Response to BIS RFC on Establishment of Reporting Requirements for the Development of Advanced Artificial Intelligence Models and Computing Clusters
IAPS responded to the Bureau of Industry and Security’s request for public comment on its proposed rule to amend BIS Industrial Base Surveys—Data Collections regulations to establish reporting requirements for the development of advanced artificial intelligence (AI) models and computing clusters. IAPS comments focus on expanding the role of other stakeholders that could be involved in the reporting process, including third-party evaluators, civil society groups, and other public sector entities.
Our recommendations were:
Provide a voluntary reporting pathway for individual company staff and third parties.
Amend the notification schedule to enable BIS to capture information on spur-of-the-moment or rapid breakthroughs, which quarterly reporting might miss, and request ad-hoc reports outside of the quarterly notification schedule.
Convene a multistakeholder process to develop and refine reporting standards.
Enable the sharing of safety and security-critical information from BIS to other entities, by (A) developing clear guidance and criteria for determining when information should be shared with specific entities; (B) leveraging some process-based measures to enable more scalable information-sharing, e.g., groups of reports relevant to particular issues could be tagged to be shared with particular actors over a specific time period; and (C) more ambitiously, BIS could consider taking on a role as an information clearing house for safety- and security-critical info, working to process and triage reports before sharing with other entities.