The policy prohibits using OpenAI services to automate high-stakes decisions in enumerated sensitive domains, including financial activities, employment, insurance, medical, legal, law enforcement, and national security, without human review.
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
This provision imposes a human-in-the-loop requirement for a broad set of consequential decision domains, which is operationally significant for enterprise and API customers building automated decision-making systems on top of OpenAI services, though the policy does not define what constitutes adequate 'human review.'
Interpretive note: The policy does not define what constitutes adequate 'human review,' creating interpretive uncertainty about the threshold required to satisfy this provision across different use cases and jurisdictions.
Establishes mandatory human oversight for AI systems making consequential decisions in critical sectors, addressing algorithmic accountability and preventing automated harm.
View full change record →This provision establishes that OpenAI services may not be used to make fully automated consequential decisions affecting individuals in domains including credit, employment, insurance, medical care, and legal proceedings without a human review step, as defined by the policy.
Cross-platform context
See how other platforms handle Human Review Requirement for High-Stakes Automated Decisions and similar clauses.
Compare across platforms →"Empower people. People should be able to make decisions about their lives and their communities. So we don't allow our services to be used to manipulate or deceive people, to interfere with their exercise of human rights, to exploit people's vulnerabilities, or to interfere with their ability to get an education or access critical services, including any use for: automation of high-stakes decisions in sensitive areas without human review critical infrastructure education housing employment financial activities and credit insurance legal medical essential government services product safety components national security migration law enforcementExcerpt from OpenAI's Usage Policies
(1) REGULATORY LANDSCAPE: This provision engages the EU AI Act's requirements for human oversight of high-risk AI systems across domains including employment, credit, insurance, and law enforcement.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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This provision imposes a human-in-the-loop requirement for a broad set of consequential decision domains, which is operationally significant for enterprise and API customers building automated decision-making systems on top of OpenAI services, though the policy does not define what constitutes adequate 'human review.'
This provision establishes that OpenAI services may not be used to make fully automated consequential decisions affecting individuals in domains including credit, employment, insurance, medical care, and legal proceedings without a human review step, as defined by the policy.
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