# Taking the Whys Seriously: Limitations of Counterfactual Explanations in Justification and Recourse

arXiv: https://arxiv.org/abs/2608.30956 · HTML: https://mlsanity.com/paper/2608.30956/

## Key facts

- No citing papers in the map yet (data through 14 Oct 2026).
- Builds on 20 of its 43 references that are in the map.
- First posted on arXiv 31 Aug 2026.

## Builds on (most cited first, 20 of 20)

- [A Unified Approach to Interpreting Model Predictions](https://mlsanity.com/paper/1705.07874/) (2017)
- ["Why Should I Trust You?": Explaining the Predictions of Any Classifier](https://mlsanity.com/paper/1602.04938/) (2016)
- [Towards A Rigorous Science of Interpretable Machine Learning](https://mlsanity.com/paper/1702.08608/) (2017)
- [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)
- [Counterfactual Explanations without Opening the Black Box: Automated Decisions and the GDPR](https://mlsanity.com/paper/1711.00399/) (2017)
- [A Survey Of Methods For Explaining Black Box Models](https://mlsanity.com/paper/1802.01933/) (2018)
- [Counterfactual Fairness](https://mlsanity.com/paper/1703.06856/) (2017)
- [Explaining Machine Learning Classifiers through Diverse Counterfactual Explanations](https://mlsanity.com/paper/1905.07697/) (2019)
- [Actionable Recourse in Linear Classification](https://mlsanity.com/paper/1809.06514/) (2018)
- [Algorithmic Recourse: from Counterfactual Explanations to Interventions](https://mlsanity.com/paper/2002.06278/) (2020)
- [The Hidden Assumptions Behind Counterfactual Explanations and Principal Reasons](https://mlsanity.com/paper/1912.04930/) (2019)
- [Counterfactual Explanations Can Be Manipulated](https://mlsanity.com/paper/2106.02666/) (2021)
- [Towards Robust and Reliable Algorithmic Recourse](https://mlsanity.com/paper/2102.13620/) (2021)
- [NICE: An Algorithm for Nearest Instance Counterfactual Explanations](https://mlsanity.com/paper/2104.07411/) (2021)
- [The Use and Misuse of Counterfactuals in Ethical Machine Learning](https://mlsanity.com/paper/2102.05085/) (2021)
- [On the Robustness of Sparse Counterfactual Explanations to Adverse Perturbations](https://mlsanity.com/paper/2201.09051/) (2022)
- [LLMs for Generating and Evaluating Counterfactuals: A Comprehensive Study](https://mlsanity.com/paper/2405.00722/) (2024)
- [AI Hiring with LLMs: A Context-Aware and Explainable Multi-Agent Framework for Resume Screening](https://mlsanity.com/paper/2504.02870/) (2025)
- [An External Stability Audit Framework to Test the Validity of Personality Prediction in AI Hiring](https://mlsanity.com/paper/2201.09151/) (2022)

## Abstract (arXiv)

Counterfactual explanations (CEs) are widely used in explainable artificial intelligence (AI) to show how a model's outputs would change if the input features were manipulated. This technique is used for a range of tasks such as debugging models, explaining predictions, justifying decisions, and providing algorithmic recourse. In this paper, we explore the normative legitimacy of employing counterfactuals in real-life model deployment settings. We discuss the different stakes involved in these different purposes for which CEs are commonly employed, and find stricter requirements for justification and recourse. In particular, we find that naive application of CEs for justification and recourse can lead to ignoring contestable choices made throughout the machine learning (ML) pipeline, thus obfuscating that decisions and counterfactuals for those decisions are also artifacts of an organization's materialized design and governance choices. We demonstrate this with four empirical experiments involving interventions at stages of the ML pipeline ``upstream" of the explanation itself, and show that these affect the generated counterfactuals. We find that an organization's choices on measurement models for feature and labels, business requirements, model validation, and the metric of model success have as much or more impact on the generated counterfactuals as the specifics of the generating method. Our findings underline the need to account for such choices upon providing justification and recourse, providing a stark reminder of the relational nature of these tasks. As putative justifications or recourse recommendations, CEs do not provide adequate answers to some important "why"-questions because they preclude consideration of whether the decision-maker ought to have acted differently.
