Risk · R-075 · Adversarial ML & Model Integrity
Safeguard erosion through fine-tuning
Fine-tuning or other adaptation weakens a base model's safety behaviour, and the change goes untested because the base model had already been assessed.
- Severity
- Medium
- Audience
- Heads-of · Practitioner
- Frameworks
- Principle 9 · Article 25 · MEASURE 2
- Responsible AI domain
- Lifecycle stage
- Reviewed
- 2026-11-10
What it is
A model's tendency to refuse harmful requests is learned behaviour, and further training can change it. Fine-tuning on an organisation's own data, even innocuous data, can reduce refusals, reintroduce unsafe outputs or undo the supplier's safeguards. The adapted model is a new model. The risk arises when it inherits the approval given to its base. Deliberate removal of safeguards by an attacker who holds the weights follows from model weight theft.
How it happens
- The base model's evaluation is reused for the fine-tuned version.
- Training data contains examples that reward compliance with any request.
- Safety tests are not part of the fine-tuning pipeline.
- Several rounds of adaptation accumulate with no baseline comparison.
Why it matters
The organisation deploys a model that is easier to misuse than the one it assessed. Under the EU AI Act, a party that substantially modifies a high-risk system takes on the provider's obligations for it.
Warning signs
- Fine-tuned models have no evaluation record of their own.
- Refusal rates are not measured before and after adaptation.
- The approval record names the base model only.
- Users report that the tuned model will do what the original would not.
Mitigating controls
Primary controls
- AI change management Preventive
- Treats fine-tuning as a change requiring assessment and approval. Changes to models, prompts, data sources, tools and configuration are assessed, tested, approved and versioned before they reach production.
- Evaluation suite and regression testing Detective
- Re-runs the safety test set after every adaptation and compares with the base model. A maintained set of test cases with expected results is run on every change to model, prompt, data or tools, and the results are compared with the approved baseline.
Supporting controls
- AI red teaming Detective
- Checks adapted models for restored unsafe behaviour. People skilled in attacking AI systems try to make the system fail as an adversary would, before release and periodically, and their findings are tracked to closure.
Framework and clause references
| Framework | Clause | Title |
|---|---|---|
| Code of Practice for the Cyber Security of AI | Principle 9 | Conduct appropriate testing and evaluation Re-testing after change. |
| EU AI Act | Article 25 | Responsibilities along the AI value chain A substantial modification can shift provider duties to the modifier. |
| NIST AI Risk Management Framework (AI RMF 1.0) | MEASURE 2 | Systems are evaluated for trustworthy characteristics Evaluation of safety after adaptation. |
Sources
- EU AI Act: Regulation (EU) 2024/1689 European Union (EUR-Lex) · official text
- NIST AI Risk Management Framework (AI RMF 1.0) NIST · framework
Related terms
How to cite
Axiom Verity (2026). Safeguard erosion through fine-tuning. Reference Library, R-075. https://axiom-verity.com/risks/safeguard-erosion-through-fine-tuning. Reviewed 2026-11-10.
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