# AI Transparency: Governance Compliance or Stakeholder Requirements?

arXiv: https://arxiv.org/abs/2606.30652 · HTML: https://mlsanity.com/paper/2606.30652/

## Key facts

- No citing papers in the map yet (data through 14 Oct 2026).
- Builds on 11 of its 52 references that are in the map.
- First posted on arXiv 16 Jun 2026.

## Builds on (most cited first, 11 of 11)

- [Explainable Artificial Intelligence (XAI): Concepts, Taxonomies, Opportunities and Challenges toward Responsible AI](https://mlsanity.com/paper/1910.10045/) (2019)
- [Explanation in Artificial Intelligence: Insights from the Social Sciences](https://mlsanity.com/paper/1706.07269/) (2017)
- [From Anecdotal Evidence to Quantitative Evaluation Methods: A Systematic Review on Evaluating Explainable AI](https://mlsanity.com/paper/2201.08164/) (2022)
- [Towards Accountability for Machine Learning Datasets: Practices from Software Engineering and Infrastructure](https://mlsanity.com/paper/2010.13561/) (2020)
- [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)
- [A Transparency Index Framework for AI in Education](https://mlsanity.com/paper/2206.03220/) (2022)
- [Audit Cards: Contextualizing AI Evaluations](https://mlsanity.com/paper/2504.13839/) (2025)
- [Think About the Stakeholders First! Towards an Algorithmic Transparency Playbook for Regulatory Compliance](https://mlsanity.com/paper/2207.01482/) (2022)
- [A Comprehensive Survey and Classification of Evaluation Criteria for Trustworthy Artificial Intelligence](https://mlsanity.com/paper/2410.17281/) (2024)
- [Explainable AI Systems Must Be Contestable: Here's How to Make It Happen](https://mlsanity.com/paper/2506.01662/) (2025)
- [A Comprehensive Perspective on Explainable AI across the Machine Learning Workflow](https://mlsanity.com/paper/2508.11529/) (2025)

## 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.