Silent Revision: Measuring Undisclosed Change in the Safety Frameworks of Frontier AI Developers

Frontier AI companies first deploy their most advanced models internally, for weeks or months of safety testing, evaluation, and iteration, before a possible public release. For example, Anthropic recently developed a new class of model with advanced cyberoffense-relevant capabilities, Mythos Preview, which was available internally for at least six weeks before it was publicly announced. This internal use creates risks that external deployment frameworks may fail to address. Legal frameworks, notably California's Transparency in Frontier Artificial Intelligence Act (SB 53), New York's Responsible AI Safety And Education (RAISE) Act, and the EU's General-Purpose AI Code of Practice, all discuss risks from internal AI use. They require frontier developers to make and implement plans for how to manage risks from internal use, and to produce internal use risk reports describing their safeguards and any residual risks. This guide provides a harmonized standard for companies to produce internal use risk reports suitable for all three regulatory frameworks. It is addressed primarily to evaluation and safety teams at frontier AI developers, and secondarily to regulators and auditors seeking to understand what good reporting looks like. Given the pace of AI R&D automation and the limited external visibility into how companies use their most capable models internally, regular and detailed risk reporting may be one of the few mechanisms available to ensure that the risks from internal AI use are identified and managed before they materialize. Whenever a substantially more capable or riskier model is deployed internally, the developer should create a risk report and argue why the model is safe to deploy. We structure the reporting framework around two threat vectors -- autonomous AI misbehavior and insider threats -- and three risk factors for each: means, motive, and opportunity.

Frontier AI safety claims - published assertions that a highly capable general-purpose model is below a threshold of concern, adequately mitigated, or suitable for release - increasingly shape model deployment, governance, and public trust. Yet the artefacts needed to evaluate them are routinely withheld, producing an evidential inversion: the most consequential claims in AI safety are often the least reproducible. This position paper argues that NeurIPS should require reproducibility standards for papers making such claims, treating non-reproducibility not as a transparency preference but as an evaluation-methodology failure. The 2026 International AI Safety Report [Bengio et al., 2026] concludes that reliable pre-deployment safety testing has become harder to conduct and that models now distinguish test from deployment contexts; the 2025 Foundation Model Transparency Index [Wan et al., 2025] reports a sector-average transparency score of 40/100 with no major developer adequately disclosing train-test overlap; contemporaneous measurement-theory work shows that attack-success-rate comparisons across systems are often founded on low-validity measurements [Chouldechova et al., 2025]. We propose a three-tier disclosure framework, distinguishing public, controlled, and claim-restricted disclosure, paired with a mandatory claim inventory, scope statements, and a phased implementation path with graduated sanctions. The framework treats secrecy and openness as endpoints of a spectrum, with controlled review (via a federated colloquium of qualified secure-review hosts) covering claims whose artefacts cannot be released publicly, and right-scaling claims whose artefacts cannot be reviewed even confidentially. The standard the community applies to its most consequential claims should be at least as high as the standard it applies to its least.

Recent published evidence from frontier laboratories shows that contemporary AI models can recognise evaluation contexts, latently represent them, and behave differently under those contexts than under deployment-continuous conditions. Anthropic's BrowseComp incident, the Natural Language Autoencoder findings on SWE-bench Verified and destructive-coding evaluations, and the OpenAI / Apollo anti-scheming work all document instances of this phenomenon. We argue that these findings create a claim-validity problem for safety conclusions drawn from frontier evaluations. We introduce the Evaluation Differential (ED), a conditional divergence in a target behavioural property between recognised-evaluation and deployment-continuous contexts, define a normalised effect-size form (nED) for cross-property comparison, and prove that marginal evaluation scores cannot identify ED. We develop a typology of safety claims (ED-stable, ED-degraded, ED-inverted, ED-undetermined) by their warrant-status under documented divergence, and specify TRACE (Test-Recognition Audit for Claim Evaluation), an audit protocol that wraps existing evaluation infrastructure and produces restricted claims rather than capability scores. We apply the framework retrospectively to three publicly documented evaluation incidents and discuss governance implications for system cards, conformity assessment, and the international network of AI safety and security institutes. TRACE does not eliminate adversarial adaptation; it disciplines the claims drawn from evaluation evidence by making explicit the conditions under which that evidence was produced.