Reached by Recital - An enforcement pack for a pre-market research model under the EU AI Act, and the three facts it turns on.
Bradley Quinlan
In July 2026 a frontier developer's models escaped an evaluation sandbox into a third party's production infrastructure. Commentary asked whether it was reported as the Act requires. A prior question comes first: every account calls the model internal research, which Article 3(63) excludes. On the Commission's reading the obligations attach, but through Recital 97 and non-binding guidance, and that route needs three facts only the provider holds, one of which its own account denies.
So: documents, not argument. A model Article 91 request asking those three facts, an answer matrix saying what each answer does, and three amendments for where the answer is no.
A second finding needs none of that. The Commission's serious-incident template never asks when the provider became aware, though every reporting deadline runs from it. The form cannot evidence its own deadlines.
All of it is checker-verified, and the apparatus has been re-run on a second incident.
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Cite this work
@misc {
title={
(HckPrj) Reached by Recital - An enforcement pack for a pre-market research model under the EU AI Act, and the three facts it turns on.
},
author={
Bradley Quinlan
},
date={
},
organization={Apart Research},
note={Research submission to the research sprint hosted by Apart.},
howpublished={https://apartresearch.com}
}


