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Committee members press ACUS to treat AI and electronic submissions more than a footnote
Summary
Several members urged that the draft recommendations explicitly address electronic submissions and artificial intelligence in agency investigative procedures, arguing an AI footnote is insufficient; the consultant said the present draft did not focus on AI and staff will cite a prior ACUS recommendation on algorithmic tools.
During review of draft recommendations on agency investigative procedures, several committee members pushed staff and the consultant to treat electronic submissions and artificial intelligence (AI) as a substantive part of the project rather than a brief reference.
Peter Strauss raised concerns that the draft does not reflect how agencies increasingly rely on automated processing of electronic reports and sensors to identify potential violations. He argued such practices can amount to investigations and said the issue "deserves a lot more than the footnote." "More than a footnote," Strauss said during the meeting.
Consultant Arum Gavor responded that "This report does not focus on AI," while acknowledging the importance of the subject and noting the research captured a snapshot of agency practices through a summer 2024 data‑collection window. Staff pointed to an earlier ACUS adoption — Recommendation 2024‑8‑5 addressing algorithmic tools in regulatory enforcement — and agreed to cite that recommendation in the preamble. Members including Strauss and others said a footnote will not suffice and asked staff to consider integrating AI considerations or adding more explicit cross‑references in the text.
The committee did not decide to expand the AI analysis at this meeting but agreed to reference prior ACUS work in the draft preamble and to revisit wording in future sessions. No formal vote was taken.
