On August 7, 2026, Avondale.AI submitted the following comment to the Shared AI Findings Exchange (SAFE) Working Group RFC. The comment was submitted via email and acknowledged by the Linux Foundation legal team. We are publishing it here as a public position statement.
Avondale.AI is a founding member of the Open Secure AI Alliance (OSAA). We build and deploy sovereign, local-first AI systems for families, educators, and small businesses. This comment addresses four areas where the current SAFE RFC draft, if adopted as written, could unintentionally exclude small operators, sovereign deployers, and accessibility-focused providers from the ecosystem the alliance is trying to build.
The reporting compact requires members to report incidents within 4 business days, preserve extensive forensic evidence (prompts, traces, tool calls, logs, configurations, model versions, agent identities, permissions, credentials, human approval events, files modified, detection events, and a complete incident timeline), and submit a preliminary control-failure analysis within 30 days.
For an enterprise with a dedicated security team, this is a reasonable ask. For a small business running a sovereign local-first stack, this is a significant operational burden. The RFC doesn't distinguish between an organization with 50,000 employees and a small team. A single incident could consume more staff time than a small operator can spare.
Recommendation: Introduce a tiered reporting framework proportional to organization size and deployment scope. Small operators should be able to submit a simplified initial report (what happened, what was affected, what was contained) with extended timelines for the full evidence package. The goal is learning, not paperwork that prices out the small players.
The requirement to publish a preliminary factual report within 30 days is reasonable for transparency. But for a small business, a public AI incident report is not just a learning exercise — it's a reputational event that could end the business. A large corporation can absorb a public incident report. A small business serving educators and small businesses at accessible price points cannot.
The RFC says "learning is separate from enforcement." But public disclosure IS a form of enforcement for small operators, even if that's not the intent. A Fortune 500 company publishes an incident report and it's a footnote. A small company publishes one and it's the headline.
Recommendation: Allow small operators to submit confidential reports with delayed or anonymized public disclosure. The learning value is in the technical details and control failures, not in which company's name is attached. De-identified reporting should be the default for organizations below a certain size threshold, not an afterthought.
The 8-layer review framework (model, instructions, safeguards, tools, environment, monitoring, human operations, supply chain) is well-designed for enterprise deployments with segregated teams, dedicated infrastructure, and complex supply chains. It doesn't map cleanly onto a sovereign local-first deployment where one operator runs the entire stack.
When the review framework asks "Were responsibilities, escalation paths and kill procedures clear?" — in a small operation, the answer is "the operator does everything." That's not a control failure, it's a different operating model. The framework should recognize that small deployments have different architectures, not assume they're missing layers.
Recommendation: Add guidance for single-operator and small-team deployments. The review framework should adapt to the deployment's actual architecture, not require small operators to describe their system using enterprise categories that don't apply.
The Member Sovereignty section states that "SAFE establishes minimum interoperability and assurance practices without superseding members' internal security policies or legal obligations." This language is concerning. Today it's incident reporting. Tomorrow "minimum assurance practices" could mean mandatory tooling, certified security components, or compliance requirements that only enterprise-scale companies can implement.
The RFC's own "From Lessons to Controls" section envisions publishing "reusable tests, machine-readable policies, detection rules, reference configurations and incident-response guidance." If these become the de facto standard for what "secure AI" means, any deployment that doesn't implement them is "insecure" by default — regardless of whether the deployment is actually safe.
A local-first deployment serving educators and small businesses at accessible price points doesn't need SPIFFE/SPIRE identity verification, NOOA-compliant agent frameworks, or enterprise-grade supply chain attestation to be safe. It needs good isolation, proper access controls, and sensible defaults. If "minimum assurance practices" evolves to require enterprise tooling, the alliance will have built a moat that excludes the exact people it claims to serve.
Recommendation: The final spec should explicitly state that "minimum assurance practices" are guidance, not requirements, and that alternative security architectures (including local-first, sovereign, and small-scale deployments) are valid if they achieve equivalent safety outcomes. The spec should define what "equivalent" means without mandating specific tools or architectures.
I joined this alliance because I believe open AI is a defensive asset. I want to help build standards that make AI safer for everyone — not just the large enterprise members who can afford to implement them. The SAFE framework has the potential to be genuinely valuable. It also has the potential to become another barrier that keeps AI in the hands of those who can afford compliance overhead.
The spec says "civil-society and affected-user representatives" should be included in SAFE. Avondale.AI IS civil society. We serve teachers, families, and small businesses who can't access enterprise AI. Our voice matters in this conversation, and I'm asking the working group to consider the impact on operators like us before the spec is finalized.
I'm available for further discussion through our contact page.
Respectfully,
Stephen Sargent
Founder & CTO
Avondale.AI
Disclaimer: This document is a public position statement reflecting the views of Avondale.AI. It is not legal advice. It does not represent the official position of the Open Secure AI Alliance (OSAA), the Linux Foundation, or any other organization. References to the SAFE RFC draft are based on the version available at the time of submission (August 7, 2026).
To the SAFE Working Group and the Linux Foundation,
I'm writing as a founding member of the Open Secure AI Alliance and the Founder & CTO of Avondale.AI, a small business that builds and deploys sovereign, local-first AI systems for families, educators, and small businesses. I'm submitting this comment on the Shared AI Findings Exchange (SAFE) draft RFC via email rather than GitHub.
I want to be clear up front: I support the mission. Sharing lessons from AI security incidents is good for the ecosystem. The NASA Aviation Safety Reporting System analogy is apt — voluntary, confidential, blameless reporting saves lives. I signed up for this alliance because I believe open AI is a defensive asset, not a liability. My comments are offered in that spirit.
What I want to flag are four areas where the current draft, if adopted as written, could unintentionally exclude small operators, sovereign deployers, and accessibility-focused providers from the ecosystem the alliance is trying to build.