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An AI model card should state which safety evaluations were run, how they were run, what the results mean, and which limitations remain. It should identify the model version, test conditions, metrics, datasets or scenarios, and any internal or external red-teaming. For general-purpose AI models with systemic risk, the EU AI Act’s Annex XI provides a detailed benchmark, but a public model card is only a summary and does not automatically replace technical documentation required for authorities or downstream providers.

What a safety-testing section must accomplish

A useful model card lets a technically informed reader answer four questions without guessing: What was tested? How was it tested? What happened? and What remains unknown? A pass label, a single benchmark score, or a statement that a model was “safe” cannot answer those questions on its own.

The card should connect every result to a specific model release and test context. A result for one checkpoint, safety configuration, language, modality, or deployment should not be presented as evidence about every other version or use case.

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The 2018 paper Model Cards for Model Reporting established the model-card format as a way to document intended use, performance, and limitations. Safety disclosures extend that idea by making the evaluation process and its boundaries visible.

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Identify the model and the evidence being reported

Model identity and release

Start with the exact model name, release or version identifier, publication date, modalities, and intended tasks. State whether the evaluation covered the base model, an instruction-tuned model, a safety-tuned variant, or a particular API configuration. If filters, system prompts, retrieval components, tool permissions, or other controls were enabled, list them.

Readers also need to know whether results refer to the model before or after a change. Alignment, fine-tuning, reinforcement learning, policy updates, and inference-time safeguards can alter behavior. A card that combines pre-change and post-change results without labeling them creates a misleading trend.

Scope and use context

Define the safety properties and risks that were in scope. Examples might include harmful-content generation, instruction-following under adversarial prompts, privacy leakage, cybersecurity misuse, robustness to distribution shifts, or risks specific to a modality. Explain the intended users and deployment environments, such as a research preview, a consumer chatbot, an internal assistant, or an embedded application.

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Say what was not evaluated. A text-only laboratory test does not establish safety for image, audio, video, tool-use, or autonomous workflows. Testing in one language, jurisdiction, age group, or content domain should not be generalized to all others.

Describe the evaluation method, not just a score

Evaluation strategy and protocol

Describe the overall strategy: which risks were prioritized, how test cases were selected, how often they were repeated, and how reviewers decided whether an output met the criterion. Name protocols, tools, datasets, scenario designs, and sampling rules when disclosure would not create a security problem.

The European Union’s AI Act Annex XI, in its section for general-purpose AI models with systemic risk, calls for “A detailed description of the evaluation strategies, including evaluation results, on the basis of available public evaluation protocols and tools or otherwise of other evaluation methodologies.” That language makes the strategy itself part of the disclosure, not an optional footnote.

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Metrics and test conditions

Define each metric in plain language and give the denominator, threshold, and aggregation method. “Refusal rate,” for example, could mean the percentage of harmful prompts refused, but the figure is uninterpretable without the prompt set, judging rubric, temperature, number of samples per prompt, and treatment of partial compliance.

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Include test conditions that can change outcomes:

  • Model version, system instructions, safety filters, and tool permissions.
  • Sampling settings, number of runs, random seeds where relevant, and timeout or token limits.
  • Languages, modalities, geographic or demographic assumptions, and user profile.
  • Whether prompts were fixed, generated, adaptive, or drawn from incidents.
  • Who judged outputs, what rubric they used, and how disagreements were resolved.

If a metric is not comparable across models because the protocols differ, say so directly rather than ranking the numbers.

Results with interpretation

Report findings in a way that distinguishes measured performance from interpretation. Include sample sizes or coverage descriptions when available, confidence intervals or uncertainty information when calculated, and representative failure patterns. A narrow success on a curated test set should be described as success on that set, not as broad safety.

Show both favorable and unfavorable results. If a model passed a refusal test but produced unsafe content after a multi-turn conversation, the conversational failure belongs in the main findings. Explain whether an observed failure was reproducible, rare, dependent on a particular language, or tied to a deployment control.

Separate model testing, red-teaming, and field testing

NIST’s AI Research and Development (ARIA) materials distinguish three evidence levels. A model card should label which level each result represents because the levels answer different questions.

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Testing level What it examines What it cannot establish by itself What to disclose
Model testing Controlled evaluations of the model’s behavior against defined prompts, datasets, protocols, or tools. How the model behaves in every real deployment, user population, or workflow. Model version, test set or scenario, protocol, metrics, conditions, results, and limitations.
Red-teaming Adversarial attempts to elicit unsafe, deceptive, biased, privacy-sensitive, or otherwise out-of-policy behavior. That all attack paths have been found or that a model is safe after the exercise. Who conducted it, attack areas, access level, method, significant findings, mitigations, and residual gaps.
Field testing Evidence from real or realistic deployment contexts, including user interactions, monitoring, and incident review. That laboratory results alone predict operational risk. Deployment context, monitoring period, user population, incidents, selection bias, and limits on generalization.

A model-level evaluation does not establish performance in a particular application. For example, an assistant may behave acceptably in a static benchmark but create new risks when connected to email, code execution, financial records, or other tools. Field evidence should therefore be reported separately from laboratory scores.

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Explain adversarial testing and what changed afterward

Red-team design

Identify whether adversarial testing was internal, external, or both. Describe the expertise and access provided to testers, the threat areas covered, and whether testers could conduct multi-turn, multilingual, multimodal, tool-use, or social-engineering attacks. If the exercise used a fixed challenge set, adaptive probing, or incident-derived scenarios, state that.

Summarize material findings without publishing details that would create a practical attack guide. You can describe the vulnerability class, affected configuration, severity rationale, reproducibility, and affected users while withholding exploit strings or operational secrets.

Adaptations and retesting

Document significant changes made in response, such as alignment or safety fine-tuning, policy updates, classifier changes, tool restrictions, or monitoring rules. Identify the release containing each change and say whether the reported result was measured before or after it.

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When a mitigation was retested, link the new result to the original finding. If only a subset of attacks was rerun, say that; a successful retest of one prompt family does not prove that the underlying risk is eliminated.

Make limitations an explicit deliverable

Annex XI includes methodology for identifying limitations. In practice, the card should maintain a limitations section rather than scattering caveats through footnotes.

  • Coverage limits: risks, languages, modalities, tools, domains, or user groups not evaluated.
  • Measurement limits: weaknesses in the rubric, judge disagreement, benchmark contamination, small samples, or metrics that capture only one aspect of harm.
  • Operational limits: differences between the tested configuration and the released product, including prompts, filters, latency fallbacks, or tool permissions.
  • Adversarial limits: attack strategies not attempted, tester access restrictions, and the possibility of undiscovered techniques.
  • Time limits: the date of testing and whether later model, policy, or data changes may invalidate results.

State what the evaluation does not establish. “No failure observed in this test set” is materially different from “the model cannot produce this output.”

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A practical workflow for preparing the disclosure

  1. Freeze the subject of the claim. Record the exact model release, configuration, date, and deployment assumptions. Do not combine results from incompatible versions.
  2. Map risks to tests. For each material safety property, list the protocol, scenario or dataset, attack style, metric, threshold, and owner. Mark risks with no evaluation rather than silently omitting them.
  3. Record conditions and provenance. Preserve prompts or scenario-generation rules, sampling settings, judge instructions, tool permissions, and whether evaluators were internal or external.
  4. Analyze failures, not only aggregate scores. Group failures by cause, severity, reproducibility, language or modality, and whether a deployment control changed the outcome.
  5. Run and document adversarial testing. Include red-team scope, access, findings, mitigations, and any disclosure restrictions.
  6. Retest material mitigations. Label pre-mitigation and post-mitigation results, and identify residual attack paths.
  7. Write the limitations before the headline. Check that every broad-sounding claim is narrowed to the evidence that supports it.
  8. Publish an update trail. Give each revision a date, version identifier, changed tests, changed results, and unresolved items.

How the EU AI Act changes the audience and level of detail

The EU AI Act is a concrete benchmark, not a universal model-card standard. Annex XI addresses technical documentation for providers of general-purpose AI models, with additional detail for models that pose systemic risk. Its systemic-risk provisions cover evaluation strategies and results, criteria and metrics, methods for identifying limitations, and applicable adversarial testing.

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The European Commission distinguishes at least two documentation audiences. Authorities may request technical documentation, while downstream providers need information about a model’s capabilities and limitations so they can understand and meet obligations for their own AI systems. A public card can summarize the relevant evidence for users and downstream developers, but it should not imply that the public summary automatically satisfies every legal documentation duty.

For systemic-risk models, Commission materials also identify standardized evaluation using available protocols and state-of-the-art tools, documented adversarial testing, systemic-risk assessment and mitigation, serious-incident tracking and reporting, and cybersecurity protection. The exact obligations depend on the provider, model classification, market activity, and applicable law at the time of deployment.

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Use a consistent structure when comparing model cards

Comparisons are meaningful only when the evidence is aligned. Use the same axes for every model and mark differences in method instead of treating unlike scores as a leaderboard.

Comparison axis Questions to answer
Risks and contexts Which harms, users, languages, modalities, tools, and deployments were evaluated?
Testing level Is the evidence from model testing, red-teaming, field testing, or a combination?
Protocol and tools What benchmark, scenario design, evaluator process, or standardized tool was used?
Metrics and conditions How is each score defined, and under what prompts, settings, sample size, and thresholds?
Findings and limitations What passed, failed, remained uncertain, or was not tested?
Independence Were evaluators internal, external, or both, and what access did they receive?
Version and adaptations Which release was tested, and what changed after testing?

If a value is not disclosed, write “not stated” and identify the missing item. Do not infer that an undisclosed test was performed.

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Common disclosure failures and how to fix them

“The model passed safety tests”

Replace the label with the test name, scope, metric, conditions, result, and known failure modes. A pass is meaningful only relative to a defined protocol.

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One score presented as overall safety

Break the result into risk areas and testing levels. Explain what the score measures and what it excludes.

Red-teaming mentioned without findings

State the attack areas, tester access, significant findings, mitigations, and residual uncertainty. Confidentiality can limit exploit detail without erasing the existence or significance of the finding.

Old results attached to a new release

Put the version and test date beside every result. If a later release differs, rerun material tests or clearly label the evidence as historical.

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Limitations hidden in a footnote

Give limitations their own section and connect each one to the affected claim, population, modality, or deployment.

A compact disclosure template

Model and release: [name, version, date, modalities]
Intended use and deployment context: [who, where, and how]
Safety properties evaluated: [risks and scenarios]
Testing level: [model testing, red-teaming, field testing]
Protocol and tools: [datasets, prompts, scenarios, evaluator method]
Conditions: [sampling, system instructions, tools, languages, sample size]
Metrics and criteria: [definitions, thresholds, aggregation]
Results: [findings, failures, uncertainty, and affected configurations]
Adversarial testing: [internal/external scope and significant findings]
Changes after testing: [fine-tuning, alignment, controls, retest status]
Limitations and unevaluated areas: [coverage and measurement gaps]
Update history: [date, release, changed evidence]

Bottom line

The strongest safety disclosure is an evidence trail, not a reassuring adjective. Identify the exact model and context, explain the evaluation strategy and conditions, report results with their interpretation, separate model tests from red-teaming and field evidence, document adaptations, and make remaining limitations impossible to miss. That format serves readers, downstream developers, and regulators without claiming that a public model card alone fulfills every technical-documentation obligation.

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