Beyond standard approval, developers building applications in healthcare, legal advice, products for minors, or systems that make important automated decisions about people must go through a separate, elevated review process before deploying.
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 distinct compliance tier for applications with elevated risk of harm, meaning developers in these categories cannot proceed based on standard approval alone and must proactively initiate a special review with Cohere.
Interpretive note: The specific procedural steps and criteria for special approval are not detailed in the document, creating uncertainty about what constitutes sufficient compliance with this requirement.
Individuals who interact with Cohere-powered health, legal, or automated decision-making applications benefit from this provision's requirement that such applications receive heightened scrutiny before deployment; minors are specifically identified as a protected group requiring additional safeguards.
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"Developers must outline and get approval for their use case to access the Cohere API. Certain use cases require special approval, such as medical or health-related applications, legal advice, applications targeting or used by minors, and high-stakes automated decision-making affecting individuals.— Excerpt from Cohere's Cohere Usage Policy
(1) REGULATORY LANDSCAPE: Medical and health applications engage HIPAA where protected health information is processed, as well as FDA guidance on AI-based clinical decision support tools. Legal advice applications may engage professional licensing regulations in applicable jurisdictions. Minor-facing applications engage COPPA in the United States and the EU AI Act's provisions on systems targeting vulnerable groups. High-stakes automated decision-making engages GDPR Article 22 rights regarding automated processing and the EU AI Act's high-risk AI system classifications under Annex III. (2) GOVERNANCE EXPOSURE: High. Deployment in any of these categories without special approval constitutes a breach of the Terms of Service. More significantly, in regulated sectors such as healthcare and financial services, deployment without appropriate safeguards may independently trigger regulatory violations that extend beyond the contractual relationship with Cohere. (3) JURISDICTION FLAGS: EU-based deployments in health, legal, and automated decision-making categories face the highest regulatory exposure under the EU AI Act and GDPR. US deployments involving health data face HIPAA exposure. Deployments involving children face COPPA and, in the EU, GDPR provisions on minors' data. California deployments may also engage CCPA's sensitive data categories. (4) CONTRACT AND VENDOR IMPLICATIONS: Organizations in healthcare, legal, or financial services procuring Cohere's API must ensure that special approval documentation is obtained and retained prior to deployment. B2B agreements in these sectors should include representations from the API customer that special approval has been granted and that required safeguards are in place. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should build a pre-deployment checklist that flags whether a proposed use case falls within any special-approval category. For health and legal applications, additional review by privacy counsel and, where applicable, clinical or legal subject matter experts is advisable. Minor-facing applications should be reviewed for COPPA consent mechanism compliance and age verification adequacy.
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This provision creates a distinct compliance tier for applications with elevated risk of harm, meaning developers in these categories cannot proceed based on standard approval alone and must proactively initiate a special review with Cohere.
Individuals who interact with Cohere-powered health, legal, or automated decision-making applications benefit from this provision's requirement that such applications receive heightened scrutiny before deployment; minors are specifically identified as a protected group requiring additional safeguards.
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