AI Transparency: Governance Compliance or Stakeholder Requirements?
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Abstract (arXiv)
Transparency is increasingly mandated for public-sector AI systems, with organisations required to publish statements describing their AI use and oversight arrangements. However, the existence of such artefacts is often treated as equivalent to transparency itself, despite limited evidence that they proportionately serve relevant stakeholder groups. From a requirements engineering perspective, this raises a validation concern: compliance with mandated disclosure criteria does not necessarily ensure transparency adequacy for stakeholders with different levels of risk exposure, decision control, and involvement. This paper presents an empirical analysis of 92 publicly available AI transparency statements published by Australian Government agencies under the national AI governance mandate. We introduce the stakeholder Risk--Control--Involvement--Need (RCIN) framework to differentiate stakeholder classes according to their structural position and transparency needs. Using a structured rubric derived from the mandated criteria, we evaluate how both the mandate and published statements are calibrated to each stakeholder class. The findings show that while structural compliance is widespread, transparency calibration is uneven. Criteria serving high-control stakeholders are consistently realised, whereas criteria most critical for high-risk, low-control stakeholders are fewer and less substantively addressed. We conceptualise this as the Transparency Illusion: a condition in which transparency appears satisfied through compliant artefacts yet remains unevenly calibrated to stakeholders bearing the greatest exposure to AI-supported decisions. The study frames transparency as a stakeholder-calibrated validation problem, demonstrating that artefact-level compliance does not constitute requirements validation in this context.
Key facts. No citing papers in the map yet (data through 7 Oct 2026). Builds on 11 of its 52 references that are in the map. First posted on arXiv 16 Jun 2026.
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References · 11
- 2019Explainable Artificial Intelligence (XAI): Concepts, Taxonomies, Opportunities and Challenges toward Responsible AIcited by 1,543
- 2017Explanation in Artificial Intelligence: Insights from the Social Sciencescited by 1,201
- 2022From Anecdotal Evidence to Quantitative Evaluation Methods: A Systematic Review on Evaluating Explainable AIcited by 299
- 2020Towards Accountability for Machine Learning Datasets: Practices from Software Engineering and Infrastructurecited by 138
- 2021What Do We Want From Explainable Artificial Intelligence (XAI)? -- A Stakeholder Perspective on XAI and a Conceptual Model Guiding Interdisciplinary XAI Researchcited by 119
- 2022A Transparency Index Framework for AI in Educationcited by 13
- 2022Think About the Stakeholders First! Towards an Algorithmic Transparency Playbook for Regulatory Compliancecited by 7
- 2025Audit Cards: Contextualizing AI Evaluationscited by 7
- 2024A Comprehensive Survey and Classification of Evaluation Criteria for Trustworthy Artificial Intelligencecited by 3
- 2025Explainable AI Systems Must Be Contestable: Here's How to Make It Happencited by 2
- 2025A Comprehensive Perspective on Explainable AI across the Machine Learning Workflowcited by 1
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