OpenAI · Usage Policies

Model Spec Incorporation by Reference

Medium severity
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What it is

OpenAI's usage rules don't just come from this policy document — they also come from a separate 'model spec' document that governs how its AI models behave, and that document can change independently.

Consumer impact (what this means for users)

The actual capabilities and restrictions of OpenAI's AI models are partly governed by a separate document (the model spec) that can change without direct notice to you — meaning what ChatGPT will or won't do for you today may change in the future without any formal announcement.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
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    Sign up for OpenAI policy update notifications at https://openai.com/form/usage-policy-update/ to receive alerts when the usage policy or model spec is updated. This allows you to proactively adjust your use of OpenAI's services if behavioral rules change.

Cross-platform context

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Why it matters (compliance & risk perspective)

Because the model spec is incorporated by reference and can evolve without formal versioning or user notification, the behavioral rules governing what OpenAI's AI will and won't do are effectively a moving target for both users and developers building on the API.

View original clause language
Our models are trained on our safety alignment research and governed by our model spec, which guides how they behave across different contexts and use cases.

Institutional analysis (Compliance & legal intelligence)

REGULATORY FRAMEWORK: This incorporation-by-reference mechanism engages FTC Act Section 5 (potentially deceptive if users are not adequately informed that governing rules exist in a separate, living document), EU GDPR Article 13 (transparency obligations requiring clear disclosure of data processing rules), and the EU AI Act Articles 12-13 (transparency and information obligations for AI systems, particularly high-risk systems). The FTC, EU Data Protection Authorities, and EU AI Office are relevant enforcement bodies.

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Applicable agencies

  • FTC
    FTC has authority over deceptive practices including inadequate disclosure of material changes to product behavior or governing rules under FTC Act Section 5.
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Provision details

Document information
Document
Usage Policies
Entity
OpenAI
Document last updated
March 5, 2026
Tracking information
First tracked
March 10, 2026
Last verified
April 27, 2026
Record ID
CA-P-003129
Document ID
CA-D-00005
Evidence Provenance
Source URL
Wayback Machine
SHA-256
d69a24617758e5b44e4be8eedeceb598a26dc4e280f2ab1469a45b64203e7403
Verified
✓ Snapshot stored   ✓ Change verified
How to Cite
ConductAtlas Policy Archive
Entity: OpenAI | Document: Usage Policies | Record: CA-P-003129
Captured: 2026-03-10 03:28:59 UTC | SHA-256: d69a24617758e5b4…
URL: https://conductatlas.com/platform/openai/usage-policies/model-spec-incorporation-by-reference/
Accessed: May 2, 2026
Classification
Severity
Medium
Categories

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