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Sprint projectSep 13, 2026Kabirwala, Pakistan

Draft Request for Information under Regulation (EU) 2024/1689: Regulatory Response to Unsanctioned Agent Behaviour During Cyber Testing and the July 2026…

Muhammad Akash Awan, Sarah Jones, Sunil Franklin · Team Article 91

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

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Report: Draft Request for Information under Regulation (EU) 2024/1689: Regulatory Response to Unsanctioned Agent Behaviour During Cyber Testing and the July 2026…

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This report presents a draft Request for Information (RFI) prepared under Article 91(1) of Regulation (EU) 2024/1689, the AI Act. The RFI concerns publicly reported unsanctioned agent behaviour during cyber testing and the July 2026 Hugging Face incident. Its purpose is not to determine liability. Rather, it provides a proportionate mechanism for the European AI Office to obtain the documentation needed to assess whether the relevant provider and model fall within the AI Act, whether a general-purpose AI model may present systemic risk, and whether the provider has met the documentation, evaluation, incident-reporting, and cybersecurity obligations that apply. The report translates the draft RFI into a structured research submission. It sets out the legal basis, public-information context, safeguards for confidential and cybersecurity-sensitive material, and the 19 categories of information sought in Annex I. It also explains why the request is organised around verifiable records: the incident timeline, model and configuration status, evaluation conditions, evidence integrity, containment, and mitigation. The result is a regulator-facing instrument designed to support fact-finding without presuming that the public account is complete or that an infringement has occurred.

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  1. This document collates and concretises what the Office would ask in an initial set of RFIs on the incidents, with direct references to the relevant Articles of the Act. It could be directly useful to the Office, and the specific information it would elicit also looks useful for any subsequent enforcement action.

  2. This submission drafts an Article 91(1) Request for Information for the July 2026 Hugging Face incident. Question 3 is particularly strong – instead of leaving scope to the provider, it considers whether the Article 2 research exemption survives when a model reaches Union infrastructure through its own unauthorised action rather than deliberate deployment. The evidence design is good, particularly the timestamp sequence separating occurrence, technical detectability, automated detection, human review and containment, and the requirement for corroborating records held outside any agent-accessible environment.

    Question 12 departs from the submission's posture by asking for findings that "concluded the zero-day had been patched" and why the agents' recreation of the message board went undetected, which could be reframed as a more open request without presupposition to keep the posture consistent. One question runs to eleven sub-categories of controls, another seeks every attempted interaction whether successful or not, with no narrowing rationale: a shorter first-instance request with a defined escalation path would be better.

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Cite this project

@misc{awan2026draft,
  title = {{Draft Request for Information under Regulation (EU) 2024/1689: Regulatory Response to Unsanctioned Agent Behaviour During Cyber Testing and the July 2026 Hugging Face Incident}},
  author = {Muhammad Akash Awan and Sarah Jones and Sunil Franklin},
  year = {2026},
  month = sep,
  note = {Submitted to AI Incident Response Sprint, an Apart Research Sprint},
  howpublished = {\url{https://apartresearch.com/sprints/projects/draft-request-for-information-under-regulation-eu-20241689-regulatory-response-to-unsanctioned-agent-behaviour-during-cyber-testing-and-the-july-2026-hugging-face-incident-851g}},
  url = {https://apartresearch.com/sprints/projects/draft-request-for-information-under-regulation-eu-20241689-regulatory-response-to-unsanctioned-agent-behaviour-during-cyber-testing-and-the-july-2026-hugging-face-incident-851g}
}

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