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Model System Cards

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Document Record

What it is

The document lists published system cards for multiple models including GPT-5, GPT-5.1-Codex-Max, GPT-5.2, GPT-5.3-Codex, Sora 2, o3, o4-mini, and associated addenda, which document model-specific safety evaluations, identified risks, and mitigation measures.

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)

System cards constitute OpenAI's primary per-model transparency disclosures, documenting safety evaluations, known limitations, and risk mitigation approaches for each named model. Deployers and enterprise customers using these models in regulated contexts should review the relevant system card to understand the documented risk profile of the specific model in use.

Interpretive note: System cards are listed by title but their full contents are not reproduced on this page; the operational significance of specific disclosures within each card requires review of the individual linked documents.

Consumer impact (what this means for users)

System cards provide users and deployers with model-specific safety evaluation disclosures. The document authorizes access to these cards through linked publications, and each card may contain materially different risk disclosures depending on the model version.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
GPT-5.3-Codex System Card ... GPT-5 System Card ... OpenAI o3 and o4-mini System Card ... Sora 2 System Card

Excerpt from OpenAI's Safety Standards

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: System cards engage with EU AI Act transparency and technical documentation requirements for general-purpose AI models, as well as the NIST AI Risk Management Framework. The EU AI Act may require deployers to maintain records of AI system characteristics and capabilities, for which system cards serve as a primary reference. (2) GOVERNANCE EXPOSURE: Medium. System cards are voluntary disclosures; their legal status as binding representations of model behavior has not been established by authoritative legal sources. Gaps between system card disclosures and actual model behavior could create exposure under consumer protection frameworks. (3) JURISDICTION FLAGS: EU/EEA jurisdictions present heightened exposure under the EU AI Act. Organizations deploying OpenAI models in high-risk application categories should assess whether system card disclosures satisfy EU AI Act Article 53 obligations for general-purpose AI model providers, noting that specific article applicability should be verified against current regulatory text. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise agreements with OpenAI should be reviewed to assess whether system card disclosures are incorporated by reference and whether updates to system cards constitute material changes to service terms. The document does not specify whether system card updates trigger notification obligations to enterprise customers. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should identify which specific model version is deployed within their environment, retrieve the corresponding system card and any applicable addenda, and assess whether the documented risk profile is consistent with the organization's internal AI risk management policies.

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Applicable agencies

  • FTC
    System card disclosures constitute representations about AI product safety and capabilities, which fall within FTC jurisdiction over unfair or deceptive practices.
    File a complaint →

Provision details

Document information
Document
OpenAI Safety Standards
Entity
OpenAI
Document last updated
May 12, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-016417
Document ID
CA-D-00822
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
29a3d40e8275f104584cc6bdb20b0b6a52711666f2f59ee81227d1760ed522ea
Analysis generated
July 9, 2026 04:12 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: OpenAI Safety Standards
Record ID: CA-P-016417
Captured: 2026-07-09 04:12:50 UTC
SHA-256: 29a3d40e8275f104…
URL: https://conductatlas.com/platform/openai/openai-safety-standards/provision/CA-P-016417/model-system-cards/
Accessed: July 24, 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 Model System Cards clause do?

System cards constitute OpenAI's primary per-model transparency disclosures, documenting safety evaluations, known limitations, and risk mitigation approaches for each named model. Deployers and enterprise customers using these models in regulated contexts should review the relevant system card to understand the documented risk profile of the specific model in use.

How does this clause affect you?

System cards provide users and deployers with model-specific safety evaluation disclosures. The document authorizes access to these cards through linked publications, and each card may contain materially different risk disclosures depending on the model version.

Is ConductAtlas affiliated with OpenAI?

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