We study high-dimensional convex empirical risk minimization (ERM) under general non-Gaussian data designs. By heuristically extending the Convex Gaussian Min-Max Theorem (CGMT) to non-Gaussian settings, we derive an asymptotic min-max characterization of key statistics, enabling approximation of the mean $μ_{\hatθ}$ and covariance $C_{\hatθ}$ of the ERM estimator $\hatθ$. Specifically, under a concentration assumption on the data matrix and standard regularity conditions on the loss and regularizer, we show that for a test covariate $x$ independent of the training data, the projection $\hatθ^\top x$ approximately follows the convolution of the generally non-Gaussian distribution of $μ_{\hatθ}^\top x$ with an independent centered Gaussian variable of variance $\mathrm{tr}(C_{\hatθ} \mathbb{E}[xx^\top])$. This result clarifies the scope and limits of Gaussian universality for ERMs. Additionally, we prove that any $\mathcal{C}^2$ regularizer is asymptotically equivalent to a quadratic form determined solely by its Hessian at zero and gradient at $μ_{\hatθ}$. Numerical simulations across diverse losses and models are provided to validate our theoretical predictions and qualitative insights.

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