Bridging the Transparency Gap: What Can Explainable AI Learn From the AI Act?
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Abstract (arXiv)
The European Union has proposed the Artificial Intelligence Act which introduces detailed requirements of transparency for AI systems. Many of these requirements can be addressed by the field of explainable AI (XAI), however, there is a fundamental difference between XAI and the Act regarding what transparency is. The Act views transparency as a means that supports wider values, such as accountability, human rights, and sustainable innovation. In contrast, XAI views transparency narrowly as an end in itself, focusing on explaining complex algorithmic properties without considering the socio-technical context. We call this difference the ``transparency gap''. Failing to address the transparency gap, XAI risks leaving a range of transparency issues unaddressed. To begin to bridge this gap, we overview and clarify the terminology of how XAI and European regulation -- the Act and the related General Data Protection Regulation (GDPR) -- view basic definitions of transparency. By comparing the disparate views of XAI and regulation, we arrive at four axes where practical work could bridge the transparency gap: defining the scope of transparency, clarifying the legal status of XAI, addressing issues with conformity assessment, and building explainability for datasets.
Key facts. Cited by 10 papers in the map (data through 7 Oct 2026). Builds on 23 of its 75 references that are in the map. First posted on arXiv 21 Feb 2023.
Builds on
23 of 75 references.
References · 23
- 2016"Why Should I Trust You?": Explaining the Predictions of Any Classifiercited by 5,040
- 2018Datasheets for Datasetscited by 1,371
- 2017Explanation in Artificial Intelligence: Insights from the Social Sciencescited by 1,201
- 2018A Survey Of Methods For Explaining Black Box Modelscited by 970
- 2018e-SNLI: Natural Language Inference with Natural Language Explanationscited by 468
- 2021Interpretable Machine Learning: Fundamental Principles and 10 Grand Challengescited by 364
- 2016European Union regulations on algorithmic decision-making and a "right to explanation"cited by 343
- 2018Metrics for Explainable AI: Challenges and Prospectscited by 257
- 2020A Survey on the Explainability of Supervised Machine Learningcited by 225
- 2018Explaining Explanations in AIcited by 136
- 2021What Do We Want From Explainable Artificial Intelligence (XAI)? -- A Stakeholder Perspective on XAI and a Conceptual Model Guiding Interdisciplinary XAI Researchcited by 119
- 2019Explainability Fact Sheets: A Framework for Systematic Assessment of Explainable Approachescited by 101
11 more
- 2021A Comprehensive Taxonomy for Explainable Artificial Intelligence: A Systematic Survey of Surveys on Methods and Conceptscited by 90
- 2021Demystifying the Draft EU Artificial Intelligence Actcited by 82
- 2020Black-box Explanation of Object Detectors via Saliency Mapscited by 74
- 2021Explainable Artificial Intelligence for Autonomous Driving: A Comprehensive Overview and Field Guide for Future Research Directionscited by 73
- 2022Connecting Algorithmic Research and Usage Contexts: A Perspective of Contextualized Evaluation for Explainable AIcited by 40
- 2021Knowledge-Grounded Self-Rationalization via Extractive and Natural Language Explanationscited by 24
- 2019Exciting, Useful, Worrying, Futuristic: Public Perception of Artificial Intelligence in 8 Countriescited by 20
- 2022"There Is Not Enough Information": On the Effects of Explanations on Perceptions of Informational Fairness and Trustworthiness in Automated Decision-Makingcited by 19
- 2018Enslaving the Algorithm: From a "Right to an Explanation" to a "Right to Better Decisions"?cited by 14
- 2021Understanding Prediction Discrepancies in Machine Learning Classifierscited by 6
- 2022A Human-Centric Assessment Framework for AIcited by 2
Built on by
Citing papers per year: 2024: 4; 2025: 4; 2026: 2.
10 papers.
- 2024Explainable AI for Safe and Trustworthy Autonomous Driving: A Systematic Reviewcited by 52
- 2024Exploring the Limits of Zero Shot Vision Language Models for Hate Meme Detection: The Vulnerabilities and their Interpretationscited by 10
- 2024How should AI decisions be explained? Requirements for Explanations from the Perspective of European Lawcited by 10
- 2025The Accountability Paradox: How Platform API Restrictions Undermine AI Transparency Mandatescited by 7
- 2025Integrating Counterfactual Simulations with Language Models for Explaining Multi-Agent Behaviourcited by 3
- 2024People Attribute Purpose to Autonomous Vehicles When Explaining Their Behavior: Insights from Cognitive Science for Explainable AIcited by 2
- 2025Building Symbiotic AI: Reviewing the AI Act for a Human-Centred, Principle-Based Frameworkcited by 2
- 2025An Analysis of the New EU AI Act and A Proposed Standardization Framework for Machine Learning Fairnesscited by 1
- 2026Assessing Model-Agnostic XAI Methods against EU AI Act Explainability Requirementscited by 1
- 2026Transferable XAI: Relating Understanding Across Domains with Explanation Transfercited by 0
- 2026Assessing Model-Agnostic XAI Methods against EU AI Act Explainability Requirements19 Mar 2026
- 2026Transferable XAI: Relating Understanding Across Domains with Explanation Transfer14 Feb 2026
- 2025An Analysis of the New EU AI Act and A Proposed Standardization Framework for Machine Learning Fairness30 Sep 2025
- 2025Integrating Counterfactual Simulations with Language Models for Explaining Multi-Agent Behaviour23 May 2025
- 2025The Accountability Paradox: How Platform API Restrictions Undermine AI Transparency Mandates16 May 2025
- 2025Building Symbiotic AI: Reviewing the AI Act for a Human-Centred, Principle-Based Framework14 Jan 2025
- 2024How should AI decisions be explained? Requirements for Explanations from the Perspective of European Law19 Apr 2024
- 2024People Attribute Purpose to Autonomous Vehicles When Explaining Their Behavior: Insights from Cognitive Science for Explainable AI11 Mar 2024
- 2024Exploring the Limits of Zero Shot Vision Language Models for Hate Meme Detection: The Vulnerabilities and their Interpretations19 Feb 2024
- 2024Explainable AI for Safe and Trustworthy Autonomous Driving: A Systematic Review8 Feb 2024