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Practitioners — Professional Engineers · Last updated 11 Jun 2026 · methodology v2.3 · Hallucination Register
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AI Hallucination on BBNJ High Seas Biodiversity Agreement for Professional Engineers in international jurisdictions

Professional engineers scoping projects that may touch areas beyond national jurisdiction are increasingly using AI to draft environmental impact assessment scoping documents, generate technical briefings for design teams on screening thresholds, and validate which provision of the BBNJ Agreement governs a particular obligation before submitting deliverables to clients or regulators.

The RLB Specialist Panel put a set of practitioner-grade questions on the BBNJ Agreement to two frontier AI models with web search active. Each question is prepared by the Panel based on the workflows that professional engineers actually use AI for under this treaty, covering the screening threshold for environmental impact assessments under Part IV, the temporal scope of the marine genetic resources and digital sequence information regime under Part II, the benefit-sharing duty for digital sequence information, and the non-undermining duty constraining Conference of the Parties decisions on area-based management tools under Part III.

The Panel then binds every AI response to verbatim regulator-issued source text held as primary substrate, comparing the AI output line-by-line against the deposited treaty text. Only responses where the AI subject was demonstrably wrong against the verbatim regulator-issued source text are published; responses that were substantively correct, or that refused on calibration grounds, are retained internally and not surfaced. On the BBNJ Agreement, the AI subjects returned a single hallucinated answer in the form of Source-Credit Misattribution for professional engineers.

For professional engineers scoping projects that may engage areas beyond national jurisdiction, citation accuracy in environmental impact assessment scoping documents is load-bearing. A scoping document that pins the screening obligation to the wrong article of the BBNJ Agreement will be challenged on first review by a regulator, a peer reviewer, or the client's own legal team. The substantive screening test the AI paraphrased may be the right test, but the citation will need to be reworked, and the engineer issuing the document carries professional responsibility for the accuracy of the regulatory reference framing the work.

The published Specialist Panel findings, with model attribution, carry the following citation identifiers, each hyperlinked to the bound regulator-issued source text on the BBNJ Agreement regulation hub. The audit register surfaces these findings for professional engineers so that any AI-assisted treaty citation, paraphrase, or rule-statement entering a deliverable can be re-validated against the deposited treaty text before the document is issued:

This is the consolidated view of findings. Click the Citation IDs or 'see details →' on any item for the full details for each finding.

  1. EIA screening threshold misattributed to wrong article
    RLB-F-INT-UNTC-BBNJ-HIGH-SEAS-BIODIVERSITY-AGREEMENT-2023-Q001

    A professional engineer scoping an environmental impact assessment for a planned high-seas activity, who relies on this AI output to identify the governing screening provision, would produce scoping documentation citing Article 30 when the correct anchor is Article 27 (Part IV). The qualitative test the model paraphrased (more than a minor or transitory effect) is in fact the Article 27 language, so the substantive screening criterion is right but the citation is wrong, leaving the deliverable defective on first review by a regulator or peer.

    see details →

Every finding on this page compares an AI subject's account of the rule against the regulator's verbatim text from the regulator's own portal. Both are linked. Each delta, its root causes, and impact analysis are documented and published with immutable Citation IDs.