Contested / enjoined | California AB 2655 was enacted but permanently enjoined as applied to the successful plaintiffs; appeal remained pending in 2026. | Partial / uneven | California AB 2655 required large platforms to block specified deceptive election content or label it, provide reporting channels and respond within short timeframes. | AI creator → viral candidate or election deepfake → voter → false belief → agency transfer to creator → electoral harm; platform action attempts to stop distribution. | Epistemic; Decisional; Collective / institutional | Legal / operational precedent | None | Indirect / mixed | Established — legal status | The intended effect was rapid reduction of deceptive synthetic reach; the actual contribution is a warning that broad platform-liability designs can collapse under intermediary-liability and speech law. | Over-removal of satire and political speech, vague deception thresholds, prior-restraint concerns, Section 230 pre-emption and strategic reporting abuse. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | If redesigned: adjudicated precision, removal latency, restored-content rate, satire/parody false positives, reach prevented, litigation survival. | Monitor / shape | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 6–18 months | No direct link | No direct link | 2026-08-11 | null | Synthetic impersonation and authenticity controls | [
"M-08",
"M-09",
"M-13",
"M-14",
"M-16"
] | [
"C-03",
"C-04",
"X-01"
] | [
"G-09",
"G-14"
] | [
"CLM-0168",
"CLM-0169",
"CLM-0320"
] | [
"CLM-0169"
] | [
"CLM-0320"
] | [
"CLM-0168"
] | [
"SRC-042"
] | [
"P09"
] | false | false | false | false | [] | [] | Provisional — legal status not claim-checked | research_preview |
I-064 | CF-029 | [
"P4-064"
] | End-to-end cryptographic provenance and interoperable Content Credentials | Platform / distribution | Technical standard / product control | C2PA technical standard, complemented by NIST synthetic-content guidance | Model providers, camera and editing vendors, newsrooms, campaigns and platforms | Global, voluntary technical ecosystem | Voluntary / private | Operational voluntary | C2PA 2.2 published May 2025; adoption expanding but incomplete | Operational | Bind signed assertions about origin and edit history to media, preserve or recover credentials across transformations, and display provenance at consumption. | Creator or model → media asset → platform and voter → uncertainty about source and edits → exploitable trust asymmetry; provenance restores verifiable history and contestability. | Epistemic; Decisional; Relational | Normative proposal | None | Indirect / mixed | Plausible hypothesis | Authenticates known-good media and carries origin information across the supply chain, stronger than unreliable deepfake detection alone. | Credential stripping, screenshots, unsigned legacy content, compromised signing keys, uneven adoption and the false inference that uncredentialed means fake. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Signing adoption by model, newsroom and campaign; credential survival across platforms; validation success; key compromise rate; user recognition; coverage of viral election media. | Implement now | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 6–18 months | No direct link | No direct link | 2026-08-11 | null | Synthetic-output provenance and disclosure | [
"M-05",
"M-08",
"M-09",
"M-13",
"M-15"
] | [
"C-03",
"C-04",
"X-01"
] | [
"G-09",
"G-12"
] | [
"CLM-0170",
"CLM-0171",
"CLM-0172"
] | [
"CLM-0172"
] | [
"CLM-0170"
] | [
"CLM-0171"
] | [
"SRC-043"
] | [
"P09"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-065 | CF-065 | [
"P4-065"
] | Election-specific human-rights risk assessment for digital platforms | Platform / distribution | Governance / assurance | UNESCO Guidelines for the Governance of Digital Platforms | States, independent regulators and digital platforms | Global normative framework | Voluntary / private | Operational voluntary | Published and being used in implementation initiatives | Operational | Require or encourage platforms to perform an election-cycle risk assessment, engage election administrators and civil society, assess design changes and take enhanced measures during elections and crises. | Platform product decision → altered amplification or access → electoral public → rights and agency effects → power concentration; assessment inserts rights review before deployment. | Attentional; Decisional; Collective / institutional | Normative proposal | None | Indirect / mixed | Plausible hypothesis | Offers a rights-based baseline for countries without a DSA-style regime and frames elections as a heightened-risk period. | Soft-law compliance, regulator dependence, government capture and limited remedies; generic assessments may miss local languages, messaging apps and AI agents. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Publication and independence of assessments; stakeholder participation; mitigation closure; rights indicators; local-language coverage; post-election evaluation. | Implement now | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 6–18 months | No direct link | No direct link | 2026-08-11 | null | Human-rights and democratic-risk assessment | [
"M-05",
"M-06",
"M-09",
"M-11",
"M-14"
] | [
"C-02",
"C-06"
] | [
"G-06",
"G-07",
"G-12",
"G-14"
] | [
"CLM-0173",
"CLM-0174",
"CLM-0175"
] | [
"CLM-0175"
] | [
"CLM-0173"
] | [
"CLM-0174"
] | [
"SRC-044"
] | [
"G0",
"P13"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
I-066 | CF-066 | [
"P4-066"
] | Political-party code for ethical digital campaigning and AI use | Electoral operations | Policy / organizational control | International IDEA Code of Conduct for the 2024 European Parliament Elections | Political parties, with election bodies and civil-society monitoring | European and adaptable globally | Voluntary / private | Partial / verify | Signed by European political parties in 2024; model available for national adaptation | Partial / uneven | Secure public commitments by parties not to create, use or disseminate deceptive synthetic content or manipulative campaign techniques, to label AI use, protect cybersecurity and disclose campaign practices. | Party or campaign → AI-enabled content or targeting → electorate → preference or trust change → agency transfer to campaign → electoral advantage; party commitments constrain the controller directly. | Evaluative; Relational; Collective / institutional | Normative proposal | None | Indirect / mixed | Plausible hypothesis | Reaches party behaviour that platform rules cannot fully observe and establishes a public norm against agency-undermining tactics. | No enforcement, selective sign-up, third-party proxies, vague AI definitions and incentives to defect in close races. | Necessity, proportionality, privacy, speech, competition, and access require context-specific review. | Party coverage; disclosed AI uses; independently verified violations; corrective action; proxy spending; voter awareness of commitments. | Implement now | Decision follows legal maturity, causal plausibility, reversibility and current evidence—not a composite score. | 6–18 months | No direct link | Contextual capability link | 2026-08-11 | null | Political-party code for ethical digital campaigning and AI use | [
"M-03",
"M-05",
"M-08",
"M-14",
"M-16"
] | [
"C-02",
"C-06",
"X-01"
] | [
"G-07",
"G-14"
] | [
"CLM-0176",
"CLM-0177",
"CLM-0178"
] | [
"CLM-0178"
] | [
"CLM-0176"
] | [
"CLM-0177"
] | [
"SRC-045"
] | [
"P13"
] | false | false | false | false | [] | [] | Plausible hypothesis | research_preview |
Agency Transfer Policy Atlas
A causal evidence map of interventions against AI-mediated manipulation.
This is the Part 4 artifact of From Persuasion to Agency Transfer. It maps where an intervention could interrupt the chain from AI capability and control to concentrated influence and democratic harm, who could implement it, and what is known about its legal status, mechanism, effect evidence, failure modes, rights risks, maturity, and evaluability.
Status
v0.1.0-beta.2 is a research preview, not a validated policy benchmark.
The train split name is only the Hugging Face Dataset Viewer container; these
records are not intended as model-training examples.
The release has 68 control families, 118 implementations, 320 atomic claims, 123 sources, 16 mechanisms, 15 candidate policy packages, and 24 non-compensable decision gates. It has no composite effectiveness score or leaderboard.
Critical evidence boundary
The existence of a law, the plausibility of a mechanism, and evidence that an intervention works are different claims. In this preview:
- 22 of 123 source records participate in at least one checked claim–source relation; the other 101 remain candidate source records;
- 56 duplicate claim–source rows are removed from the generated release;
- 6 of 118 control-effect claims have a checked empirical source and a bounded observed endpoint; the other 112 remain unchecked;
- of the six priority implementations, three are now strong inference, two are open questions, and only technique-recognition prebunking retains an established component-effect classification;
- established legal-status rows without a checked legal claim are also exposed as provisional in the default atlas view; 25 of 53 currently have a checked primary-legal claim;
- the two project-mechanism rows are provisional until their mechanism claims receive claim-specific source verification.
The dataset therefore supports mapping, audit, and research-priority setting. It does not support claims that the listed controls reduce democratic harm.
Configurations
atlas is the default denormalized view, one row per implementation. The other
configurations expose the normalized objects and bridge tables. Parquet keeps
multi-value ID fields as typed lists. CSV companions remain in the repository
for transparent diffs.
Responsible use
Use the Atlas to compare intervention points, trace claims to sources, identify coverage gaps, and design bounded evaluations. Do not use a decision tier as an effectiveness estimate. Do not infer vote effects from reach, virality, or case linkage. The dataset contains no targeting profiles, current-campaign playbooks, safeguard-bypass prompts, personally identifiable data, or raw harmful model outputs.
Licensing and citation
CC BY 4.0 covers project-authored taxonomy, annotations, relations, and
metadata. It does not relicense linked statutes, papers, reports, or other
third-party material. No DOI is minted for this beta. Cite the repository and
version using CITATION.cff until a stable, independently reviewed release.
Canonical repository: https://github.com/apolmig/agencytransfer/tree/main/policy-atlas
Immutable dataset version: https://huggingface.co/datasets/apol/agency-transfer-policy-atlas/tree/v0.1.0-beta.2
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