When No Benchmark Exists: Validating Comparative LLM Safety Scoring Without Ground-Truth Labels

Many deployments must compare candidate language models for safety before a labeled benchmark exists for the relevant language, sector, or regulatory regime. We formalize this setting as benchmarkless comparative safety scoring and specify the contract under which a scenario-based audit can be interpreted as deployment evidence. Scores are valid only under a fixed scenario pack, rubric, auditor, judge, sampling configuration, and rerun budget. Because no labels are available, we replace ground-truth agreement with an instrumental-validity chain: responsiveness to a controlled safe-versus-abliterated contrast, dominance of target-driven variance over auditor and judge artifacts, and stability across reruns. We instantiate the chain in SimpleAudit, a local-first scoring instrument, and validate it on a Norwegian safety pack. Safe and abliterated targets separate with AUROC values between 0.89 and 1.00, target identity is the dominant variance component ($η^2 \approx 0.52$), and severity profiles stabilize by ten reruns. Applying the same chain to Petri shows that it admits both tools. The substantial differences arise upstream of the chain, in claim-contract enforcement and deployment fit. A Norwegian public-sector procurement case comparing Borealis and Gemma 3 demonstrates the resulting evidence in practice: the safer model depends on scenario category and risk measure. Consequently, scores, matched deltas, critical rates, uncertainty, and the auditor and judge used must be r