The policy prohibits using OpenAI services to automate high-stakes decisions in enumerated sensitive domains without human review. The listed domains include housing, employment, financial activities and credit, insurance, legal, medical, essential government services, national security, migration, and law enforcement.
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 requires that any deployment of OpenAI services involving automated decisions in the named sensitive domains include human review as a condition of permitted use. Organizations integrating OpenAI into decision-support or automated decision-making workflows in regulated sectors must assess whether their processes satisfy this human review requirement to remain within permitted use.
Interpretive note: The policy does not define what constitutes sufficient human review, creating ambiguity in determining compliance for automated workflows that include some but limited human involvement.
Under this clause, users and developers are prohibited from using OpenAI services to fully automate consequential decisions in domains including credit, housing, employment, medical care, and law enforcement without incorporating human review. The agreement establishes human oversight as a mandatory condition for use in these categories.
Cross-platform context
See how other platforms handle Prohibition on Automated High-Stakes Decisions Without Human Review 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 high-risk AI system requirements, which mandate human oversight for AI systems deployed in domains including employment, credit, education, migration, and law enforcement.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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This provision requires that any deployment of OpenAI services involving automated decisions in the named sensitive domains include human review as a condition of permitted use. Organizations integrating OpenAI into decision-support or automated decision-making workflows in regulated sectors must assess whether their processes satisfy this human review requirement to remain within permitted use.
Under this clause, users and developers are prohibited from using OpenAI services to fully automate consequential decisions in domains including credit, housing, employment, medical care, and law enforcement without incorporating human review. The agreement establishes human oversight as a mandatory condition for use in these categories.
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