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The document identifies human-outside-the-loop decision-making as a prohibited use case, defined as generating text used to make important decisions about individuals without human oversight in the decision process.
This analysis describes what Cohere's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes a human oversight requirement as a condition of permitted use, which intersects with regulatory mandates under the EU AI Act and GDPR Article 22 for automated decision-making systems affecting individuals.
Interpretive note: The document does not define what level of human involvement satisfies the human-in-the-loop requirement, creating interpretive ambiguity for compliance teams.
Under this provision, using Command R model outputs to make consequential decisions about individuals without human review is identified as a prohibited use case that violates Cohere's Usage Guidelines and Terms of Use. The document does not define the threshold for what constitutes an important decision or specify what level of human involvement satisfies the requirement.
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"Human-outside-the-loop: The generation of text that could be used to make important decisions about people, without a human-in-the-loop.Excerpt from Cohere's Responsible Use Policy
1. REGULATORY LANDSCAPE: This provision engages GDPR Article 22, which grants individuals the right not to be subject to solely automated decisions that produce legal or similarly significant effects, and requires human intervention mechanisms. The EU AI Act similarly mandates human oversight for high-risk AI systems in employment, credit, and housing contexts. The document's prohibition aligns directionally with these requirements but does not constitute a compliance certification. 2. GOVERNANCE EXPOSURE: High for enterprise customers deploying Command R in any workflow that generates outputs used in individual-level decisions. The provision does not define the minimum level of human involvement required, creating interpretive ambiguity for compliance teams designing human-in-the-loop architectures. 3. JURISDICTION FLAGS: EU and EEA deployments face the most explicit regulatory obligations around human oversight of automated decision-making under GDPR and the EU AI Act. US federal law does not currently impose a general human-in-the-loop requirement, though sector-specific frameworks such as the Equal Credit Opportunity Act and Fair Housing Act may impose adverse action explanation requirements relevant to AI-assisted decisions. 4. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should document their human oversight procedures and assess whether those procedures satisfy both Cohere's contractual requirement and applicable regulatory standards. Procurement teams should evaluate whether Cohere's customer agreements provide any further specification of the human-in-the-loop standard required. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should audit AI-assisted workflows to identify any decision points where Command R outputs are used to make or significantly influence individual-level decisions without documented human review. Human oversight policies and logging mechanisms should be implemented and reviewed against both this document's prohibition and applicable regulatory standards in the deployment jurisdiction.
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This provision establishes a human oversight requirement as a condition of permitted use, which intersects with regulatory mandates under the EU AI Act and GDPR Article 22 for automated decision-making systems affecting individuals.
Under this provision, using Command R model outputs to make consequential decisions about individuals without human review is identified as a prohibited use case that violates Cohere's Usage Guidelines and Terms of Use. The document does not define the threshold for what constitutes an important decision or specify what level of human involvement satisfies the requirement.
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