Operationalising the GC REAIM ‘Responsible by Design’ Report
In September 2025, the Netherlands' MFA initiated Global Commission on Responsible Artificial Intelligence in the Military Domain (GC REAIM) released its first report, Responsible by Design: Strategic Guidance on the Risks, Opportunities, and Governance of Artificial Intelligence in the Military Domain (the Report).
The Report represents the culmination of two years of global consultation on the challenges and opportunities presented by AI in the military domain. It draws on the work of two international summits and five regional meetings, bringing together experts from government, industry, academia, and civil society.
At its heart, the Report calls for human-centred design, testing, and deployment of military AI that upholds peace and human dignity. It urges militaries and their industry partners to embed ethical and legal safeguards from the earliest stages of development and throughout the AI system lifecycle.
GC REAIM sets out three guiding principles and five core recommendations designed to institutionalise responsible design and governance in military AI. The challenge now is to operationalise these principles—to turn global commitments into real-world practice.
Integrating Legal and Ethical Design
Article 36 Legal’s Lawful by Design (LBD) initiative, launched on 12 June 2025, demonstrates how legal and ethical principles can be embedded throughout the development and use of AI-enabled military systems.
The initiative takes two complementary approaches:
It encourages industry to recognise the commercial value of responsible AI design, reducing R&D risk, improving efficiency, and attracting responsible investment.
It calls on governments to integrate responsible development into defence procurement, requiring evidence of ethical and legal risk mitigation in bids for military contracts.
These actions give effect to GC REAIM’s first guiding principle—compliance with international law and shared ethical values to protect human life and peace for current and future generations.
Applying a Functional Approach
Article 36 Legal’s Functional Approach to the Legal Review of Autonomous Weapon Systems provides a structured method to operationalise GC REAIM’s second guiding principle.
The approach consists of eight elements that integrate legal, ethical, and operational analysis throughout the system’s lifecycle. Its use of Human Control Levels, adapted from automotive autonomy standards, ensures context-appropriate human control and accountability in each operational setting.
By reinforcing human agency and responsibility, the Functional Approach ensures that ultimate decision-making remains firmly in human hands.
Embedding Lifecycle Responsibility
The Functional Approach also promotes a lifecycle perspective across three key phases:
Informative phase: States communicate legal and ethical requirements to developers early in design.
Determinative phase: During procurement, systems are assessed for compliance with international law and ethical standards.
Governance phase: Continuous training, testing, and oversight during operation maintain responsible control.
These phases align closely with GC REAIM’s third guiding principle and Core Recommendation 3 on continuous capacity building and responsible governance.
Building Communities of Practice
Article 36 Legal’s LBD Industry Workshops—recently hosted in Melbourne and Utrecht—and its Expert Meetings on the Legal Review of Autonomous Weapon Systems (Geneva 2025; Stockholm 2026) advance GC REAIM’s objectives by creating platforms for dialogue among states, industry, academia, and civil society.
These collaborative spaces foster shared understanding, peer learning, and practical exchange—helping to translate international principles into national and organisational practice.
Introducing Accountability Through Ratings
The Responsible by Design (RBD) Rating System for Military AI, developed by the LBD Ambassadors, provides an independent framework to assess responsible practices across four pillars: legality, ethics, safety, and trust.
By offering transparent, evidence-based ratings, the system encourages states and defence companies to adopt more accountable and transparent AI governance. It also provides a benchmark for responsible innovation and procurement.
Expanding State Capacity
The LBD 30x30 Program aims to increase the number of states with national legal review mechanisms from around 20 to at least 30 by 2030.
Through training and partnerships—such as with the International Institute of Humanitarian Law—the program delivers practical capacity building, including annual courses on Article 36 legal reviews and new technology weapons.
Shared Goals, Distinct Paths
Although Article 36 Legal is not formally affiliated with GC REAIM, both share a common purpose: embedding legality, accountability, and responsibility in the development and use of military AI.
Through its Lawful by Design ecosystem, Article 36 Legal demonstrates how GC REAIM’s principles can be operationalised, transforming aspirational norms into tangible, verifiable practice.
