Gradient Institute Response to the Productivity Commission's Interim Recommendations on AI

25 September 2025

PC Submission Gradient Institute

Gradient Institute has responded to the Productivity Commission's interim report on 'Harnessing data and digital technology', arguing that its proposed regulatory approach to AI applies conventional governance principles to a fundamentally unconventional technology that may lead to a paradigm shift in how society operates.

The Commission's approach can work well for traditional technologies – including some forms of AI. However, drawing from the International AI Safety Report 2025, we argue that it fails to account for factors that together make advanced AI exceptional: its uncertain evolution in capabilities, general-purpose nature, and the poor scientific understanding of how it actually works.

The International AI Safety Report 2025 qualifies today’s most advanced generative AI as an instance of advanced AI, which it defines as "the most advanced general-purpose AI systems at the time of writing, as well as future systems that might be even more capable."

When it comes to advanced AI, we propose a different path: establish a new national scientific and technical body to research, measure, and monitor advanced AI's evolving capabilities and risks. This body would then support the development of frameworks that are more adaptive, anticipatory, and robust to deep uncertainty than standard regulatory principles would suggest. This will allow Australia to move beyond a reactive posture toward a more forward-looking, strategic approach to both AI and its governance, as this technology reshapes society in ways we're only beginning to understand.

Read our full submission here.