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string
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string
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string
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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
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context_entity_ids
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research_gap_ids
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claim_ids
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effect_claim_ids
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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
End of preview. Expand in Data Studio

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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