# Bridging the Transparency Gap: What Can Explainable AI Learn From the AI Act?

arXiv: https://arxiv.org/abs/2302.10766 · HTML: https://mlsanity.com/paper/2302.10766/

## Key facts

- Cited by 10 papers in the map (data through 14 Oct 2026).
- Builds on 23 of its 75 references that are in the map.
- First posted on arXiv 21 Feb 2023.

## Builds on (most cited first, 23 of 23)

- ["Why Should I Trust You?": Explaining the Predictions of Any Classifier](https://mlsanity.com/paper/1602.04938/) (2016)
- [Datasheets for Datasets](https://mlsanity.com/paper/1803.09010/) (2018)
- [Explanation in Artificial Intelligence: Insights from the Social Sciences](https://mlsanity.com/paper/1706.07269/) (2017)
- [A Survey Of Methods For Explaining Black Box Models](https://mlsanity.com/paper/1802.01933/) (2018)
- [e-SNLI: Natural Language Inference with Natural Language Explanations](https://mlsanity.com/paper/1812.01193/) (2018)
- [Interpretable Machine Learning: Fundamental Principles and 10 Grand Challenges](https://mlsanity.com/paper/2103.11251/) (2021)
- [European Union regulations on algorithmic decision-making and a "right to explanation"](https://mlsanity.com/paper/1606.08813/) (2016)
- [Metrics for Explainable AI: Challenges and Prospects](https://mlsanity.com/paper/1812.04608/) (2018)
- [A Survey on the Explainability of Supervised Machine Learning](https://mlsanity.com/paper/2011.07876/) (2020)
- [Explaining Explanations in AI](https://mlsanity.com/paper/1811.01439/) (2018)
- [What Do We Want From Explainable Artificial Intelligence (XAI)? -- A Stakeholder Perspective on XAI and a Conceptual Model Guiding Interdisciplinary XAI Research](https://mlsanity.com/paper/2102.07817/) (2021)
- [Explainability Fact Sheets: A Framework for Systematic Assessment of Explainable Approaches](https://mlsanity.com/paper/1912.05100/) (2019)
- [A Comprehensive Taxonomy for Explainable Artificial Intelligence: A Systematic Survey of Surveys on Methods and Concepts](https://mlsanity.com/paper/2105.07190/) (2021)
- [Demystifying the Draft EU Artificial Intelligence Act](https://mlsanity.com/paper/2107.03721/) (2021)
- [Black-box Explanation of Object Detectors via Saliency Maps](https://mlsanity.com/paper/2006.03204/) (2020)
- [Explainable Artificial Intelligence for Autonomous Driving: A Comprehensive Overview and Field Guide for Future Research Directions](https://mlsanity.com/paper/2112.11561/) (2021)
- [Connecting Algorithmic Research and Usage Contexts: A Perspective of Contextualized Evaluation for Explainable AI](https://mlsanity.com/paper/2206.10847/) (2022)
- [Knowledge-Grounded Self-Rationalization via Extractive and Natural Language Explanations](https://mlsanity.com/paper/2106.13876/) (2021)
- [Exciting, Useful, Worrying, Futuristic: Public Perception of Artificial Intelligence in 8 Countries](https://mlsanity.com/paper/2001.00081/) (2019)
- ["There Is Not Enough Information": On the Effects of Explanations on Perceptions of Informational Fairness and Trustworthiness in Automated Decision-Making](https://mlsanity.com/paper/2205.05758/) (2022)
- [Enslaving the Algorithm: From a "Right to an Explanation" to a "Right to Better Decisions"?](https://mlsanity.com/paper/1803.07540/) (2018)
- [Understanding Prediction Discrepancies in Machine Learning Classifiers](https://mlsanity.com/paper/2104.05467/) (2021)
- [A Human-Centric Assessment Framework for AI](https://mlsanity.com/paper/2205.12749/) (2022)

## Built on by (most cited first, 10 of 10)

- [Explainable AI for Safe and Trustworthy Autonomous Driving: A Systematic Review](https://mlsanity.com/paper/2402.10086/) (2024)
- [How should AI decisions be explained? Requirements for Explanations from the Perspective of European Law](https://mlsanity.com/paper/2404.12762/) (2024)
- [Exploring the Limits of Zero Shot Vision Language Models for Hate Meme Detection: The Vulnerabilities and their Interpretations](https://mlsanity.com/paper/2402.12198/) (2024)
- [The Accountability Paradox: How Platform API Restrictions Undermine AI Transparency Mandates](https://mlsanity.com/paper/2505.11577/) (2025)
- [Integrating Counterfactual Simulations with Language Models for Explaining Multi-Agent Behaviour](https://mlsanity.com/paper/2505.17801/) (2025)
- [People Attribute Purpose to Autonomous Vehicles When Explaining Their Behavior: Insights from Cognitive Science for Explainable AI](https://mlsanity.com/paper/2403.08828/) (2024)
- [Building Symbiotic AI: Reviewing the AI Act for a Human-Centred, Principle-Based Framework](https://mlsanity.com/paper/2501.08046/) (2025)
- [An Analysis of the New EU AI Act and A Proposed Standardization Framework for Machine Learning Fairness](https://mlsanity.com/paper/2510.01281/) (2025)
- [Assessing Model-Agnostic XAI Methods against EU AI Act Explainability Requirements](https://mlsanity.com/paper/2604.09628/) (2026)
- [Transferable XAI: Relating Understanding Across Domains with Explanation Transfer](https://mlsanity.com/paper/2602.13675/) (2026)

## 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.