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Developers and businesses building applications on Cohere's services are required to ensure that their own applications comply with Cohere's Universal Requirements and that their end users are also bound by substantially similar restrictions.
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 creates a contractual chain of compliance obligations that flows from Cohere through Customer Application operators to end users, requiring operators to implement their own acceptable use frameworks that mirror Cohere's Universal Requirements and to contractually bind their users to those requirements.
Interpretive note: The policy does not define a minimum standard for 'substantially similar requirements,' leaving the compliance threshold subject to operator interpretation and potential dispute.
The updated policy removes all substantive acceptable use requirements that were previously posted and enforceable. Users no longer have a referenced standard defining what conduct is prohibited on the platform. The removal of enforcement procedures means users cannot verify what conduct may trigger access restriction, suspension, or termination. The elimination of the child safety and sexually explicit content prohibitions from the posted policy creates uncertainty about whether these protections remain in effect through other terms or have been abandoned.
View change record →Under this clause, consumers using applications built on Cohere's platform are required by the application operator to comply with restrictions substantially similar to Cohere's Universal Requirements, even if those consumers have no direct contractual relationship with Cohere. The specific mechanism for imposing those requirements on end users is left to the operator's discretion.
Cross-platform context
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"You must ensure your Customer Application complies with the Universal Requirements of this Usage Policy and that users of your Customer Application understand and are required to comply with substantially similar requirements.Excerpt from Cohere's Usage Policy
1) REGULATORY LANDSCAPE: The downstream compliance requirement creates a contractual structure in which Customer Application operators assume responsibility for their end users' compliance with Cohere's policy. This structure may interact with platform liability frameworks in applicable jurisdictions, including Section 230 of the Communications Decency Act in the US and the EU Digital Services Act, which allocate liability for user-generated content differently depending on operator knowledge and control mechanisms. 2) GOVERNANCE EXPOSURE: Medium. The requirement to ensure end users comply with 'substantially similar requirements' is operationally significant but uses imprecise language that does not specify the minimum acceptable compliance mechanism. Operators must make independent judgments about what constitutes a 'substantially similar' acceptable use framework, which creates interpretive risk. 3) JURISDICTION FLAGS: EU operators face heightened exposure under the Digital Services Act, which imposes specific content moderation and transparency obligations on platform operators that may interact with this downstream compliance requirement. Operators in jurisdictions with consumer contract formation requirements should assess whether their mechanism for binding end users to these requirements is legally effective under applicable contract law. 4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers building commercial products on Cohere should review their end user license agreements or terms of service to confirm they include prohibited use provisions that meet the 'substantially similar' standard. The policy does not specify whether Cohere retains audit rights over Customer Application terms of service, but the operator remains contractually responsible for compliance. 5) COMPLIANCE CONSIDERATIONS: Legal teams at organizations building on Cohere's API should review their existing end user agreements and update them to incorporate the Universal Requirements categories if not already present. Particular attention should be given to the High Risk Activities, child safety, and surveillance prohibitions, which are operationally distinct and may require specific disclosure or implementation mechanisms beyond general acceptable use language.
This provision creates a contractual chain of compliance obligations that flows from Cohere through Customer Application operators to end users, requiring operators to implement their own acceptable use frameworks that mirror Cohere's Universal Requirements and to contractually bind their users to those requirements.
Under this clause, consumers using applications built on Cohere's platform are required by the application operator to comply with restrictions substantially similar to Cohere's Universal Requirements, even if those consumers have no direct contractual relationship with Cohere. The specific mechanism for imposing those requirements on end users is left to the operator's discretion.
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