FRONTIER Act vs Voluntary AI Review

No. H.R. 9925 was introduced in the House on July 23, 2026 and referred to committee. It has not passed either chamber and is not in force. Everything about its 6-month cadence, unredacted-access requirement, and penalties describes what the bill would require if enacted as introduced, not a current legal obligation on any lab.

Quoting the bill text as introduced: Section 5(f)(1) requires the independent verification organization to "prepare and submit an assessment report not less frequently than once every 6 months." Section 5(e)(1) requires the developer to "grant an IVO timely access upon request to unredacted materials, records, personnel, systems, and all other information reasonably necessary" to the assessment. Both are drafted as fixed statutory floors, not negotiable terms.

Partially, and in Anthropic’s own words. Per anthropic.com/rsp-updates, RSP version 3.2 "authorizes the [Long-Term Benefit Trust] to request external review of Risk Reports, gives the LTBT the power to approve our selection of external reviewers," and version 3.4 clarifies that review "can involve multiple external reviewers reviewing different unredacted sections of the Risk Report, so long as all parts of the unredacted report are evaluated by at least one external reviewer." That is close to the FRONTIER Act’s access requirement. But the reviewer is approved by a body Anthropic itself created and can amend, not a federally licensed IVO, and there is no fixed 6-month statutory cadence in the policy language.

That depends on whether each company’s trailing-36-month revenue and AI-development spend cross the bill’s $5B/$10B thresholds (Sec. 2(22)) — figures CASRAI has not independently verified against a primary source for either company this session, so this piece does not assert either one currently qualifies. The thresholds are large enough that they are plausibly within reach of both companies’ scale, but "plausible" is not the same as confirmed.

It means every row in NIKOLAI’s External Review crosswalk — including the FRONTIER Act row — is CASRAI’s own reading of a published document, not something the named organization, lab, or Congress has declared, endorsed, or been consulted on. NIKOLAI is CASRAI’s own independent, unendorsed reference dictionary, not a standard any of these organizations has adopted, and the FRONTIER Act’s binding requirement is a real legislative proposal that exists independently of, and is not endorsed by, NIKOLAI’s reading of it.

As element N8.5 in NIKOLAI’s Transparency and Review track: "a record of an assessment performed by a party outside the model developer… capturing the review’s type, scope, and output." That element’s crosswalk is the richest one checked in this drafting pass — 11 shadow-mapped rows across 10 organizations and legal instruments, including Anthropic, OpenAI, the EU, California SB 53, METR, and the FRONTIER Act itself — and it is the definition this comparison uses to line up the FRONTIER Act, Anthropic, and OpenAI against the same three questions: type, scope, and output.