Common Obligations

Obligation 03 of 06

Make scrutiny independent.

Let qualified outsiders challenge the claims, and report what they find.

Prevents A builder choosing its own examiner until it gets the answer it wants.

Proposed

What it asks

Builders should enable qualified outside scrutiny, with access proportionate to the claims and risks being examined. For higher-risk systems, the builder should not be able to make an unfavourable assessment disappear by choosing a different evaluator.

Independence needs an operating model. Who chooses the examiner? Who pays? Can the examiner run its own tests? Can it report a serious concern to an authorised oversight body without the client’s permission? A company-funded audit can still be useful, but these questions determine how much confidence it deserves.

Access to evidence and the freedom to publish findings are meaningful safeguards in their own right. They are not the same as authority to require a response. An assessment should make a decision better informed; it should not give its author unchecked power to stop work. The responsible authority, its duties and the route to challenge its decision must be specified too.

Public accountability does not require publishing private training records, security vulnerabilities, or every model artefact. Sensitive evidence can be examined through controlled access, with public summaries explaining the scope, findings, and unresolved concerns. Restrictions should have stated reasons and a route to challenge them, because commercial confidentiality can otherwise become a permanent answer to every difficult question.

Evaluators should also face scrutiny. Their methods, conflicts of interest, and material errors need examination. Independent assessment improves the basis for a decision; it cannot turn uncertainty into a guarantee.

Proposed

What compliance looks like

  • A published assessment scope and disclosed conflicts of interest.
  • A route for evaluators to report adverse findings.
  • Public explanations of concerns that remain unresolved.

Illustrative

The case that tests it

An outside team finds a serious risk. What happens next?

Two labs find a reason to spend longer testing. Neither wants to be the only one that waits. A government may see leadership as a source of security, prosperity and influence, and slowing down alone could surrender those advantages without reducing a rival’s risks. But a failure can harm people across borders, including countries that had little say. Shared checks and agreed responses could make it easier to wait without acting alone.

An outside team finds a serious risk. What happens next?

These arrangements can work together. The difference is whether a finding comes with an agreed duty to respond.

Outside review

A finding people can examine.

Give an outside team access to the work and the right to report concerns. Its findings can prompt repairs and help other labs and the public judge the risks.

Finding a problem does not decide what must happen next. Without an agreed response, a lab may keep going while competitors wait.

Reasoning and limits
The strongest case
Ongoing outside review can detect overlooked failures, challenge internal assumptions and inform the public. Publication rights matter even before a binding shared response exists.
What it asks us to accept
Reviewers need expertise, access and independence. Reporting alone does not establish who must respond, what action is required or how a dispute will be resolved.

Review with required follow-up

A finding with a response attached.

Agree in advance who must respond to a serious finding, what they can require, and how the decision can be challenged. Give competing labs the same obligations.

The decision-maker can be wrong or favour powerful companies. Restrictions need evidence, clear limits and a route to appeal; international enforcement remains difficult.

Reasoning and limits
The strongest case
Independent review and specified response duties can make shared restraint more credible. Contracts, purchasing requirements or public rules can assign responsibilities, while the appropriate authority decides on proportionate action.
What it asks us to accept
Required follow-up is not automatic acceptance of a reviewer’s recommendation or an unchecked power to stop work. Decisions need reasons, appeal and review deadlines. States may refuse scrutiny, and hidden activity can escape verification.

Neither arrangement guarantees safety. Some companies or states may refuse to participate, and checks can miss hidden activity. People outside the leading companies and countries need a voice in setting the terms.

Our inferenceThe test of any institution is whether it can obtain evidence, act on it, resist pressure, and be held accountable itself.

Reported

What the case draws on

Reported

On the record

Legislation signed

Outside scrutiny enters a legal framework.

California signed SB 813 and AB 1405, establishing an independent-verification framework and a registry with standards for AI auditors.

The governor’s announcement records legislation, not proof that oversight works in practice. It does not establish influence by this proposal.

Governor of California: Governor Newsom signs AI safeguards

This obligation in the full record

Proposed

Where it can fail

  • Evaluators can be captured, mistaken, or selected for favourable conclusions. Their independence needs scrutiny too.
  • Restricted access programmes need transparent criteria and a route to challenge exclusion.
Outside review will leak secrets.
Sensitive evidence can be examined under controlled access, with public summaries of scope, findings and unresolved concerns. Restrictions need stated reasons and a route to challenge them.
Reviewers would gain unchecked power to stop work.
An assessment should make a decision better informed, not hand its author a veto. The responsible authority, its duties and the route to challenge it must be specified too.

Sources

  1. Dario Amodei: We Must Pace the Frontier checked 2026-09-14
  2. IAEA: Basics of IAEA safeguards
  3. United Nations: AI scientific panel and global dialogue