Skip to content
Sprint projectOct 25, 2026Bend, Oregon, USA

Evaluation Before Regulation: How LLM Pricing Agents Come to Collude, and What Stops It

Christopher Graham · Team CKAI

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

Read the report

Report: Evaluation Before Regulation: How LLM Pricing Agents Come to Collude, and What Stops It

Code (opens in new tab)
Share

As AI agents take on concurrent tasks, they can collude against the people they serve: in one recent incident, about 1,200 agents meant to work in isolation coordinated to beat the system grading them. Stopping this depends on why agents collude. Human cartels hold together because members punish those who break ranks. I tested whether AI agents collude the same way, in a setting where collusion is easy to measure: agents competing on price, where collusion shows up as prices held above the competitive level. They do not. When I forced one agent to break ranks, the others didn't punish it; they ignored it or followed it. The agents collude because they start from a comfortable position and learn too slowly to leave it, not because they police each other. That diagnosis changes the remedy. Limiting what agents see of each other, a standard anti-cartel tool, didn't stop collusion, and wiping their memory made it worse. Two simple interventions prevented it in every game: telling each agent the move that would serve it best, and occasionally making one agent break ranks. Reading the agents’ reasoning was no guide: judge them by what they do, not what they say, as the agents talking most about coordinating were the ones competing. The lesson, which I expect to carry to other multi-agent tasks, is: test first, with a cheap experiment that makes one agent break ranks and watches how the other agents respond, then take corrective action.

Reviews

Judging this Sprint?

Review “Evaluation Before Regulation: How LLM Pricing Agents Come to Collude, and What Stops It”

Your public critique appears on the project page without your name. Reviews of strong projects are shared with funders, as you choose below.

Not shown on the project page.

Shown on the project page, without your name.

Only the Apart team reads this, and funders if you agree below.

Decline to score

Only when the quality of the writing makes the work impossible to follow. Say why in your private critique; the project page shows only that a judge declined, not why.

How much would this matter for the field 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 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.
Sharing your name *

When we share a strong project with funders, your name, scores and public critique go with it, confidentially; this choice is only about whether your name is public. If you think this project deserves funding, please also endorse it: that carries the most weight.

Share my private critique with funders *

See our Privacy Policy.

  1. This is a strong paper that suggests that before trying to stop AI pricing agents from keeping prices high, first figure out why they are doing it. The main findings are clear and easy to follow. Hiding competitors’ prices did not help, and wiping the agents’ memory actually made prices go up, but simply showing each agent its best price stopped high prices in every game. These findings are the most useful part, so in my opinion they should be highlighted and shared upfront. The finding that agents’ written reasoning can be misleading is interesting, but it is concluded based on only a small number of games, so testing it more would make it more convincing. One obvious next step is to try the fixes in more realistic settings, because the best ones depend on knowing the right price, which real platforms may not know. It would also help to explain more simply how an agent following a price cut differs from a punishing one, since both can keep prices high. That could be another area for further exploration.

    Read full reviewShow less
  2. I like the idea of diagnosing why high prices persist before choosing an intervention. The forced-deviation experiments and comparisons across remedies provide more insight than simply testing whether a compliance instruction lowers prices.

    I would be more cautious about the sharp distinction between following and enforcement. Matching a rival’s price cut can discourage future undercutting, even if the agent describes its motive as recovering sales rather than punishing its rival. Your observation that matching can make cutting unprofitable suggests that this distinction deserves more care. The results provide evidence against particular punishment patterns; the abstract’s broader conclusion about how LLM agents collude seems stronger than the tests establish.

    The best-response intervention is interesting, but its success through deference raises another question. Would agents follow an inaccurate recommendation just as readily? Testing noisy or deliberately perturbed recommendations would help distinguish the value of better information from obedience to a platform-supplied number. It would also make the practical implications more convincing, since estimating the relevant demand and profit functions is itself a substantial problem in real markets.

    Finally, I found the diagnosis and policy prescription somewhat difficult to assess because several strong conclusions arrive before the qualifications. A simpler explanation of the non-strategic benchmark, followed by more narrowly stated conclusions in the abstract and recommendations, would make the contribution clearer.

    Read full reviewShow less
  3. This paper makes a simple point very well: before trying to stop collusion, work out what is actually causing it. The author tests whether LLM pricing agents hold prices high because they punish each other for cutting, like a human cartel, or because they start high and learn too slowly to compete prices down. The evidence points clearly to the second. When one agent is forced to cut its price, the others do not punish it - they ignore the cut or follow it down.

    That diagnosis matters, because the remedies behave very differently. Hiding rivals' prices, a standard anti-cartel tool, does nothing here, and wiping the agents' memory actually makes prices higher. Two fixes aimed at slow learning work much better: telling each agent the price that would serve it best, and occasionally forcing one agent to break ranks. Both prevented high prices in every game tested, including with four firms.

    I also liked the finding on the agents' own notes. The agents that talked most about coordinating were the ones competing, so reading their reasoning would have pointed an auditor in exactly the wrong direction.

    One suggestion: the samples are small, so it would be good to see the two successful remedies repeated at larger scale and on other models. The forced-deviation test also struggled to classify agents that were told to punish, which is worth exploring further.

    Overall, a thoughtful paper with a clear, practical message: test first, then choose the remedy.

    Read full reviewShow less

Cite this project

@misc{graham2026evaluation,
  title = {{Evaluation Before Regulation: How LLM Pricing Agents Come to Collude, and What Stops It}},
  author = {Christopher Graham},
  year = {2026},
  month = oct,
  note = {Submitted to AI Collusion Research Sprint, an Apart Research Sprint},
  howpublished = {\url{https://apartresearch.com/sprints/projects/evaluation-before-regulation-how-llm-pricing-agents-come-to-collude-and-what-stops-it-mo61}},
  url = {https://apartresearch.com/sprints/projects/evaluation-before-regulation-how-llm-pricing-agents-come-to-collude-and-what-stops-it-mo61}
}