模型治理
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关于模型治理,中美欧的差异与共识
3 6 Ke· 2025-11-14 11:07
Core Viewpoint - The article discusses the evolving landscape of artificial intelligence (AI) governance, highlighting the different approaches taken by the EU, California, and China in regulating AI models, particularly general-purpose and frontier models. It emphasizes the need for innovation while ensuring safety and control over AI models. Group 1: EU Approach - The EU has established a complex risk governance framework categorizing AI systems into four risk levels: prohibited, high-risk, limited risk, and minimal risk, with stricter regulations for higher risks [2][3] - The EU's governance mechanism for models distinguishes between those with and without "systemic risk," requiring all model providers to disclose technical documentation and training summaries, while those with systemic risk must undergo model assessments and implement mitigation measures [2][3] - The EU's framework is characterized by overlapping standards for models and applications, leading to a complex and burdensome regulatory environment, prompting the EU Commission to push for simplification of related regulations [3][4] Group 2: California Approach - California's SB 53 focuses on a narrower regulatory scope, targeting "frontier developers" who train models using over 10^26 FLOPs, and imposes lighter obligations compared to the EU [4][5] - The obligations under SB 53 are limited to basic transparency requirements, such as website information and communication mechanisms, contrasting with the EU's extensive documentation requirements [4][5] - California's legislative approach aims to promote industry growth and competitiveness, avoiding excessive regulatory constraints [5] Group 3: China Approach - China's governance is application-driven, focusing on practical service applications to indirectly regulate models, rather than directly targeting the models themselves [6][7] - The Chinese regulatory framework has evolved from algorithm governance to model governance, establishing institutional constraints through various regulations that address algorithmic risks and model training [7][8] - China's approach emphasizes risk identification and management, categorizing risks into internal, application, and derivative risks, with a clear distinction between model risks and application risks [8][9] Group 4: Commonalities and Future Directions - Despite differing approaches, the EU, California, and China share a tendency towards "flexible governance" and industry-led initiatives, allowing for greater compliance autonomy [9][10] - All three regions recognize the importance of building an assessment ecosystem to address uncertainties in model capabilities, suggesting community-driven evaluation mechanisms [10][11] - Transparency is identified as a core governance tool, facilitating control while allowing for innovation, with each region developing its own transparency frameworks [11]
关于模型治理,中美欧的差异与共识
腾讯研究院· 2025-11-14 10:13
Core Viewpoint - The article discusses the evolving landscape of artificial intelligence governance, particularly focusing on the governance of general-purpose and frontier models in the US, EU, and China, highlighting their distinct approaches and regulatory frameworks [2][10]. Group 1: EU Governance Approach - The EU has established a complex risk governance framework categorizing AI systems into four risk levels: prohibited, high-risk, limited-risk, and minimal-risk, with stricter regulations for higher-risk categories [4]. - The EU's governance mechanism for general models distinguishes between those with and without "systemic risk," requiring all providers to disclose technical documentation and training summaries, while those with systemic risk must undergo model assessments and report significant incidents [5]. - The EU's framework is characterized by overlapping standards for models and applications, leading to a burdensome regulatory environment that may hinder innovation, prompting the EU Commission to push for simplification of related regulations [6]. Group 2: US Governance Approach - California has adopted a lighter regulatory approach with the signing of the "Frontier AI Transparency Act" (SB 53), focusing on self-regulation and limiting the scope of obligations for model developers [6]. - SB 53 targets "frontier developers" using models with over 10^26 FLOPs, with additional criteria for larger developers, thus narrowing the regulatory scope compared to the EU's broader approach [6]. - The obligations under SB 53 are minimal, primarily requiring basic transparency regarding website information and intended use, contrasting sharply with the EU's extensive documentation requirements [6]. Group 3: China's Governance Approach - China's governance strategy is application-driven, focusing on real-world issues and extending regulations from application services to model governance [7][8]. - The country has established a regulatory framework for algorithm governance, which has laid the groundwork for model governance, addressing risks associated with algorithmic recommendations and deep synthesis technologies [8]. - China's governance framework emphasizes practical measures for risk identification and management, categorizing risks into endogenous, application, and derivative risks, thus providing a clear delineation of responsibilities [9]. Group 4: Commonalities and Future Directions - Despite differing backgrounds and regulatory obligations, the US, EU, and China share a tendency towards "flexible governance" and industry-led initiatives, allowing for greater compliance autonomy [11]. - All three regions are exploring the establishment of assessment ecosystems to address uncertainties in model capabilities, with suggestions for community-driven evaluation mechanisms [11]. - Transparency has emerged as a core governance tool across the three regions, facilitating maximum control with minimal constraints, thereby fostering innovation while ensuring accountability [12].