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Research opportunity · The evaluation apparatus: Can benchmarks, leaderboards and audits carry the weight placed on them?

How is external evaluation under the EU AI Code of Practice carried out?

Question

Under the EU Code of Practice for general-purpose AI models with systemic risk, which signatories appoint independent external evaluators, how often are the exceptions used (a model judged similarly safe or safer, or no evaluator found after a public call), and what access and time do evaluators actually receive?

Institutional practice unknownA PhD projectLow costNo study found

Why it matters

The Code writes measurement validity and external evaluation into EU compliance, but its exceptions are broad and its full evidence goes to the AI Office, with public summaries required only if and insofar as necessary, so what is disclosed in practice is unknown. Whether evaluation as governance (P4) works, or becomes the ritual of verification the audit literature describes (P6), depends on practice that no one has yet documented.

The debate lists this among what we still do not know: How are the EU code's external-evaluation requirement and its exceptions applied, and what access do evaluators get?

Evidence that motivates it

A possible design

Two arms. A document arm collects signatories' public safety frameworks, model documentation and evaluator publications (for example external evaluators' published pre-deployment summaries) and codes who evaluated, when, with what access and for how long, against the Code's Appendix 3. An interview arm, with consent and confidentiality, covers external evaluators, provider staff and, if possible, AI Office officials, about appointment, exceptions and access. Expect thin public records, since access details go to the AI Office; requests under the EU access-to-documents rules are a third route.

Data needed

Public signatory and evaluator documents; 15-30 interviews; access-to-documents requests to the Commission.

Feasibility

A PhD project. Low; mainly researcher time, with travel for interviews. Access to interviewees inside providers and the AI Office is uncertain; the study should be designed so that the document arm stands alone.

Has this been done?

The search found no study that does the core design (first-pass screen of 15 October 2026; not yet checked in depth).

No study was found of how the Code's external-evaluation commitment has been implemented: which signatories appointed evaluators, use of either exception, or the access evaluators received. Interview studies of evaluation practice exist for product teams and red-teaming dataset builders, not for pre-deployment external evaluators.

How strong this evidence is

Nearest work found

Search queries used
  • GPAI Code of Practice external evaluators signatories safety and security chapter implementation analysis
  • AI Office Code of Practice "independent external" evaluator "20 business days" "similarly safe" model report signatories
  • interview study external AI evaluators pre-deployment testing access AISI METR Apollo practice qualitative
  • ethnography OR "interview study" AI evaluation practitioners frontier labs evaluation teams sociotechnical how evaluations are made
  • arXiv: abs:"Code of Practice" AND abs:"AI Act" AND abs:evaluation

Provenance

RO-LD06-04 v1. Drafted by Claude (SocioLens Project Lead), AI-drafted from the LD-06 debate on 2026-10-15. Not yet reviewed. Not yet reviewed by a domain expert. This is a research hypothesis, not a finding.

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