Position: Current Model Cards Are Insufficient for Downstream Governance of Open-Weight Foundation Models
The growth of open-weight foundation models (OWFMs) has prompted the AI community to re-evaluate strategies for effective downstream governance. Although model cards have been widely adopted as transparency artifacts in model repositories, existing frameworks often fail to adequately inform downstream developers and users about the distinct safety challenges posed by OWFMs. This position paper analyzes 500 model cards hosted on Hugging Face and argues that effective governance of OWFMs requires a multi-layered approach integrating three complementary components: (i) model cards, (ii) acceptable use policies (AUPs), and (iii) licenses. To motivate this claim, we identify a safety gap left by existing regulatory approaches, including model heritage, alignment provenance, and empirically observed behaviors, through an analysis of model cards with safety-critical information. We further argue that standard open-source licenses (OSLs) are not well suited for OWFMs and may weaken the enforceability of AUPs. Building on these observations, we outline directions for evolving model cards, AUPs, and licenses into integrated safety artifacts to enable a more comprehensive governance framework that coherently integrates informational, normative, and legal dimensions.