One provider cut off two models for every customer, on a US directive. What to copy now.

Disclosure: I run Katonic, which sells a sovereign AI platform to regulated buyers, including in the Gulf. Own Your AI, every second Thursday: one thing to copy into a contract, a runbook or a board paper.

Last Thursday the president of the European Central Bank put that event in a speech. For Europe, she said, "the result was an abrupt cut-off", and tools vital to financial resilience must not "depend on a switch controlled elsewhere". When a central bank president says it, your supervisor reads it. Then your board asks you.

I sell AI platforms to banks and governments, so I sit on the other side of this table most weeks. I have watched "who can switch this off" go from a slide nobody asked about to the first thing procurement writes down.

In the same ten days a US procurement office wrote it into a clause, Brazil wrote it into a lab test, and a UK committee chair called it a kill switch.

You do not need a framework to answer it. You need three things you can copy this week: a contract clause a government has already written, a one-hour test another government already runs, and one paragraph for the board paper you are writing anyway.

The clause: copy it from the US federal government

What happened. On 28 September the US General Services Administration issued its contract clause for large language models, 552.239-7001, effective Monday 19 October, per a law-firm analysis of 2 October. It applies where the model is a material feature of what is bought and government data goes in or comes out.

Two lines matter. The government may suspend use of the model "at any time", without qualification in the law firm's reading. And the supplier must report any incident that may affect the confidentiality, integrity or availability of government data.

Why it matters to you. Most AI contracts give the customer a right to leave, with notice. Almost none give the customer a right to pause: stop the model today, keep the data, keep the contract, decide later. The federal buyer has written the pause in, and anything a government can get written, a bank can.

Under DORA, EU financial entities already carry exit, incident and subcontractor terms for critical ICT services. The five lines below are the AI-specific additions. Line 5 is the one your DORA register of information does not capture.

Copy this. Put the five lines below into your next AI request for proposal, or your next renewal, as mandatory written responses. Score the redline each vendor returns, not the yes. The first two start from the US clause as a law firm summarised it; the fee line and the 24 hours are mine, as are the other three.

1. We may suspend use of any model at any time, without conditions, while the rest of the contract runs, fees for the suspended use stop, and the pause counts against no minimum commitment.
2. You report any incident that may affect the confidentiality, integrity or availability of our data in or out of the model, including at your subcontractors, within [24] hours of detection.
3. Our data is not used to train or improve any model without our written consent.
4. On suspension or exit you return our data, prompts, evaluations, embeddings and any fine-tuned weights where the licence permits export, otherwise the data and recipe to recreate them, in a format we name, and help us move, within a period we set.
5. You list the countries of incorporation, operation and data location for you, your parent and each subcontractor in the chain, and tell us in writing who, other than us, can suspend the service, what notice we get when they do, or why none.

What you will hear back. Three answers, nearly every time I sit on the selling side of this table. "We are multi-region": a location answer to a control question. "Suspension is covered by termination for convenience": your right to leave, not your right to pause and keep what is yours.

"We have never had an outage like that." Nobody had. June was not an outage. It was a directive.

The drill: one hour, the Brazilian way

What happened. Brazil's state IT company, Serpro, wrote the admission test for the Nuvem Brasileira, the state-run sovereign cloud whose market consultation closed on 25 September. A candidate solution goes into a laboratory and its external connection is cut.

It passes if the essential services keep running and the environment stays administrable. A console outside the national data centre, or a permanent external connection needed for administration, counts against it.

Why it matters to you. A government has turned "could we run without them" from a contract question into a lab result. Out of 100, it gives 30 to where the data sits and 40 to whether the thing keeps running when the cable is cut.

You can run the same test on one system in an hour, with a firewall rule and a stopwatch.

Copy this. Pick one AI system you would miss on a Monday. Book an hour with the people who run it. Staging first: on production this is a change ticket. Under DORA, or your regulator's technology risk rules, file it as a resilience test; that is how you get the people.

Here is what you will find, in my experience. It is rarely the model that stops first. It is identity, the licence server, the key service and the console, in roughly that order, and three of those four are usually sold to you as part of the platform. Now prove it:

• Minute 0. Name the system, the hour, and the person writing the list.
• Minute 5. Block traffic from the system to everything you do not administer yourself, including private endpoints into your cloud provider. One rule, reversible. Tell the on-call team first and keep a break-glass login that does not depend on a provider's identity service.
• Minute 10. Log in. If identity lives with a provider, this is where most lists of what stopped start.
• Minute 15. Send the model a real request. Note whether it answers, fails or hangs.
• Minute 20. Open the admin console. Change one setting.
• Minute 25. Read one secret. Rotate a key only in staging. Note where the key service lives.
• Minute 30. Pull one update: a package, an image, a model file. Note what the licence check does.
• Minute 40. Check that logs and alerts still reach the people on call.
• Minute 50. Remove the rule. Confirm everything comes back, and how long that took.
• Minute 60. Write the list of what stopped, who owns each item, and the date of the next hour.

If the system is software as a service there is nothing inside your network to block, and the hour ends at minute 5 with the word "everything". Write that down. It is the most common result. If the system runs inside a hyperscaler, the rule you can write is theirs, and the honest answer is the same word.

The list is your answer to Brazil's test. One provider is running the same test on itself. AWS will cut its European Sovereign Cloud off from its global network for several hours on Saturday 24 October, announced on 28 September, with an EU-resident team and only what sits inside the region. Credit for doing it in public.

It proves the region runs without the parent's network, and nothing about who can compel the parent.

The paragraph: for the board paper you are writing anyway

What happened. Christine Lagarde's speech of 1 October adds two things to the June story. General access came back a few weeks later, but the model with fewer cyber safeguards built in stayed limited to organisations vetted by the US administration. And she did not name the provider from the podium. Footnote 23 does.

Three days later Chi Onwurah, who chairs the UK Commons science, innovation and technology committee, told Bloomberg that two US providers supply as much as 80 percent of the cloud the UK government buys. The CLOUD Act, a 2018 US law on access to data, is what she called a kill switch. June's switch was export control, a different law.

"The president could kill parts of critical national infrastructure by turning it off." Chi Onwurah MP, 4 October 2026.

Why it matters to you. Lines 1 to 4 of the clause cover what your vendor controls. June is line 5: nobody in your contract held the switch. Better the board hears it from you than from your supervisor.

Copy this. Paste it, fill the brackets, name the owner.

In June 2026, as the ECB president said on 1 October, a US export-control directive led one model provider to suspend access to two of its models for all its customers. We [do / do not] use that provider. We run [N] applications on hosted models from [M] providers. Our contracts give us [X] days' notice of withdrawal, and clause [Y / none] addresses whether the provider may shorten that notice to comply with law. We have [not yet] rehearsed running [system] without the primary provider; the last test was on [date] and [what stopped]. Owner: [name]. Next test: [date]. Decision sought: [fund a second path / accept the risk / test by date].

From the room

What I have seen in the last fortnight, names and numbers removed.

A bank in Southeast Asia, buying through a hardware partner, asked for the renewal price of years two and three before it would sign year one. It is the right question: a renewal you cannot afford is an off-switch with a twelve-month fuse, and the people who signed year one are rarely in the room when it burns.

Ask for the number, in writing, before the first invoice.

A European telecom operator asked whether to reach two US frontier labs directly or through a broker. One lab's own API offered no EU inference region when we checked last week, so the "EU" route runs through a hyperscaler's marketplace.

That changes who can switch you off: the notice period you hold is the reseller's, not the lab's, and the deprecation clock is the reseller's too. Before you sign for a hosted model, write down whose door you are walking through.

One against us, so you know I keep the same score. In September a routine job on a development environment of a platform we run for a customer asked a cloud provider for its list of model deployments, got back an empty list with a success code, believed it, and deleted the model settings of every customer organisation on it.

Nobody had switched anything off. Our code trusted an empty answer. The settings came back by hand inside the morning. The fix was obvious afterwards: an empty list from a provider is a fault, not a fact. Add that line to your disconnection hour.

Outside the perimeter

From the fortnight, each with one thing to do.

Twenty days. OpenAI removed gpt-5.4-cyber on 1 October, twenty days after notice on 11 September, under the safety-or-compliance exception to its published six-month notice policy. Anthropic gave sixty days' notice on Claude Sonnet 4.5 on 30 September and notes that partner channels set their own schedules.

Do this: find your shortest notice period across every hosted model you use, on the page of whoever you buy through, reseller or marketplace, not the lab's, and put that number in the board paragraph.

Six hours in Sweden. Azure OpenAI and Azure AI Foundry in Sweden Central returned failures and HTTP 5XX errors for nearly six hours on 29 September, per Microsoft's incident record; the next night its private connectivity gateways degraded across several European regions for five and three quarter hours. The region did not move. The service did not answer.

Do this: pull your request logs for those two windows. If something failed, you have already run the hour, unplanned.

One to watch. California's attorney general served OpenAI with an investigative subpoena on 1 October over cybersecurity incidents involving its models. No view on the merits. Do this: ask whether your contract gets you incident facts as fast as a prosecutor gets them.

Before Friday

1. Put the five clause lines into the next AI RFP, or the next renewal, as mandatory written responses.
2. Book the hour. Run it before the end of October, before a tender or a supervisor runs it for you.
3. Paste the paragraph into the next board risk paper, with a named owner and a test date.

Then one line in the comments: what stopped first in your hour. I will collect them for the next issue, no names.

I can be argued out of this. If you think a suspension clause is theatre because the vendor who matters will never sign it, say so, and tell me what you got them to sign instead. And if your hour produced an empty list, I want to see the firewall rule.

Next issue, Thursday 22 October: the exit clause. Five AI contracts read side by side, no names, and what each would actually get you the morning after. Plus your hour results.

About this newsletter

Own Your AI comes out every second Thursday. Subscribe if it is useful, and tell me where you disagree.

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References

1. Crowell & Moring client alert, "GSA Issues Final Rule on Large Language Model Procurements", 2 October 2026: clause 552.239-7001 issued 28 September, effective 19 October, suspension right "at any time", incident reporting, scope. The GSA deviation itself was not opened.
2. Serpro, "Soberania sem isolamento", 4 September 2026: the laboratory disconnection test, the console sentence, fifteen criteria weighted 30/40/30 (data, operations, technology).
3. Intelligent CIO LATAM, Bill Tanner, "Brazil tests whether its sovereign Cloud can survive being disconnected", 2 October 2026; the 25 September consultation close was reported by Tele.Sintese on 14 September 2026.
4. AWS Security Blog, "AWS European Sovereign Cloud: demonstrating an independent operation", 28 September 2026: the 24 October disconnection exercise, run by a team of EU residents using only the hardware and software inside the region, results to be shared with regulators and customers.
5. European Central Bank, Christine Lagarde, "Where AI risks meet", Frankfurt am Main, 1 October 2026; the June paragraph verbatim: "led their provider to suspend access", "an abrupt cut-off", general-use model restored a few weeks later, the model with fewer cyber safeguards limited to organisations vetted by the US administration; "switch controlled elsewhere"; footnote 23 names the provider and the two models and says access was suspended for all customers, including those in the United States.
6. Bloomberg, Philip Aldrick and Jacob Reid, "Britain's Reliance on US Cloud Giants Alarms Its Politicians", 4 October 2026, read via Yahoo Finance UK; Chi Onwurah quotes and the 80 percent figure.
7. OpenAI, API deprecations page: gpt-5.4-cyber removal of 1 October 2026 after notice on 11 September, and the deprecation policy (six months' notice as standard, with a safety or compliance exception), read 5 October 2026.
8. Anthropic, model deprecations page: Claude Sonnet 4.5 notice of 30 September 2026, retirement 30 November, partner platforms set their own schedules, read 5 October 2026.
9. Microsoft, Azure status history: incident 7QL5-Z50, Sweden Central, 29 September 2026 10:03 to 15:58 UTC; incident 7Q30-010, gateway services in several regions, 30 September 20:30 to 1 October 02:15 UTC.
10. California Department of Justice, "As Part of Ongoing Investigation, Attorney General Bonta Serves Investigative Subpoena on OpenAI", 1 October 2026.