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Frontier model deployed without a public transparency report

When a frontier model (new or substantially modified) is deployed, its developer publishes a transparency report (identity and contact route, release date, languages, output modalities, intended uses, use restrictions) and, for large developers, summaries of catastrophic-risk assessments, their results and third-party evaluator involvement.

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.

Family: Developers do not give deployers, users, or the public the documentation they need · control id cond.frontier-model-deployed-without-transparency-report

Reach

2items this one guard addresses
0jurisdictions where binding law on it is in force
2more where it is enacted, not yet applying
0standards and frameworks on the same control

enacted, not yet applying in Illinois (US-IL), New York (US-NY); next date 2027-01-01.

The guard to add

Publish a transparency report or system card on the developer's website before or at each new or substantially modified frontier-model deployment, and gate release on it.

A transparency report the frontier developer publishes on its website before or when each new or substantially modified frontier model is deployed; a model card or system card can carry it. It lists the developer's website, a contact channel for individuals, the release date, supported languages and output modalities, intended uses, and general use restrictions; for large developers it adds summaries of the catastrophic-risk assessments run under the developer's framework, their results, how far third-party evaluators were involved, and other framework steps taken for that model. The release or safety-policy owner maintains it and revises it for every new or substantially modified model, and the deployment pipeline carries a release gate that blocks rollout until the report is live with its fields present (for example a transparency-report.json validated against a schema in CI).

Where it goes: 12 repository artifacts, 14 user-facing text, 11 CI/CD pipeline.

What reviewers look for: for each frontier-model release, a published report or system card carrying every listed field and that version's release date; for large developers, risk-assessment summaries with results and third-party evaluator involvement; and a release checklist or pipeline step that fails when the report is not live or a field is missing, rather than a report written after launch.

Organizational control: the evidence is a kept record, its owner and its upkeep, not code.

Example (GitHub Actions release gate), before:

deploy-model:
  runs-on: ubuntu-latest
  steps:
    - run: ./deploy.sh "$MODEL_VERSION"

After:

deploy-model:
  runs-on: ubuntu-latest
  steps:
    - uses: actions/checkout@v4
    - run: pipx run check-jsonschema --schemafile schemas/transparency-report.schema.json "reports/$MODEL_VERSION/transparency-report.json"
    - run: curl -fsS "https://example.com/models/$MODEL_VERSION/transparency" > /dev/null   # report is live
    - run: ./deploy.sh "$MODEL_VERSION"

Engineering guidance, not legal advice. Each provision below may add its own details (a cadence, a deadline, a required notice element): open it for those.

Every rule this guard addresses

Binding law — not yet in force or stayed (2)