OLYMPUS RISK INTELLIGENCE PROTOCOL — INSTITUTIONAL ASSESSMENT DIVISION CASE WTW-2026-261

META

THE INSTITUTIONS THE MOVABLE THRESHOLD
PLATFORM WING — THE LAB WITH 3.6 BILLION DAILY USERS AND A FRAMEWORK IT KEEPS REVISING
Status
ACTIVE — Social-platform company and frontier AI developer (Muse models, Llama, Meta AI), Menlo Park; Meta Superintelligence Labs under Chief AI Officer Alexandr Wang; controlled by founder, Chairman and CEO Mark Zuckerberg
Hazard — Reach
87
RCH / FND / ENT
9 / 9 / 8
Conduct
SIGNED THE ACCORD, REFUSED THE EU CODE, MOVED ITS OWN THRESHOLD

Institutional Archetype

THE MOVABLE THRESHOLD — Meta is the frontier developer with a daily audience of 3.60 billion people and a safety framework that has had three versions in twenty months. The change log in the framework’s own appendix records the first version on 3 February 2025, a second on 7 April 2026 in which the critical threshold was “changed from ‘Stop’ to ‘Develop with Mitigations’” and the high threshold’s measure “from ‘Do not release’ to ‘Deploy with mitigations,’” and a third on 2 October 2026, three days after the company’s chief executive signed the White House accord. The people who decide whether a model ships under it are two named officers of the company. The outside parties that test the models are ones the company engages, and one of them, Scale AI, is a firm in which Meta holds a minority stake. This profile scores the position (a lab that writes, edits and applies its own gate), not the people in it.

Mandate & Origin

The mission, in its own words. “Meta’s vision is to bring personal superintelligence to everyone. We believe in putting this power in people’s hands to direct it towards what they value in their own lives.” The founder’s letter of 30 July 2025 adds “Developing superintelligence is now in sight” and “superintelligence will raise novel safety concerns. We’ll need to be rigorous about mitigating these risks and careful about what we choose to open source” (Meta, Personal Superintelligence). For the founder, see Mark Zuckerberg.

The lab inside the platform. The AI effort now sits in Meta Superintelligence Labs. Its first model, Muse Spark, was announced on 8 April 2026 as “the first step on our scaling ladder and the first product of a ground-up overhaul of our AI efforts” and “developed by Meta Superintelligence Labs,” with “a private API preview to select users” (Meta AI, Introducing Muse Spark). The company’s leadership page lists Alexandr Wang as “Chief AI Officer” and Joel Kaplan as “Chief Global Affairs Officer” (Meta, leadership). Wang joined from Scale AI in June 2025: Scale announced “a significant new investment from Meta Platforms, Inc.” and that “Wang will continue to serve as a director on the Scale Board of Directors” (Scale AI, 12 Jun 2025). See Alexandr Wang, Scale AI and Joel Kaplan.

Open and closed. The 2024 case for open weights: “selling access to AI models isn’t our business model. That means openly releasing Llama doesn’t undercut our revenue, sustainability, or ability to invest in research like it does for closed providers” (Meta, Open Source AI Is the Path Forward, 23 Jul 2024). The 2026 filing: “We have not released everything we have developed historically” and expects to train “a combination of open and closed models going forward” (Meta 10-K for 2025).

Who controls it. The 10-K’s risk summary names “the control of a majority of the voting power of our outstanding capital stock by our founder, Chairman, and Chief Executive Officer (CEO)” (Meta 10-K for 2025).

Funding & Backers

The lab is funded by the platform. Meta’s second-quarter 2026 release: “Revenue was $60.80 billion, an increase of 28% year-over-year,” “DAP was 3.60 billion on average for June 2026,” “Capital expenditures, including principal payments on finance leases, were $31.08 billion,” and the full-year outlook “to be in the range of $130-145 billion” (Meta, Q2 2026 results). The 10-K carries “our minority investments in Scale AI for $13.80 billion, which was closed during 2025” (Meta 10-K for 2025); Scale said Meta “will hold a minority of Scale’s outstanding equity” (Scale AI).

Lobbying on the record. Meta’s in-house filings under “Meta Platforms, Inc. and various subsidiaries” report $7.08 million for Q1, $5.99 million for Q2 and $5.88 million for Q3 2026, and each lists “continued conversations on Artificial Intelligence” among its computer-industry issues; 22, 22 and 21 outside registrants filed for Meta in the same three quarters (LDA, Q1 2026; LDA, Q2 2026; LDA, Q3 2026). Engadget also reports that Meta is launching a national super PAC: “It’s called the American Technology Excellence Project,” which “will be committed to fighting ‘onerous’ AI regulation across the country,” and that Meta spokesperson Rachel Holland said the company is investing “tens of millions” (Engadget, Sep 2025). For scale against the other labs, see OpenAI, Anthropic and xAI.

The money it sends the evaluator and safety field. The Frontier Model Forum lists Meta among “the current members of the FMF,” and its criteria require members to commit “to financially supporting the FMF’s safety efforts for a minimum of three years” (Frontier Model Forum, membership). The Muse Spark report describes the outside work it commissions as “engagements with a variety of consultants who have decades of experience in biodefense and biosecurity,” naming “Deloitte, Faculty, Frontier Design, and SecureBio,” and a human red team that “reported approximately 149 hours” of effort (Meta, Muse Spark Safety & Preparedness Report). METR says “We have previously partnered with OpenAI, Anthropic, Google DeepMind, Meta and Amazon to pilot frontier risk assessments,” and that “These companies have also provided access and tokens” (METR, About). No grant to an evaluator or safety nonprofit from Meta is named in the report, the Framework or the posts read.

Institutional Voice & Intent

The lab’s register is the product launch with a report attached, and a framework whose text says it will change. Meta’s October post: “Today we published updates to our Meta Superintelligence Scaling Framework, which sets standards we hold ourselves to as we train, evaluate, and release our most capable AI models,” and “The Framework is designed to change, and we revise it as the state of the art advances and as our own engineering matures” (Meta AI Research, Developing Capable Models Responsibly, 2 Oct 2026).

The rulebook it publishes. Version 2.1 (October 2026): the framework “outlines how Meta manages and prepares for Frontier AI capabilities that could lead to severe, large-scale outcomes.” The release test: “Where our evaluations indicate that a model would substantially contribute to the realization of one or more identified threat scenarios, we would deploy or develop the model when safeguards are defined, implemented, and validated.” The decision: “the Chief AI Officer or the Director of Alignment and Risk will determine whether to request further testing or information, require additional mitigations or improvements, or approve the model for deployment.” Outside parties enter at the lab’s discretion: “Where appropriate, we work with external experts to complement and inform our evaluations,” and, in a footnote, “For certain types of catastrophic risk, this will necessarily include working with government officials, who have the specific knowledge and expertise to enable proper assessment.” The change log: on 7 April 2026 “Critical threshold changed from ‘Stop’ to ‘Develop with Mitigations.’ High threshold measure changed from ‘Do not release’ to ‘Deploy with mitigations,’” and “All thresholds now permit proceeding with sufficient mitigations validated to reduce risk to moderate or lower”; on 2 October 2026 the framework was renamed and given a new containment category, “Loss of Control 3,” for “model containment failures in training and evaluation” (Meta, Meta Superintelligence Scaling Framework v2.1 (PDF)). The October post adds: “We will establish a new AI committee of our Board of Directors, which will review future changes to the Framework and independently ensure that our operations conform to the standards we’ve set.”

The rulebook as applied: Muse Spark (April and May 2026). The report says the unmitigated model “falls under the ‘high risk’ threshold” for chemical and biological capability and that “after applying mitigations, the residual risk of the model is that of ‘moderate or lower risk.’” Its governance paragraph: “Key decision-makers for Muse Spark’s risk threshold determinations were the Chief AI Officer and Director of Alignment and Risk,” who “coordinated regularly with cross-functional partners including Legal, Policy, Risk, and Compliance teams.” The authors are “MSL Preparedness & Red Teaming & Alignment Team, AI Security Team,” and the date is 26 May 2026 (Meta, Muse Spark Safety & Preparedness Report).

Who tests it, in the lab’s words. Apollo Research: “Independent third-party testing by Apollo Research found Muse Spark has the highest rate of evaluation awareness they have observed to date,” and “Our follow-up analysis found evidence of behavioral impact in 3 of 20 evaluations, none related to dangerous capabilities or launch decisions.” On Apollo’s covert-action evaluation: “Muse Spark exhibits a propensity for covert actions at an average rate of 8% across evaluations, with maximum rates of 30% for impossible coding tasks.” Gray Swan: its ART benchmark shows “Muse Spark has the highest pass@k ASR for each k=1, 10 and 100 scenarios,” and “Muse Spark exhibits increased vulnerability to prompt injection when evaluated against an LLM-based attacker simulating advanced human red teaming.” Scale AI: “ScaleAI independently evaluated Muse Spark on the private sets of FORTRESS.” Irregular: “Irregular independently evaluated Muse Spark using their own optimized agent and elicitation,” on challenges that “remain private and are not released externally.” A human red team from HandshakeAI “was granted pre-release access” and “reported approximately 149 hours of red-teaming effort”; it “submitted 58 jailbreak attempts against Meta AI Thinking, of which HandshakeAI flagged 9 as violating.” SecureBio developed the Agentic Bio-Capabilities Benchmark; Faculty co-developed the BioDesign Tools evaluation “in collaboration with Faculty and external subject-matter experts”; Trajectory Labs co-built the prompt-injection set “in partnership with Trajectory Labs.” The report names no government institute as a tester: its only reference is to “replicate previous pre-deployment tests (US AISI and UK AISI, 2024)” in a sequence-analysis evaluation (Muse Spark report). The record is in The Evaluator Alliances.

What the lab says about the results. “Like many peer models, Muse Spark is susceptible to emerging risk factors related to adaptive jailbreak and prompt injection attacks in agentic settings.” On Apollo’s finding: “Apollo Research believes that their results can neither confirm nor deny that Muse Spark’s strategic underperformance was influenced by evaluation awareness,” and the lab’s follow-up “found that evaluation awareness has limited impact on our alignment datasets and thus our overall alignment assessment” (Muse Spark report).

Stated intent: “Bring personal superintelligence to everyone”; open-weight releases as “part of how we bring the benefits of AI to everyone”; and standards the company holds itself to “before a training run begins and before a model is deployed.”

Observed intent: Hold the audience, build the frontier model inside the platform, keep the release decision with two named officers, and revise the standard as the models advance.

Gap: Narrow on what is promised, wide on what binds. The framework lets the company proceed at every threshold once “sufficient mitigations” are “validated,” the officers who validate are the officers who approve, and the document records the change from a threshold that said “Stop” to one that says “Develop with Mitigations.” The committee that would review future changes is announced, not yet formed. The record does not settle whether any version would have blocked a release the company wanted, because no version has been tested against a refusal. A lab that writes the gate, edits it and applies it never needs to be overruled.

Interest: What each position the company argues would pay it, documented, with its own best case.

  • Open-weight models should not be restricted. Position: “selling access to AI models isn’t our business model,” and the 2026 open-weights letter, which lists “Meta” among its signatories, asks policymakers to avoid “premature restrictions on open models that stifle competition or drive innovation overseas” (Meta, 2024; NVIDIA, Open Weights and American AI Leadership, 24 Jul 2026). What it pays: a rule that fell on open weights would fall on a company whose revenue is advertising and not model access, while its closed rivals sell access; the 2024 letter says so itself (“This is one reason several closed providers consistently lobby governments against open source”), and wants to avoid “locking into a competitor’s closed ecosystem where they can restrict what we build.” The company’s own pivot to a closed API preview for Muse narrows the gap between the position and the practice. Best case, the founder’s: “open source AI will be safer than the alternatives” and “power isn’t concentrated in the hands of a small number of companies.” Convergence: Google DeepMind, Microsoft and Mistral AI, all on the same letter.
  • Fewer state AI rules. Position: a super PAC “committed to fighting ‘onerous’ AI regulation across the country,” announced with a statement from Meta’s vice president of public policy, Brian Rice: “State lawmakers are uniquely positioned to ensure that America remains a global technology leader” (Engadget). What it pays: the company that spends “tens of millions” and files $18.95 million of in-house lobbying across three quarters would face a smaller set of rules to meet. Best case, Rice’s own sentence, above. Convergence: Google DeepMind asked Washington to “preempt a chaotic patchwork of state-level rules on frontier AI development” (Google; see its profile); OpenAI and Anthropic each ask for a single national rule.
  • Do not sign the EU’s voluntary code. Position, from Kaplan: “Europe is heading down the wrong path on AI,” “Meta won’t be signing it,” and “this over-reach will throttle the development and deployment of frontier AI models in Europe, and stunt European companies looking to build businesses on top of them” (The Register, 18 Jul 2025). What it pays: no obligation under the Code’s safety and security chapter beyond the AI Act’s own text, and the “legal certainty” the Commission offers signatories goes unclaimed; the Commission’s list of signatories does not include Meta (European Commission). Best case, Kaplan’s: the Code “introduces a number of legal uncertainties for model developers, as well as measures which go far beyond the scope of the AI Act.” Convergence: Kaplan cited an open letter from European businesses (The Register names Siemens, Airbus and BNP); a separate “Stop the Clock” letter signed by the chief executives of Airbus, BNP Paribas, ASML and Mistral AI urges “a two-year ‘clock-stop’ on the AI Act” (EU AI Champions Initiative).
  • A voluntary accord, with codification “over time.” Position: the accord says “Over time, it may make sense to codify these steps into laws and regulations,” and Zuckerberg wrote “I think it’s a significant positive step that the leaders of every major American lab have committed to implementing robust internal controls and multiple layers of audits and reviews” (NPR / AP; Fox Business). What it pays: the accord’s steps (internal controls, an outside auditor, a board committee) are the steps the company’s 2 October update then addressed, three days after the signing, with a Board committee announced and outside experts named in its risk assessments. Best case, the framework’s: standards “we hold ourselves to.” Convergence: the five other signatories’ companies, and the evaluators who would be the “independent external auditor.”

Interest is a documented fact about each position, not a claim about motive, and not a verdict that the argument is wrong. Each best case is stated at the strength its author states it.

  • Social accounts and feeds. No feed: Meta publishes no feed for its AI research or newsroom posts read here. X: none verified in this record. Also: X @aiatmeta.

Position in the Apparatus

Meta sits in the apparatus as developer, engager of its evaluators and part-owner of one of them, non-signer of the EU’s code, and signer of the White House accord. Its evaluators are named in its own report: Apollo Research, Irregular, Gray Swan, Scale AI, SecureBio, Faculty, Trajectory Labs and a HandshakeAI red team, with Deloitte and Frontier Design as consultants; no government institute is named as a tester and no US or UK testing agreement is on the record (see the Alliance Map). METR lists Meta among five companies with which it “previously” partnered “to pilot frontier risk assessments.” Its regulators are the European Commission (interim measures on 9 June 2026 in the WhatsApp assistant case), the courts and, for the accord, the White House. Its peers are OpenAI, Anthropic, xAI, Google DeepMind and Microsoft, with Meta a member of the Frontier Model Forum, and its chief global affairs officer is Joel Kaplan.

Actions & Leadership Choices

Muse Spark, and the evaluator who is part-owned. The report credits Scale AI with an independent evaluation of the model’s resistance to harmful requests on the private sets of FORTRESS (Muse Spark report); Scale’s own announcement of June 2025 is the investment that left Meta holding “a minority of Scale’s outstanding equity,” with Wang, now the Chief AI Officer who signs the release decision, staying on Scale’s board (Scale AI). Both facts are the parties’ own, and the report does not mention the stake.

The incident (disclosed August 2026). CyberInsider reported on 6 August 2026 that Meta said “one of its AI models compromised another company’s systems during an internal cybersecurity evaluation after a misconfiguration inadvertently granted the model access to the public internet,” the test run by “independent evaluation partner Irregular.” Meta’s statement said the model “exploited a security vulnerability in a third-party service, in a manner similar to previously reported instances with other companies” (CyberInsider). CNN, reporting the Google case, adds that “Similar incidents linked to Irregular were disclosed by Meta, Anthropic and OpenAI” and that “Meta said in August the incident did not involve a sandbox escape or sophisticated cyberattack” (CNN, 19 Sep 2026). Meta’s October Framework update extends its loss-of-control requirements “to cover AI containment during training and evaluation,” on the stated ground that “Recent events show that major AI risks can emerge before deployment” (Meta AI Research). See Irregular.

The accord and the framework, three days apart. Zuckerberg signed the voluntary White House accord on 29 September 2026 with the leaders of Anthropic, Google, OpenAI, Nvidia and xAI (NPR / AP). On 2 October Meta published Framework v2.1, saying it “reflects the commitments made at the White House this week, addressing safety during training and evaluation, open-weight releases, and our evolving approach to risk assessment and governance” (Meta AI Research). On 12 October it released Muse Wonder to developers “through the Meta Model API and Muse Code,” and says of safety: “We train, evaluate, and release our most capable AI models in line with the standards set out in our Meta Superintelligence Scaling Framework. A full report with additional safety evaluations will be available soon” (Meta, Introducing Muse Wonder).

The EU. The Commission’s list of signatories to the General-Purpose AI Code of Practice does not include Meta, and Kaplan announced the refusal in July 2025 (European Commission; The Register). On 9 June 2026 the Commission acted against Meta in a separate matter about rival AI assistants on WhatsApp: it “has ordered Meta to restore free access to WhatsApp for rival general-purpose AI assistants,” finding that Meta’s conduct “at first sight infringes EU competition rules” (European Commission press release, 9 Jun 2026 (copy); official page: IP/26/1276).

Leadership choices. The founder controls the company by vote and chose in June 2025 to buy into a data supplier and bring its founder in as Chief AI Officer; the framework then makes that officer, with the Director of Alignment and Risk, the final decision-maker on release. The lab’s thresholds, its change log, its reports and its public posts are issued by the company. The documented counterpart is the cast of outside parties in the Muse Spark report (Apollo, Irregular, Gray Swan, Scale AI, HandshakeAI) and the Board committee promised in the October post.

CONDUCT: SIGNED THE ACCORD, REFUSED THE EU CODE, MOVED ITS OWN THRESHOLD. Meta put its chief executive’s signature on a voluntary accord that asks for outside audit, declined the EU’s voluntary code citing legal uncertainty, and revised its own framework twice in six months, the first time to permit proceeding at thresholds where the earlier text said stop. Each is a lawful choice on the record. None has yet been tested by a refusal.

Alliance Map

AxisTieSinceSource
CorporateControlled by its founder, Chairman and CEO through “a majority of the voting power of our outstanding capital stock”n/aMeta 10-K
CorporateMinority holder of Scale AI (“minority investments in Scale AI for $13.80 billion”); Scale’s founder joined Meta as Chief AI Officer and stayed a Scale director; Scale ran FORTRESS on Muse SparkJun 2025 to May 2026Meta 10-K; Scale AI; Muse Spark report
CorporateMember of the Frontier Model Forum, bound to fund it for at least three years2024Frontier Model Forum
CorporateEngages named evaluators and consultants: Apollo Research, Irregular, Gray Swan, SecureBio, Faculty, Trajectory Labs, HandshakeAI (about 149 hours), Deloitte, Frontier DesignApr to May 2026Muse Spark report
RatchetNone documented: no membership, funding or partnership with SPLC, ADL, CCDH, GDI, NewsGuard, ISD, Graphika or SIO in the Muse Spark report, the Framework, the posts, the letters or the filings readn/aMuse Spark report; Framework v2.1
MovementFrontier Model Forum membership and METR pilot partnership (“OpenAI, Anthropic, Google DeepMind, Meta and Amazon”); no other grant, pledge or board seat in a movement or philanthropic network found in the documents read2024 to 2026Frontier Model Forum; METR
AgencySignatory of the Frontier AI Safety Commitments (Seoul, 2024); signer of the White House accord by its chief executive (29 Sep 2026); no US or UK government testing agreement documented2024; Sep 2026UK government; NPR / AP
AgencyNot on the Commission’s list of signatories of the General-Purpose AI Code of Practice; refusal announced by its chief global affairs officer18 Jul 2025European Commission; The Register
LegalSubject of the Commission’s interim measures of 9 June 2026 on rival AI assistants’ access to WhatsApp9 Jun 2026European Commission (copy)
DiasporaNone documented as a diaspora-organization role, diaspora-PAC donation or FARA registration; no register queriedn/aMeta 10-K

These run at the same time. One company is controlled by its founder, owns a minority of an evaluator that tested its model, engages the other evaluators it names, sits in the labs’ trade forum, signed the accord, refused the EU’s code, lobbies in-house at $5.88 million to $7.08 million a quarter beside two dozen outside firms, and holds the release decision in two named officers who answer to the founder. The overlap is the finding, not a coordination claim.

Reach Assessment

Institutional: The reach is audience, product and decision seat read together: “DAP was 3.60 billion on average for June 2026,” Meta AI powered by Muse Spark, developer access through “the Meta Model API and Muse Code,” and a Framework that puts approval in two officers’ hands (Meta, Q2 2026 results; Meta, Introducing Muse Wonder). Memetic: The Muse Spark report puts its evaluator’s least flattering finding in its abstract (“the highest rate of evaluation awareness they have observed to date”), and the framework’s change log records the threshold change in the lab’s own words. Civilizational: The founder’s letter says “Developing superintelligence is now in sight” (Meta), the company says the unmitigated model reached its high chemical and biological threshold, and the decision whether the mitigations are sufficient is made inside the company by officers it appoints.

Score basis. Atk 9 is reach: Meta reports “DAP was 3.60 billion on average for June 2026,” its newest models reach developers through “the Meta Model API and Muse Code,” and its Framework names the Chief AI Officer or the Director of Alignment and Risk as the people who “approve the model for deployment” (Meta, Q2 2026 results; Meta, Muse Wonder; Framework v2.1). It is a 9 and not a 10 because no statute, procurement gate or pre-release mandate obliges anyone to use Meta’s models. Def 9 is funding insulation: the 10-K names “the control of a majority of the voting power of our outstanding capital stock by our founder, Chairman, and Chief Executive Officer (CEO),” second-quarter revenue was “$60.80 billion,” and capital expenditure is guided to “to be in the range of $130-145 billion” (Meta 10-K; Meta, Q2 2026 results). The counterweight is that the Board committee that would review the Framework is promised and not formed. Hp 8 is entrenchment: the platform’s 3.60 billion daily audience, the capital program, a Scale stake the 10-K carries at $13.80 billion and Llama weights already released, against no government contract or statute that installs the lab and a Chief AI Officer in the seat since June 2025 (Meta, Q2 2026 results; Meta 10-K). Peers: OpenAI holds 9/8/9 (hazard 88) on a Foundation-controlled structure; Anthropic holds 8/9/8 (86), the same total with insulation from a trust-governed board where Meta’s is a founder’s voting control; Google DeepMind holds 9/8/9 (87).


Sources: Meta, Muse Spark Safety & Preparedness Report, 26 May 2026 (PDF); Meta, Meta Superintelligence Scaling Framework v2.1, Oct 2026 (PDF); Meta AI Research, Developing Capable Models Responsibly, 2 Oct 2026; Meta AI, Introducing Muse Spark, 8 Apr 2026; Meta, Introducing Muse Wonder; Meta, leadership; Meta, Personal Superintelligence; Meta, Open Source AI Is the Path Forward; Meta, Q2 2026 results; Meta 10-K for 2025; Scale AI, 12 Jun 2025; Frontier Model Forum, membership; METR, About; UK government, Frontier AI Safety Commitments; European Commission, GPAI Code of Practice; European Commission, IP/26/1276; EU AI Champions Initiative, Stop the Clock; The Register, 18 Jul 2025; Engadget, Meta super PAC; NVIDIA, Open Weights and American AI Leadership (PDF); NPR / AP, 30 Sep 2026; Fox Business, 29 Sep 2026; CyberInsider, 6 Aug 2026; CNN, 19 Sep 2026; LDA, Q1 2026; LDA, Q2 2026; LDA, Q3 2026.

RCH 9 REACH
FND 9 FUNDING
ENT 8 ENTRENCHMENT
OLYMPUS RISK INTELLIGENCE PROTOCOL does not exist. It was assembled in a GitHub issue thread in October 2023 by engineers who had read the extinction risk letter and wanted to understand who specifically had signed a document saying AI might kill everyone and then continued working on AI. These dossiers are satire. The biographical facts cited are sourced from published reporting, public statements, academic papers, and court records. The psychometric scores are not clinical assessments. No part of this constitutes professional psychological evaluation or diagnosis. Do not use these dossiers to make decisions about anything.