We sketch how developers of frontier AI systems could construct a structured rationale -- a 'safety case' -- that an AI system is unlikely to cause catastrophic outcomes through scheming. Scheming is a potential threat model where AI systems could pursue misaligned goals covertly, hiding their true capabilities and objectives. In this report, we propose three arguments that safety cases could use in relation to scheming. For each argument we sketch how evidence could be gathered from empirical evaluations, and what assumptions would need to be met to provide strong assurance. First, developers of frontier AI systems could argue that AI systems are not capable of scheming (Scheming Inability). Second, one could argue that AI systems are not capable of posing harm through scheming (Harm Inability). Third, one could argue that control measures around the AI systems would prevent unacceptable outcomes even if the AI systems intentionally attempted to subvert them (Harm Control). Additionally, we discuss how safety cases might be supported by evidence that an AI system is reasonably aligned with its developers (Alignment). Finally, we point out that many of the assumptions required to make these safety arguments have not been confidently satisfied to date and require making progress on multiple open research problems.
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