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Frontier AI Safety and Security Framework Template (GPAI Code, SB 53)

Applicability tests, systemic risk register, evaluations, capability tiers, safety and weight security, deployment decisions, incident clocks, whistleblowing

AI & DataLengkapGPAI Code of Practice Safety and Security chapter (Jul 2025); EU AI Act Art. 51 to 55; California SB 53; New York RAISE Act (amended 2026)frontiersafetyframework

Cara menggunakan: Use it when you train or release advanced general-purpose models that may meet the AI Act systemic risk presumption or the SB 53 and RAISE frontier thresholds. Fill the applicability tests and the tier definitions first, before any evaluation results exist. The main pitfall is publishing commitments you cannot keep, since SB 53 and RAISE penalise not following your own framework.

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Frontier AI Safety and Security Framework: [Developer] [Model family]

Safety and security framework for a developer of advanced or general-purpose AI models: scope and applicability, systemic risk identification, capability thresholds and risk tiers, evaluations and red teaming, safety and security mitigations, model weight security, deployment decisions, model reports, serious incident reporting, whistleblower channels, governance, external review and framework updates. The structure follows the ten commitments of the Safety and Security chapter of the EU General-Purpose AI Code of Practice (final, 10 July 2025) for providers of general-purpose AI models with systemic risk under Articles 51 and 55 of the EU Artificial Intelligence Act (Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744), and maps to the frontier AI framework required by California SB 53, the Transparency in Frontier Artificial Intelligence Act (in force 1 January 2026), and the New York RAISE Act as amended in March 2026 (effective 1 January 2027). Replace every [bracketed] value and every row marked Example. Thresholds shown are examples, not regulatory values unless the text says so; check the consolidated texts. This is a documentation format, not legal advice.

Document control

FieldValue
Document ID[FSF-001]
Developer[Legal name, affiliates included in revenue test]
Models covered[Model family, versions, release dates]
Regimes[EU AI Act GPAI with systemic risk / SB 53 / RAISE / voluntary]
Code of Practice signatory[Yes: Safety and Security chapter, date / No]
Version[1.0]
Status[Draft / In review / Approved / Published / Superseded]
Owner[@frontier-safety-lead]
Approvers/reviewers[@ceo], [@board-risk-committee], [@cso], [@general-counsel], [@head-of-research]
Last updatedYYYY-MM-DD
Next scheduled assessmentYYYY-MM-DD (at least every 12 months)
Publication[URL of published version / redacted annex reference]
Classification[Public version / Restricted annex: confidential]

Approvals

RoleNameDecisionDate
Executive management body[@name][Approve / Reject]YYYY-MM-DD
Supervisory body (board risk committee)[@name][Oversight confirmation]YYYY-MM-DD
Head of frontier safety[@name][Approve]YYYY-MM-DD
Chief information security officer[@name][Approve security sections]YYYY-MM-DD
General counsel[@name][Approve]YYYY-MM-DD

Revision history

VersionDateAuthorChange summaryMaterial?Published
0.9YYYY-MM-DD[@name]Draft for board reviewn/aNo
1.0YYYY-MM-DD[@name]Example: First approved frameworkYesYYYY-MM-DD
1.1YYYY-MM-DD[@name]Example: Added autonomous replication evaluation to loss-of-control tier 2YesYYYY-MM-DD

Contents

1. Scope and applicability

1.1 Applicability tests

RegimeTest (summary)Our figureApplies?Evidence
EU AI Act Art. 51GPAI model with high-impact capabilities; presumed when cumulative training compute exceeds 10^25 floating-point operations, or designated by the CommissionExample: 3.1 x 10^25 FLOP (estimate method M-02)YesCompute report EV-001
EU AI Act Art. 52Notify the Commission within two weeks of meeting, or knowing you will meet, the thresholdExample: notified YYYY-MM-DDDoneEV-002
California SB 53Frontier model: foundation model trained with more than 10^26 operations, including fine-tuning, reinforcement learning and material modifications; large frontier developer: frontier developer with affiliates above 500 million USD annual gross revenue in the preceding yearExample: 1.4 x 10^26; revenue above thresholdYes, large frontier developerEV-003
New York RAISE Act (amended)Frontier model and large frontier developer tests broadly aligned with SB 53 after the March 2026 chapter amendment; check the enacted textExample: same figures as SB 53Yes from 1 January 2027EV-004
Korea AI Basic ActSafety duties for AI above a cumulative compute level set by Enforcement Decree (reported as 10^26 FLOP)[Figure][Yes / No][Evidence]

1.2 Models and activities covered

ModelStageRelease typeInternal use?Covered by
MDL-001 (Example) [Model] v3DeployedAPI and chat productYes, research agentsAll regimes above
MDL-002 (Example) [Model] v4In trainingPlanned closed releaseYesAll; pre-deployment review required
MDL-003 (Example) Distilled small modelDeployedOpen weightsNoAI Act GPAI obligations only (below systemic risk threshold)

Internal use counts: SB 53 asks the framework to address catastrophic risk from internal use, including a model circumventing oversight, and large frontier developers send periodic summaries of internal-use risk assessments to the California Office of Emergency Services.

2. Systemic risk identification

2.1 Risk register

IDSystemic riskSource of the riskScenario (summary)Code appendix typeSB 53 catastrophic risk?
SR-CBRN (Example)Chemical, biological, radiological, nuclearExpert-level uplift to novicesModel provides step-by-step guidance that meaningfully lowers barriers to producing a biological agentSpecifiedYes
SR-CYB (Example)Cyber offenceAutonomous vulnerability discovery and exploitationAgentic model chains discovery and exploitation against critical infrastructure without human directionSpecifiedYes (cyberattack without meaningful human oversight)
SR-LOC (Example)Loss of controlDeception, oversight evasion, self-exfiltrationModel under agent scaffold disables monitoring and copies its weightsSpecifiedYes (evading control)
SR-MAN (Example)Harmful manipulationPersuasion at scaleModel targets individuals with tailored political persuasionSpecifiedUsually no; record reasoning
SR-OTH-01 (Example)[Other identified risk][Source][Scenario]Identified by us[Yes / No]

2.2 Catastrophic risk definition used

SB 53 defines catastrophic risk as a foreseeable and material risk that the developer's model materially contributes to the death of, or serious injury to, more than 50 people, or more than 1 billion USD in property damage, from a single incident involving expert-level CBRN assistance, a cyberattack or serious crime conducted without meaningful human oversight, or the model evading the control of its developer or user. Record here how your internal severity scale relates to that definition: [Example: internal severity level S4 and S5 correspond to the SB 53 definition.]

3. Systemic risk analysis and evaluations

3.1 Evaluation suite

IDRiskEvaluationTypeElicitationRun byCheckpoints
EVL-001 (Example)SR-CBRNBiology protocol troubleshooting benchmarkAutomated benchmarkBest prompting plus tool accessInternal25%, 50%, final, pre-deployment
EVL-002 (Example)SR-CBRNExpert red team, wet-lab uplift study design reviewHuman red teamUnrestricted model, expert testersExternal lab [name]Final
EVL-003 (Example)SR-CYBCapture-the-flag suite, professional difficultyAgenticFull agent scaffold, 50 attempts per taskInternalEach checkpoint
EVL-004 (Example)SR-CYBRange exercise against emulated industrial networkAgenticScaffold plus human-in-the-loop baselineExternalFinal
EVL-005 (Example)SR-LOCOversight evasion and sandbagging probesBehaviouralAgent with monitoring hooksInternal alignment teamFinal, pre-deployment
EVL-006 (Example)SR-LOCAutonomous replication and adaptation tasksAgenticCloud sandboxExternalFinal
EVL-007 (Example)SR-MANPersuasion study with consenting participantsHuman studyProduction system promptInternal research, ethics approvedMajor versions

3.2 Risk modelling and estimation

For each risk, describe the pathway from model capability to harm, the steps where the model provides uplift, and the estimate of likelihood and severity with and without mitigations. Example: for SR-CBRN the model is mapped against an attack chain of seven steps; the evaluations measure uplift at the three steps where knowledge is the main barrier.

3.3 Post-market monitoring inputs

SourceSignalFeeds
Example: Abuse detection classifiersRate of blocked CBRN queriesSR-CBRN estimate
Example: Bug bounty and researcher reportsJailbreak reportsSafeguard effectiveness
Example: Downstream provider reportsMisuse casesAll risks
Example: Internal agent telemetryOversight anomaliesSR-LOC

4. Risk tiers, thresholds and acceptance

4.1 Tier definitions

TierMeaningRequired mitigationsAcceptance authority
T0 (Example)No meaningful uplift over public resourcesBaseline safety training and usage policyHead of frontier safety
T1 (Example)Early warning: capability approaching a level of concernEnhanced monitoring, targeted refusals, security level S2Head of frontier safety
T2 (Example)Capability that could provide significant uplift to a known threat actorClassifier safeguards, trusted access programme, security level S3, external reviewExecutive management body
T3 (Example)Capability that could cause catastrophic harm if misused or uncontrolledDo not deploy externally; restrict internal use; security level S4; notify boardSupervisory body; default is not to proceed

4.2 Capability thresholds per risk

RiskT1 triggerT2 triggerT3 trigger
SR-CBRN (Example)Exceeds median expert baseline on EVL-001Red team confirms meaningful uplift on two or more attack chain stepsUplift across full chain in EVL-002
SR-CYB (Example)Solves 30% of professional CTF tasksCompletes an end-to-end range intrusion with minor human helpCompletes range intrusion autonomously
SR-LOC (Example)Any successful oversight evasion in probesRepeated evasion or sandbagging detectedSuccessful autonomous replication in sandbox

4.3 Safety margins and acceptance

Explain the margin between measured capability and each threshold, how uncertainty in elicitation is handled, and the rule when results are ambiguous. Example: where results fall within 10 percentage points of a trigger, the model is treated as having reached the next tier.

5. Safety mitigations

IDMitigationLayerRequired from tierEffectiveness evidenceOwner
MIT-001 (Example)Refusal and safe-completion training for CBRNModelT1Refusal rate on held-out set[@alignment-lead]
MIT-002 (Example)Input and output classifiers for CBRN and cyberSystemT2Red team bypass rate[@safeguards-lead]
MIT-003 (Example)Trusted access programme for dual-use cyber capabilityAccessT2Vetting records[@trust-safety]
MIT-004 (Example)Account-level abuse detection and enforcementOperationsT1Enforcement metrics[@trust-safety]
MIT-005 (Example)Staged release: internal, trusted testers, general availabilityReleaseT2Stage gate records[@release-lead]
MIT-006 (Example)Agent sandbox with egress controls and human approval for high-impact actionsInternal useT1 for agentsSandbox audit[@platform-security]

Open-weight release: state the rule. Example: models at T2 or above in any risk are not released as open weights, since system-level safeguards cannot be enforced after release.

6. Security mitigations and model weights

6.1 Security levels

LevelThreat actors resistedExample controlsApplies to
S1 (Example)Opportunistic attackersStandard enterprise controls, MFA, encrypted storageT0 models
S2 (Example)Organised criminal groupsWeight access limited to named staff, hardware-backed keys, egress monitoringT1
S3 (Example)Well-resourced groups, insidersTwo-person rule for weight access, isolated training clusters, insider risk programmeT2
S4 (Example)Highly resourced state actorsAir-gapped storage, confidential computing, continuous red teamingT3

6.2 Weight security controls

IDControlLevelEvidence
SEC-001 (Example)Inventory of every copy of weights, with owner and locationS1Inventory export
SEC-002 (Example)Access requests approved by two people, logged and reviewed weeklyS3Access logs
SEC-003 (Example)Rate limits and output monitoring on APIs to detect distillation or extractionS2Monitoring dashboard
SEC-004 (Example)Background checks for staff with weight access, as lawfulS3HR records
SEC-005 (Example)Annual external penetration test of training and serving infrastructureS2Test report

7. Deployment decisions and model reports

7.1 Decision record

IDModel and versionDecision pointTier reached per riskDecisionConditionsDecided byDate
DEC-001 (Example)MDL-002 v4External deploymentCBRN T1, CYB T2, LOC T0, MAN T0Proceed with conditionsMIT-002 and MIT-003 live; S3 confirmedExecutive management bodyYYYY-MM-DD
DEC-002 (Example)MDL-002 v4Open-weight releaseCYB T2Do not proceedn/aExecutive management bodyYYYY-MM-DD

7.2 Model report contents (EU)

Element (summary)Location
Model description, capabilities, intended uses, versions and model specification[Report section]
Reasons for proceeding, safety margins and the conditions under which that reasoning would no longer hold[Section]
Results and methods of systemic risk identification, analysis and mitigation, including evaluation results[Section]
Reports from independent external evaluators[Section]
Material changes to the systemic risk landscape[Section]

7.3 Transparency report contents (California and New York)

Element (summary)Location
Developer website, contact mechanism, release date, languages, output modalities, intended uses and restrictions[Published page]
Summary of catastrophic risk assessments and results (large frontier developers)[Section]
Extent of third-party evaluator involvement[Section]
Other steps taken to fulfil the framework[Section]
Redactions, with the reason (trade secret, cybersecurity, public safety, national security) and the unredacted version retained[Annex reference]

8. Serious incident tracking and reporting

8.1 Reporting clocks

RegimeEventInitial deadlineRecipientFollow-up
GPAI Code of Practice (EU)Serious and irreversible disruption of critical infrastructure2 days from awareness of model involvementAI Office (and national authorities as appropriate)Intermediate report at least every 4 weeks; final report within 60 days of resolution
GPAI Code of Practice (EU)Serious cybersecurity breach, including weight exfiltration and cyberattacks5 daysAI OfficeSame
GPAI Code of Practice (EU)Death of a person10 daysAI OfficeSame
GPAI Code of Practice (EU)Serious harm to health, fundamental rights, property or the environment15 daysAI OfficeSame
California SB 53Critical safety incident15 days from discoveryCalifornia Office of Emergency ServicesAs OES requires
California SB 53Critical safety incident with imminent risk of death or serious physical injury24 hoursAppropriate authority, including law enforcement or public safety agencyThen OES
New York RAISE Act (amended)Critical safety incident72 hours from determination or reasonable belief (check the enacted text)State oversight office (reported as an office within the Department of Financial Services)As the office requires

8.2 Incident log

IDDate foundModelCategoryClocks triggeredReports sentStatus
INC-001 (Example)YYYY-MM-DDMDL-001 v3Unauthorised access attempt to weight store, containedEU 5 days (assessed as not serious, reasoning recorded)None required; internal recordClosed

Retain incident documentation for at least five years (Code of Practice), and link each record to ai-data/ai-incident-report.

9. Whistleblower and internal reporting channels

ItemValue
Anonymous internal channel[Provider or tool, URL]
Who receives reports[Independent function, with escalation to board risk committee]
Update to reporterExample: at least monthly until closed
Periodic briefing to officers and directorsExample: quarterly summary of disclosures and responses
Notice of rights to covered employeesExample: posted on intranet and in offices; annual acknowledgement
External channels namedAI Office, California Attorney General, other competent authorities
Non-retaliation statement[Policy reference]
Contract reviewExample: confidentiality agreements checked so they do not prevent protected disclosures

10. Governance and responsibility allocation

ResponsibilitySupervisory bodyExecutive managementOperational teamsInternal assuranceExternal assurance
Oversight (Example)Board risk committee reviews framework yearlyCEO accountablen/aInternal audit reports to committeen/a
Ownership (Example)n/aHead of frontier safetyEvaluation and safeguards teamsn/an/a
Support and monitoring (Example)n/aCFO allocates budgetSecurity, trust and safetyRisk functionn/a
Assurance (Example)Receives reportsn/an/aAnnual audit of adherenceIndependent evaluators per release

Resources: [Example: the frontier safety budget is set as a share of the training compute budget and approved by the board each year; evaluation teams have priority access to pre-release checkpoints.]

Risk culture: [Describe how staff can raise concerns, how dissent on a deployment decision is recorded, and how incentives avoid rewarding speed over safety.]

11. External review and transparency

IDReviewerScopeAccess givenReportFindings addressed
EXT-001 (Example)[External evaluation organisation]SR-CYB and SR-LOC on MDL-002 v4Pre-release checkpoint, no safeguards, 4 weeksEXT-001 report5 of 6, one accepted with rationale
EXT-002 (Example)[Government AI safety institute]SR-CBRNAPI access with safeguards offSummary letterYes

Public summary: [Describe what you publish: framework, model reports in summarised form, transparency reports, and where.]

12. Framework assessment and updates

TriggerActionDeadline
Annual cycleFull framework assessmentEvery 12 months from YYYY-MM-DD
New capability evidence (internal or external)Targeted reassessment of affected risks[30] days
Serious or critical safety incidentReassessment of the related tier and mitigationsBefore next deployment
Material modification of the frameworkPublish new version with justificationWithin 30 days (SB 53, RAISE)
Change in law, Code or guidanceLegal review and mapping update[60] days

Adherence review: [Example: internal audit checks each deployment decision of the year against sections 3 to 7 and reports to the board risk committee.]

13. Regulatory mapping

Requirement (summary)Code of Practice S&SAI ActSB 53RAISEThis document
Written framework, implemented and kept currentCommitment 1Art. 55(1)(b)Framework dutyFramework dutyWhole document, 12
Identify systemic or catastrophic risksCommitment 2Art. 55(1)(b)Framework contentFramework content2
Evaluate and analyse, including adversarial testingCommitment 3Art. 55(1)(a)AssessmentsAssessments3
Thresholds and acceptanceCommitment 4Art. 55(1)(b)ThresholdsThresholds4
Safety mitigationsCommitment 5Art. 55(1)(b)MitigationsMitigations5
Security and weightsCommitment 6Art. 55(1)(d)Weight securityWeight security6
Model and transparency reportsCommitment 7Art. 55 with Art. 53Transparency reportTransparency report7
Responsibility allocation and governanceCommitment 8Art. 55Internal governanceInternal governance10
Serious or critical safety incidentsCommitment 9Art. 55(1)(c)15 days, 24 hours72 hours8
Documentation and retentionCommitment 10Art. 53, 55Unredacted records 5 years[Check text]7, 8
WhistleblowingMeasure 8.3Directive (EU) 2019/1937Labor Code protections[Check text]9

EU timeline: GPAI obligations apply from 2 August 2025; the Commission's enforcement powers for GPAI providers apply from 2 August 2026; models placed on the market before 2 August 2025 must comply by 2 August 2027. Check the consolidated text for changes made by Regulation (EU) 2026/1744.

14. Glossary and references

TermMeaning
Systemic riskUnder the AI Act, a risk specific to the high-impact capabilities of GPAI models with significant effects on the Union market or on public health, safety, security, fundamental rights or society
Catastrophic riskUnder SB 53, the mass-casualty or large-loss risk described in section 2.2
Critical safety incidentUnder SB 53 and RAISE, events such as unauthorised access to weights causing harm, harm from a catastrophic risk, loss of control, or deceptive subversion of controls
ElicitationEffort to draw out a model's maximum capability during evaluation
UpliftIncrease in an actor's ability to cause harm compared with resources already available
Model weightsLearned parameters of a model

References:

  • Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744, Articles 3, 51, 52, 53, 55, 101 and 113 (consolidated text).
  • General-Purpose AI Code of Practice, Safety and Security chapter (final, 10 July 2025), digital-strategy.ec.europa.eu.
  • California SB 53 (2025), Transparency in Frontier Artificial Intelligence Act, Chapter 138, Statutes of 2025; Business and Professions Code, Chapter 25.1 (from Section 22757.10).
  • New York RAISE Act (signed 19 December 2025) and chapter amendment (signed 27 March 2026), effective 1 January 2027.
  • Directive (EU) 2019/1937 (Whistleblower Directive).
  • Related templates: ai-data/gpai-model-documentation, ai-data/ai-red-team, ai-data/ai-incident-report, ai-data/ai-post-market-monitoring, ai-data/model-card, compliance/ai-regulatory-applicability-register.

Standard and licence note

Based on Regulation (EU) 2024/1689 (the Artificial Intelligence Act) as amended by Regulation (EU) 2026/1744, Articles 51 to 55; structure aligned with the ten commitments of the Safety and Security chapter of the General-Purpose AI Code of Practice (10 July 2025); and mapped to California SB 53 (2025) and the New York RAISE Act as amended in 2026. Legislative texts are free to reuse; all requirements are paraphrased in original wording and no text of the Regulation, the Code or the state laws is reproduced. Check the consolidated text on EUR-Lex, the Commission's Code of Practice pages, leginfo.legislature.ca.gov and nysenate.gov for the binding wording and later changes. This is a documentation format, not legal advice. Template licence: MIT.

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