OpenAI · OpenAI GPT-5.5 System Card · View original document ↗

Biological and Chemical Risk Assessment

High severity Medium confidence Explicitdocumentlanguage Unique · 0 of 352 platforms
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Document Record

What it is

The document discloses that GPT-5.5 was assessed for its potential to provide assistance in biological and chemical weapons-relevant domains, received a medium risk rating, and is subject to usage policy restrictions on such content as the primary mitigation mechanism.

This analysis describes what OpenAI'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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

The disclosure that GPT-5.5 was evaluated and rated at medium risk in biological and chemical threat domains is operationally significant for regulatory compliance purposes, as these domains are subject to specific legal restrictions in most jurisdictions. The primary mitigation described is usage policy enforcement rather than absolute technical restriction.

Interpretive note: The document does not specify the precise content categories or request patterns that trigger usage policy enforcement in the biological and chemical risk domains, making it difficult to assess the practical scope of the disclosed mitigation.

Consumer impact (what this means for users)

Under the terms disclosed in this document, GPT-5.5 is subject to usage policy restrictions on biological and chemical weapons-relevant content, with policy enforcement serving as the primary control mechanism. Access to this category of content is not described as subject to an absolute technical block.

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▸ View Original Clause Language DOCUMENT RECORD
"
GPT-5.5 was evaluated for potential uplift in biological and chemical threat domains as part of the Preparedness Framework assessment. The model received a medium risk rating in these categories, with mitigations including usage policy restrictions on content related to weapons of mass destruction.

— Excerpt from OpenAI's OpenAI GPT-5.5 System Card

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

1) REGULATORY LANDSCAPE: Biological and chemical threat uplift capabilities engage the Biological Weapons Anti-Terrorism Act and the Chemical Weapons Convention Implementation Act in the US, as well as equivalent biosecurity and chemical security frameworks in other jurisdictions. Export control regulations administered by the US Department of Commerce and State Department may apply to the export of AI systems with assessed dual-use capabilities in these domains. The EU AI Act's systemic risk provisions are also relevant. 2) GOVERNANCE EXPOSURE: High. The disclosure of medium-rated biological and chemical threat uplift capability, managed primarily through usage policy enforcement, creates significant governance exposure for regulators and enterprise operators in biosecurity-sensitive contexts. The adequacy of policy-based mitigations for this category of risk is subject to ongoing regulatory scrutiny. 3) JURISDICTION FLAGS: US federal law enforcement and intelligence agencies maintain oversight interests in AI systems with assessed bioweapons-adjacent capabilities. EU biosecurity and dual-use export control authorities are relevant for European deployments. Any cross-border provision of API access to this model may require export control analysis. 4) CONTRACT AND VENDOR IMPLICATIONS: Operators providing GPT-5.5 access in research, life sciences, or defense-adjacent contexts should conduct specific due diligence on their obligations under applicable biosecurity and export control frameworks and should not rely solely on OpenAI's usage policy enforcement as their compliance mechanism. 5) COMPLIANCE CONSIDERATIONS: Life sciences and defense sector operators should conduct specific risk assessments for GPT-5.5 deployments referencing this disclosure and should implement supplementary technical and procedural controls beyond what OpenAI's usage policies provide. Legal teams should evaluate whether applicable biosecurity regulations impose affirmative obligations to restrict AI system access in ways that go beyond usage policy enforcement.

Full compliance analysis

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Applicable agencies

  • FTC
    The FTC has authority over representations made about AI safety measures in consumer and business-facing products, relevant to the accuracy of disclosed mitigations for biological and chemical risk categories.
    File a complaint →

Provision details

Document information
Document
OpenAI GPT-5.5 System Card
Entity
OpenAI
Document last updated
July 6, 2026
Tracking information
First tracked
July 6, 2026
Last verified
July 6, 2026
Record ID
CA-P-013399
Document ID
CA-D-00924
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
1408d102faed20b4eb10fc79b0fdedfb44cacf7d752f2293429e5f342d0fe485
Analysis generated
July 6, 2026 22:09 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: OpenAI GPT-5.5 System Card
Record ID: CA-P-013399
Captured: 2026-07-06 22:09:40 UTC
SHA-256: 1408d102faed20b4…
URL: https://conductatlas.com/platform/openai/openai-gpt-55-system-card/biological-and-chemical-risk-assessment/
Accessed: July 7, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does OpenAI's Biological and Chemical Risk Assessment clause do?

The disclosure that GPT-5.5 was evaluated and rated at medium risk in biological and chemical threat domains is operationally significant for regulatory compliance purposes, as these domains are subject to specific legal restrictions in most jurisdictions. The primary mitigation described is usage policy enforcement rather than absolute technical restriction.

How does this clause affect you?

Under the terms disclosed in this document, GPT-5.5 is subject to usage policy restrictions on biological and chemical weapons-relevant content, with policy enforcement serving as the primary control mechanism. Access to this category of content is not described as subject to an absolute technical block.

Is ConductAtlas affiliated with OpenAI?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenAI.