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Sprint projectSep 14, 2026Toronto, Ontario, Canada

An Argument for the Reporting of Serious Hazards

Ilyass Mofaddel , Louis Mandela Brown · Team Pretty Tired

Submitted to AI Incident Response Sprint. Sprint projects are early-stage work by participants, not Apart Research publications.

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Report: An Argument for the Reporting of Serious Hazards

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Mandatory reporting of serious incidents does not include near-misses in the Artificial Intelligence Act or the Transparency in Frontier Artificial Intelligence Act. We make the argument that it should be the case, and use the criteria from the International Civil Aviation Organization to help determine what would constitute a near-miss worthy of reporting. In the process, we also clarify common misconceptions between the definition of incident in AI and Aviation.

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How much would this matter for AI safety if it worked? How innovative is it? For scores of 4-5: is this actually new to the field, or replicating recent work?

Scoring guide
  1. 1Negligible. No clear problem addressed, or no meaningful novelty.
  2. 2Limited. Addresses a real problem but with a generic or well-trodden approach. Incremental at best.
  3. 3Moderate. Clear problem with a reasonable approach; some novelty in framing or method beyond routine application of existing tools.
  4. 4Significant. Important problem with an original approach, or identifies a neglected problem area. A valuable contribution others could build on.
  5. 5Exceptional. Tackles a critical AI safety problem with a genuinely novel approach, or opens a new research direction. Clear theory of change. You'd be excited to share this with researchers in the area.

How sound are methodology, implementation, and findings?

Scoring guide
  1. 1Seriously flawed. Methodology broken, results uninterpretable, or implementation doesn't work.
  2. 2Weak. Approach has significant gaps: missing validation, flawed experimental design, or incomplete implementation.
  3. 3Competent. Technically solid given the short duration. Methodology makes sense, results are interpretable, limitations acknowledged, work builds toward clear conclusions.
  4. 4Strong. Thorough methodology with convincing validation. Results clearly support conclusions. Immediately useful for future work.
  5. 5Exceptional. Ambitious scope executed rigorously. Surprising findings, novel methods, or unusually robust validation.

How clearly are work, findings, and impact potential communicated?

Scoring guide
  1. 1Incomprehensible. Cannot determine what the project is actually claiming or doing.
  2. 2Hard to follow. Key information buried, missing, or diluted by excessive length. Significant effort to extract main points.
  3. 3Clear enough. Can understand the problem, approach, and results without undue effort. Core content clearly present: problem, method, findings, limitations.
  4. 4Well presented. Easy to follow, well-structured, appropriate level of detail. Target audience would get it quickly.
  5. 5Exceptionally clear. A pleasure to read. Complex ideas made accessible. Could serve as a model for how to present this type of work.

  1. I appreciate the authors' comparison to ICAO's 'incident' definition to those of prominent AI laws. I also appreciated the discussion on over- vs. under-reporting. Going forward, I'd love to see more analysis on whether existing laws give regulators latitude to reinterpret the standard for reportable incident, or whether new laws/amendments will be required.

  2. This submission argues that serious near-misses should be mandatory to report under the AI Act and SB 53, drawing on the ICAO framework. It attempts terminology harmonisation, noting that an ICAO 'incident' corresponds to an OECD 'hazard', while an AI Act 'serious incident' corresponds to an aviation 'accident'. The limitations section raises the over-reporting objection and the absence of any AI equivalent to an independent investigator.

    However, the central claim does not entirely hold: the paper says near-misses are excluded from these frameworks, then notes that SB 53 covers attempted evasion, placing other cases in a grey zone, which could be expanded. Second, the ICAO test asks how many safety barriers existed between the event and a crash, and it can answer it because the barriers are physical, certified and countable; whether 'limited safeguards' can be assessed for a frontier model, and by whom, is not addressed, nor is Article 3(49) of the EU AIA engaged where the submission has argued for changed definitions. H.R. 9917 is described both as a Texas bill and a federal one.

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Cite this project

@misc{mofaddel2026argument,
  title = {{An Argument for the Reporting of Serious Hazards}},
  author = {Ilyass Mofaddel and Louis Mandela Brown},
  year = {2026},
  month = sep,
  note = {Submitted to AI Incident Response Sprint, an Apart Research Sprint},
  howpublished = {\url{https://apartresearch.com/sprints/projects/an-argument-for-the-reporting-of-serious-hazards-bobf}},
  url = {https://apartresearch.com/sprints/projects/an-argument-for-the-reporting-of-serious-hazards-bobf}
}

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