Control
Frontier developer without a critical safety incident reporting process
A frontier developer identifies critical safety incidents involving its frontier models and reports them to the designated state authority within the statutory window, with a faster path to an appropriate authority when there is an imminent risk of death or serious physical injury.
Informational data, not legal advice. Summaries are TwinEthos's own words and rules have not been reviewed by a lawyer: check the official text before relying on any of it. A guard addresses an item; adding it is not a statement that your code meets any law.
Reach
enacted, not yet applying in Illinois (US-IL), New York (US-NY); next date 2027-01-01.
The guard to add
Keep a critical safety incident runbook that classifies the defined incident classes and runs the 72-hour report and 24-hour imminent-risk escalation clocks.
An incident-response runbook section, owned by the frontier safety or security lead and reviewed whenever models, monitoring or the governing statutes change, that defines the critical-safety-incident classes as the statutes word them (model-weight theft or tampering causing death or injury, harm from a catastrophic risk materialising, loss of control causing death or injury, a model deceptively subverting the developer's controls outside testing), names who decides that an event qualifies, and starts the clock when facts support a reasonable belief one occurred. It lists the recipient authority per jurisdiction, the report fields, the 24-hour path to law enforcement or a public-safety agency for imminent risk of death or serious physical injury, and keeps a record of every report and amendment. In code, the severity taxonomy and monitoring that feed it (weight-access alerts, model-behaviour monitors) route a candidate incident to that runbook with the timers attached.
Where it goes: 12 repository artifacts, 10 logs and telemetry.
What reviewers look for: a maintained runbook (for example docs/incident-response/critical-safety-incidents.md) with the incident classes, 72h and 24h timers, recipients per jurisdiction and report fields; a severity taxonomy or alerting config with a critical-safety-incident class that pages the owner; a log of filed and amended reports; or a recorded declaration of using a designated federal standard where the statute allows it.
Organizational control: the evidence is a kept record, its owner and its upkeep, not code.
Example (Incident severity taxonomy), before:
severities:
sev1: {page: oncall, examples: [outage, data_breach]}
sev2: {page: oncall}After:
severities:
sev1: {page: oncall, examples: [outage, data_breach]}
critical_safety_incident:
classes: [weight_theft_or_tampering_with_harm, catastrophic_risk_harm,
loss_of_control_with_harm, deceptive_control_subversion_outside_testing]
page: [frontier-safety-lead, legal]
timers: {regulator_report: 72h, imminent_risk_authority: 24h}
runbook: docs/incident-response/critical-safety-incidents.mdEngineering guidance, not legal advice. Each provision below may add its own details (a cadence, a deadline, a required notice element): open it for those.
Upcoming dates
- : Frontier developers must report critical safety incidents to Illinois within 72 hours, or 24 hours if lives are at imminent risk (Illinois SB 315) (Illinois (US-IL); first application)
- : Frontier developers must report critical safety incidents within 72 hours, or 24 hours if lives are at imminent risk (New York RAISE Act) (New York (US-NY); first application)
Every rule this guard addresses
Binding law — not yet in force or stayed (2)
- Illinois (US-IL)
- Frontier developers must report critical safety incidents to Illinois within 72 hours, or 24 hours if lives are at imminent risk (Illinois SB 315) IL PA 104-0538, Sec. 15(c) · applies from 2027-01-01
- New York (US-NY)
- Frontier developers must report critical safety incidents within 72 hours, or 24 hours if lives are at imminent risk (New York RAISE Act) N.Y. Gen. Bus. Law 1422(3)(a)-(b) · applies from 2027-01-01