Designing escalation criteria for international AI incident response: criteria, triggers, and thresholds
Authors: Francesca Gomez, Matthew Ball, Michael Harre, Lydia Preston, Josephine Schwab, Caio Machado
Organizations: 1Arcadia Impact AI Governance Taskforce · 2The Future Society
Abstract
AI incident reporting requirements are emerging in regulation and policy, yet no operational criteria exist for determining when a detected AI incident warrants escalation beyond national handling to international coordination. This paper proposes an escalation framework to address this gap, intended as a common reference point across jurisdictions that enables aligned escalation while preserving flexibility in how actors respond within their own legal and policy contexts. We review SB 53, the EU AI Act, the GPAI Code of Practice, and incident frameworks from other industries to derive eight criteria for assessing whether an incident warrants escalation, translated into a sequential flowchart with gated decision points and threshold checks. For each criterion, we map how it interplays with these regulatory frameworks, identifying where their design choices support or undermine effective detection. We test the framework against ten documented AI incidents and structured variants to identify where criteria under-detect or misclassify incidents in practice. We find three design patterns that may lead to systematic under-detection in regimes where model developers are responsible for escalation: a. where escalation requires confirmed harm, events such as model weight exfiltration risk detection only after severe, irreversible harm has propagated; b. where incidents are assessed individually, systemic harms emerging from accumulation risk being under-detected; and c. where thresholds align with legal instruments rather than quantitatively testable terms, criteria risk being impractical to apply under time pressure. We also find that escalation rules are only one component of a broader framework: the underlying definitions against which thresholds are set, and the data available to the responsible actor, create interdependencies that can themselves drive under-detection.
Frontier AI companies have published capability thresholds that differ substantially, making it difficult for third parties to verify whether a threshold has been crossed or to compare requirements across companies. Moreover, without common minimum thresholds, risk mitigation may be inconsistent, creating a potential race to the bottom in safety standards. We develop a methodology for deriving harmonized thresholds across three risk domains. For misuse risks (cyber and biological), we take expected harm as the key primitive and use an explicit risk-modeling approach that accounts for risk channels and model release conditions. For automated AI R&D, we base our proposed threshold on the observed rate of AI progress rather than expected harm. Our analysis expands upon prior work and highlights existing empirical gaps and limitations.
Wilber Sean Anterola, Matthew Ball, Luis F. Lafuerza +1
AI systems may produce failures after deployment that pre-deployment safety assessments do not anticipate. Managing these failures requires what we refer to as adequate \textit{AI incident governance}, where having good definitions, taxonomies, monitoring practices, reporting mechanisms, and incident analysis is essential. We examine existing frameworks related to AI incident governance by regulatory bodies and independent efforts, and find that while there are frameworks that describe how individual functions can be performed, there is a lack of consistency within the aspects of definitions, classification, monitoring, and reporting. These inconsistencies apply to the types of incident data that is collected and reported, the ways in which they are categorised, and as a result, the depth, representativeness, and accuracy of analysis that can be performed.
Harleen Kaur Sidhu, Rebecca Scholefield, Nour Annan +5
Post-deployment accountability has become central to AI governance, yet little empirical evidence shows whether monitoring, incident reporting, and impact assessment obligations are visible when AI systems fail. This study analyzes real-world AI incidents from the AI Incident Database (2020--2026) and codes them against nine post-deployment provisions from the EU AI Act, the NIST AI Risk Management Framework, and the GDPR. The findings show substantial accountability gaps: 77.1% of incidents lack evidence of EU AI Act post-market monitoring, and 99.6% lack documented Data-Protection Impact Assessment evidence. Governance gaps are also systemic, with 9.8% of incidents simultaneously non-compliant under two or more regimes. Incidents detected through internal monitoring show much higher compliance than externally detected incidents (87.5% vs 5.3% under the EU AI Act; 95.8% vs 58.1% under NIST), suggesting that monitoring capacity is a key condition for effective post-deployment governance. Building on these findings, the paper proposes the Proactive AI Governance Compliance Framework (PAGCF), a four-phase lifecycle for pre-deployment assessment, continuous monitoring, incident preparedness, and cross-framework verification.