BIS Proposes Reporting Requirements for Large AI Models and Computing Clusters
Summary
On September 11, 2024, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) proposed a new rule, pursuant to directives in the 2023 AI Executive Order, that would establish a quarterly reporting requirement for AI developers and hardware providers that meet certain thresholds. This rule would amend the BIS’s Industrial Base Surveys—Data Collections to require notification to BIS of AI models with more than 10^26 computational operations and compute clusters networked at 300 Gbit/s or faster, capable of at least 10^20 computational operations per second (i.e., 100 exaflops), encompassing plans for the subsequent six months. Following that notification, BIS will send follow up questions, which must be answered within 30 days and any ensuing follow up from BIS within 7 days. BIS’s questions will cover subjects identified in the AI EO, including dual-use model activities, physical and cybersecurity protections taken to protect training processes and model weights, and red-team testing.
BIS is accepting comments through October 11, 2024, and identified three areas of particular interest:
- Whether the quarterly notification frequency is appropriate for timely information gathering.
- How the information, especially sensitive data, gathered should be collected and stored; and
- Whether the technical thresholds, which come from the 2023 AI EO, should be updated.
