# Data-Centric AI Governance: Addressing the Limitations of Model-Focused Policies

arXiv: https://arxiv.org/abs/2409.17216 · HTML: https://mlsanity.com/paper/2409.17216/

## Key facts

- Cited by 2 papers in the map (data through 14 Oct 2026).
- Builds on 53 of its 89 references that are in the map.
- First posted on arXiv 25 Sep 2024.

## Builds on (most cited first, 30 of 53)

- [Language Models are Few-Shot Learners](https://mlsanity.com/paper/2005.14165/) (2020)
- [Training language models to follow instructions with human feedback](https://mlsanity.com/paper/2203.02155/) (2022)
- [Retrieval-Augmented Generation for Knowledge-Intensive NLP Tasks](https://mlsanity.com/paper/2005.11401/) (2020)
- [Measuring Massive Multitask Language Understanding](https://mlsanity.com/paper/2009.03300/) (2020)
- [Scaling Laws for Neural Language Models](https://mlsanity.com/paper/2001.08361/) (2020)
- [Toolformer: Language Models Can Teach Themselves to Use Tools](https://mlsanity.com/paper/2302.04761/) (2023)
- [Constitutional AI: Harmlessness from AI Feedback](https://mlsanity.com/paper/2212.08073/) (2022)
- [Training Compute-Optimal Large Language Models](https://mlsanity.com/paper/2203.15556/) (2022)
- [Neural Machine Translation of Rare Words with Subword Units](https://mlsanity.com/paper/1508.07909/) (2015)
- [Emergent Abilities of Large Language Models](https://mlsanity.com/paper/2206.07682/) (2022)
- [Retrieval-Augmented Generation for Large Language Models: A Survey](https://mlsanity.com/paper/2312.10997/) (2023)
- [Jailbroken: How Does LLM Safety Training Fail?](https://mlsanity.com/paper/2307.02483/) (2023)
- [Transformers are SSMs: Generalized Models and Efficient Algorithms Through Structured State Space Duality](https://mlsanity.com/paper/2405.21060/) (2024)
- [Llama Guard: LLM-based Input-Output Safeguard for Human-AI Conversations](https://mlsanity.com/paper/2312.06674/) (2023)
- [Model Cards for Model Reporting](https://mlsanity.com/paper/1810.03993/) (2018)
- [Red Teaming Language Models with Language Models](https://mlsanity.com/paper/2202.03286/) (2022)
- [Scaling Vision Transformers](https://mlsanity.com/paper/2106.04560/) (2021)
- [Quantifying Memorization Across Neural Language Models](https://mlsanity.com/paper/2202.07646/) (2022)
- [Red Teaming Language Models to Reduce Harms: Methods, Scaling Behaviors, and Lessons Learned](https://mlsanity.com/paper/2209.07858/) (2022)
- [The Falcon Series of Open Language Models](https://mlsanity.com/paper/2311.16867/) (2023)
- [Dataset Condensation with Gradient Matching](https://mlsanity.com/paper/2006.05929/) (2020)
- [What Neural Networks Memorize and Why: Discovering the Long Tail via Influence Estimation](https://mlsanity.com/paper/2008.03703/) (2020)
- [Does Learning Require Memorization? A Short Tale about a Long Tail](https://mlsanity.com/paper/1906.05271/) (2019)
- [TinyStories: How Small Can Language Models Be and Still Speak Coherent English?](https://mlsanity.com/paper/2305.07759/) (2023)
- [Scalable Extraction of Training Data from (Production) Language Models](https://mlsanity.com/paper/2311.17035/) (2023)
- [The Reversal Curse: LLMs trained on "A is B" fail to learn "B is A"](https://mlsanity.com/paper/2309.12288/) (2023)
- [Can LLMs Generate Novel Research Ideas? A Large-Scale Human Study with 100+ NLP Researchers](https://mlsanity.com/paper/2409.04109/) (2024)
- [AI and the Everything in the Whole Wide World Benchmark](https://mlsanity.com/paper/2111.15366/) (2021)
- [RAFT: Adapting Language Model to Domain Specific RAG](https://mlsanity.com/paper/2403.10131/) (2024)
- [T2I-CompBench++: An Enhanced and Comprehensive Benchmark for Compositional Text-to-image Generation](https://mlsanity.com/paper/2307.06350/) (2023)

## Built on by (most cited first, 2 of 2)

- [Build Agent Advocates, Not Platform Agents](https://mlsanity.com/paper/2505.04345/) (2025)
- [Governance at the Edge of Architecture: Regulating NeuroAI and Neuromorphic Systems](https://mlsanity.com/paper/2602.01503/) (2026)

## Abstract (arXiv)

Current regulations on powerful AI capabilities are narrowly focused on "foundation" or "frontier" models. However, these terms are vague and inconsistently defined, leading to an unstable foundation for governance efforts. Critically, policy debates often fail to consider the data used with these models, despite the clear link between data and model performance. Even (relatively) "small" models that fall outside the typical definitions of foundation and frontier models can achieve equivalent outcomes when exposed to sufficiently specific datasets. In this work, we illustrate the importance of considering dataset size and content as essential factors in assessing the risks posed by models both today and in the future. More broadly, we emphasize the risk posed by over-regulating reactively and provide a path towards careful, quantitative evaluation of capabilities that can lead to a simplified regulatory environment.