AI Reports · GovAI (Oxford) · 2026-10-17 · Research paper
AI Regulation On Regulating Downstream AI Developers March 2025 Research Paper Sophie Williams, Jonas Schuett, Markus Anderljung Downstream developers - actors who fine-tune or otherwise modify founda
Downstream developers who fine-tune or otherwise modify foundation models can create or amplify risks by improving capabilities or compromising safety features, which can make upstream rules ineffective. Because downstream developers are numerous and growing, direct regulation of them may be impractical and stifling to innovation, so regulation of upstream developers to mitigate downstream modification risks is expected to be necessary. Regulating downstream developers may be warranted where they can raise risk to an unacceptable level, though further work is needed.