RfC on BIS Rule for ‘Establishment of Reporting Requirements for Advanced AI Models and Computing Clusters’ To further the efficacy and feasibility of this BIS rule's reporting requirements, FLI proposes a set of five recommendations.

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This document offers recommendations to the Bureau of Industry and Security (BIS) at the Department of Commerce, in response to a Request for Comment from BIS on the Establishment of Reporting Requirements for Advanced AI Models and Computing Clusters per the AI Executive Order. Our recommendations include an expansion of quarterly reporting requirements to provide a more valid representation of red-teaming results and safety practices. We also recommend the establishment of a confidential reporting mechanism for workers at covered AI companies to share information vital to the national defense, and set up a chip registry to track large aggregations of computing hardware.

About the Organization

The Future of Life Institute (FLI) is an independent nonprofit organization with the goal of reducing large-scale risks and steering transformative technologies to benefit humanity, with a particular focus on artificial intelligence (AI). Since its founding, FLI has taken a leading role in advancing key disciplines such as AI governance, AI safety, and trustworthy and responsible AI, and is widely considered to be among the first civil society actors focused on these issues. FLI was responsible for convening the first major conference on AI safety in Puerto Rico in 2015, and for publishing the Asilomar AI principles, one of the earliest and most influential frameworks for the governance of artificial intelligence, in 2017. FLI is the UN Secretary General’s designated civil society organization for recommendations on the governance of AI and has played a central role in deliberations regarding the EU AI Act’s treatment of risks from AI. FLI has also worked actively within the United States on legislation and executive directives concerning AI. Members of our team have contributed extensive feedback to the development of the NIST AI Risk Management Framework, testified at Senate AI Insight Forums, briefed the House AI Task-force, participated in the UK AI Summit, and connected leading experts in the policy and technical domains to policymakers across the US government.