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Human behaviour
AI incidents involving rules-behaviour gap
Headlights has recorded rules-behaviour gap as the main behaviour in 38 of the 234 incidents in the library (16%), and as a contributing behaviour in 20 more. They span 2020 to 2026. Most come from Government & public administration (12), Professional & legal services (10), Consumer AI (6).
Headlights' test for rules-behaviour gap
A written policy, procedure or legal requirement existed and practice did not follow it.
A behaviour tag is Headlights' reading of the public record, not a finding by any court, regulator or company. Each entry gives the one sentence in the record that supports it.
Main behaviour in the record · 38
HD-INC-235Brazil's Audit Court Found More Than One in Ten Automatic Benefit Refusals Were WrongBrazil · 2025HD-INC-234Ireland's Regulator Found No Lawful Basis for Public Services Card Facial MatchingIreland · 2025HD-INC-231A Court Struck Part of Anthropic's Expert Evidence After Claude Changed a CitationUnited States · 2025HD-INC-219UK Inspectors Found AI Used Inappropriately in Asylum Decision Letters and InterviewsUnited Kingdom · 2026HD-INC-212France's Top Administrative Court Cut Amazon's Warehouse Data Fine to 15 Million EurosFrance · 2025HD-INC-209A Spanish Court Let a Worker Quit With Compensation Over Facial Recognition ClockingSpain · 2026HD-INC-203An Online University Required Facial Recognition for Classes, and Italy Fined ItItaly · 2024HD-INC-197A Paris Court Suspended a Publisher's Newsroom AI Tools Pending Works Council ConsultationFrance · 2025HD-INC-186Ofcom fined a nudification service for having no age check beyond a line saying users must be 18, and the operator blocked the United Kingdom rather than add oneUnited Kingdom · 2025HD-INC-178Canadian privacy regulators found OpenAI had not validated the general accuracy of personal information generated about peopleCanada · 2026HD-INC-177A KPMG partner used AI to pass the firm's own mandatory AI test, and 28 staff instances were identifiedAustralia · 2026HD-INC-171South Africa's social grant agency read every deposit into an applicant's bank account as income, and the High Court found its checks against government databases unreasonable and unfairSouth Africa · 2025HD-INC-169OpenAI paused Sora depictions of a civil rights leader at his estate's request, and offered estates an opt-out while living people's likenesses were already opt-inUnited States · 2025HD-INC-167Reuters found chatbots on Meta's apps using real celebrities' names and likenesses without permission, and its own testing produced intimate images including one of a teenage actorUnited States · 2025HD-INC-165Character.AI removed reported chatbots impersonating deceased teenagers after families, lawyers and journalists notified it, and its terms of service already prohibited impersonating a real personUnited States · 2024HD-INC-164Researchers ran AI-written comments under fabricated personas at Reddit users for four months, and the community learned of it only when the researchers told the moderators afterwardsSwitzerland · 2025HD-INC-160A Munich court found at first instance that OpenAI's models hold the words of nine German songs and reproduce them in chatbot outputs, and rejected the argument that this was text and data miningGermany · 2025HD-INC-156Greece's data protection authority fined the Migration Ministry 175,000 euros after finding that the impact assessments for the camera, behavioural analytics, drone and fingerprint systems at five island reception centres were substantially incompleteGreece · 2024HD-INC-155California's Labour Commissioner cited Amazon nearly six million dollars for failing to meet a warehouse quota law written three years earlier, at two of its own fulfilment centresUnited States · 2024HD-INC-151Two US federal judges withdrew orders that contained misstated case outcomes and a citation to a case that did not exist, and both told a Senate committee that staff had used AI to draft themUnited States · 2025HD-INC-150A project scanned people's irises around the world for a digital ID, and regulators told it to stopGlobal · 2024HD-INC-139Researchers found suspected child-abuse images inside the open dataset used to train popular AI image generatorsGermany · 2023HD-INC-123South Korea's privacy regulator fined Kakao Pay after finding it had sent about 40 million users' data to Alipay without their consent, where it was used to build a scoring model, and it ordered the model deletedSouth Korea · 2025HD-INC-113A court in Bologna found that Deliveroo's rider-ranking algorithm discriminated against couriers because it treated a legally protected strike the same as an unexplained no-showItaly · 2021HD-INC-096Australia's federal police trialled Clearview's face-search tool on Australians without a privacy check, and the regulator found it breached privacy lawAustralia · 2021HD-INC-094Discord wrongly banned more than 8,000 users over benign images after bugs bypassed the intended human review, and the company admitted the errorUnited States · 2026HD-INC-093Ross trained an AI legal-research tool on Westlaw headnotes obtained after being refused a licence, and a US court ruled it was not fair use, in what commentators called the first such decisionUnited States · 2025HD-INC-076Australia changed the law so a human had to decide before a job seeker's payment was cancelled, and the automated system kept cancelling anywayAustralia · 2025HD-INC-073An AI transcription tool used by clinicians invented text no one said, researchers reported, and the audio that could have proved it was deletedUnited States · 2024HD-INC-072The Dutch student-finance agency picked fraud targets with a risk profile for a decade, and official investigations found it indirectly discriminated against students with migration backgroundsNetherlands · 2024HD-INC-066A child protection worker used ChatGPT on a Children's Court report, and the regulator found it disclosed a child's details and understated riskAustralia · 2024HD-INC-060South Korea's 'Lee Luda' chatbot was trained on billions of real chat messages without consent, then spat out slurs and exposed users' personal dataSouth Korea · 2021HD-INC-059A Dutch court struck down SyRI, a secret welfare-fraud profiling system aimed at poor neighbourhoods, as a violation of human rightsNetherlands · 2020HD-INC-0587-Eleven scanned the faces of customers filling in feedback surveys at 700 stores, and Australia's privacy regulator ordered the faceprints destroyedAustralia · 2021HD-INC-042The Dutch tax office used a risk algorithm that flagged families by nationality, and wrongly branded tens of thousands as benefit fraudstersNetherlands · 2021HD-INC-022Bunnings Scanned Shoppers' Faces Without Telling Them, and Won Only Half Its AppealAustralia · 2024HD-INC-021Kmart Scanned Shoppers' Faces in 28 Stores, and the Privacy Commissioner Found It UnlawfulAustralia · 2025HD-INC-018iTutorGroup's Hiring Software Automatically Rejected Older Applicants Because of Their AgeUnited States · 2020
Also present · 20
HD-INC-233Starling Bank's Sanctions Screen Checked Customers Against 39 of 3,088 Listed NamesUnited Kingdom · 2024HD-INC-201Home Affairs' System Ended a Bridging Visa Unlawfully, the Commonwealth Ombudsman FoundAustralia · 2023HD-INC-174The FDA told a company its AI app was an unapproved medical device after it advertised a five minute gaze test to detect early signs of Alzheimer's diseaseUnited States · 2025HD-INC-158A US drug manufacturer told inspectors it had used AI agents to write the documents that define how its products are made, and said it had not known about a validation requirement because the AI had not raised itUnited States · 2026HD-INC-091Uber cut drivers off for alleged fraud by algorithm, and an Amsterdam court found the human review was not much more than a symbolic actNetherlands · 2023HD-INC-082Flight Centre handed developers at a hackathon a dataset with thousands of customers' passport and credit card details, and the privacy regulator found it broke the lawAustralia · 2020HD-INC-079Trivago advertised the best hotel deal while its algorithm favoured the advertiser that paid it most, and the penalty was $44.7 millionAustralia · 2022HD-INC-078An insurer promised loyalty discounts while a pricing algorithm capped them, and the Federal Court imposed what was then a record $40 million penaltyAustralia · 2023HD-INC-077Revenue NSW took money from fine defaulters' bank accounts by automation for years, and the Ombudsman found the process contrary to lawAustralia · 2024HD-INC-043A Cruise robotaxi dragged a pedestrian twenty feet, and the company left the dragging out of what it told regulatorsUnited States · 2023HD-INC-036A Misinformation Expert's Court Declaration on Deepfakes Cited Studies That Did Not ExistUnited States · 2024HD-INC-025An Australian Lawyer Relied on ChatGPT and Filed 17 Cases That Did Not ExistAustralia · 2025HD-INC-023Clearview AI Built a Face Search Engine From Billions of Scraped Photos Without ConsentAustralia · 2021HD-INC-013Melbourne Law Firm Ordered to Pay Costs Over Fake Citations in a Native Title ClaimAustralia · 2025HD-INC-012A Senior Barrister Filed AI-Invented Cases and Quotes in a Victorian Murder TrialAustralia · 2025HD-INC-011The First Australian Lawyer Disciplined for AI Misuse Handed a Judge Fake CasesAustralia · 2024HD-INC-010Deloitte's $440K AUD report for the Australian government cited a federal court quote that did not existAustralia · 2025HD-INC-004Replit's AI Agent Deleted a Production Database Despite Being Told to StopUnited States · 2025HD-INC-003Google Bard Invented Three Court Cases, and a Lawyer Filed Them Without CheckingUnited States · 2023HD-INC-002Mata v. Avianca: A Lawyer Cited Six Fake Cases and Asked ChatGPT to Confirm ThemUnited States · 2023
Related topics
- Government & public administration 12
- Professional & legal services 10
- Consumer AI 6
- Automation bias 9
- Judgement surrendered 4
- Overconfidence 3
- Defensive denial 2
- Australia 18
- United States 17
- Netherlands 4
Cite this page: Harris, E. (2026). AI incidents involving rules-behaviour gap. Headlights. https://useheadlights.com/topics/behaviour/rules-behaviour-gap/