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

GPT-5.5 Pro Proxy Safety Evaluation Methodology

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Document Record

What it is

The document states that GPT-5.5 Pro safety evaluations are generally based on GPT-5.5 evaluation results used as proxies, with separate evaluation conducted only where OpenAI judges that the parallel test-time compute setting could materially affect risk or safeguard posture.

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)

This provision establishes that GPT-5.5 Pro, a distinct product configuration, relies primarily on safety evaluations conducted for a different operational setting. Compliance teams assessing AI model governance should evaluate whether this proxy methodology meets the independent evaluation expectations of applicable frameworks, particularly for higher-compute configurations that may exhibit different capability profiles.

Interpretive note: The document does not specify which capability categories or risk domains triggered separate GPT-5.5 Pro evaluation, limiting assessment of the proxy methodology's adequacy for specific deployment contexts.

Consumer impact (what this means for users)

Under these terms, users of GPT-5.5 Pro operate under a safety posture that is primarily informed by evaluations conducted on GPT-5.5 rather than on GPT-5.5 Pro directly, except in cases where OpenAI determines the compute setting materially affects risk. The document does not specify which capability categories triggered separate GPT-5.5 Pro evaluation.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
We generally treat GPT‑5.5's safety results as strong proxies for GPT‑5.5 Pro, which is the same underlying model using a setting that makes use of parallel test time compute. As noted below, we separately evaluate GPT‑5.5 Pro in certain cases because we judge that the setting could materially impact the relevant risks or appropriate safeguards posture.

Excerpt from OpenAI's GPT-5.5 System Card

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: The proxy evaluation methodology engages with EU AI Act conformity assessment requirements, which may require that safety evaluations reflect the actual operational configuration of the deployed system.

Insight

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Provision details

Document information
Document
OpenAI GPT-5.5 System Card
Entity
OpenAI
Document last updated
July 6, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-016509
Document ID
CA-D-00924
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
9cd35182163188c95261409ddc3e9c4a3d892b1d27b8ea9e5eb4a18c682a9df9
Analysis generated
July 9, 2026 08:25 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: OpenAI GPT-5.5 System Card
Record ID: CA-P-016509
Captured: 2026-07-09 08:25:24 UTC
SHA-256: 9cd35182163188c9…
URL: https://conductatlas.com/platform/openai/openai-gpt-55-system-card/provision/CA-P-016509/gpt-55-pro-proxy-safety-evaluation-methodology/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does OpenAI's GPT-5.5 Pro Proxy Safety Evaluation Methodology clause do?

This provision establishes that GPT-5.5 Pro, a distinct product configuration, relies primarily on safety evaluations conducted for a different operational setting. Compliance teams assessing AI model governance should evaluate whether this proxy methodology meets the independent evaluation expectations of applicable frameworks, particularly for higher-compute configurations that may exhibit different capability profiles.

How does this clause affect you?

Under these terms, users of GPT-5.5 Pro operate under a safety posture that is primarily informed by evaluations conducted on GPT-5.5 rather than on GPT-5.5 Pro directly, except in cases where OpenAI determines the compute setting materially affects risk. The document does not specify which capability categories triggered separate GPT-5.5 Pro evaluation.

Is ConductAtlas affiliated with OpenAI?

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