# Causal Evidentiary Governance for High-Risk Machine Learning Systems

arXiv: https://arxiv.org/abs/2609.01040 · HTML: https://mlsanity.com/paper/2609.01040/

## Key facts

- No citing papers in the map yet (data through 14 Oct 2026).
- Builds on 10 of its 21 references that are in the map.
- First posted on arXiv 1 Sep 2026.

## Builds on (most cited first, 10 of 10)

- [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)
- [Counterfactual Explanations without Opening the Black Box: Automated Decisions and the GDPR](https://mlsanity.com/paper/1711.00399/) (2017)
- [Counterfactual Fairness](https://mlsanity.com/paper/1703.06856/) (2017)
- [Fair prediction with disparate impact: A study of bias in recidivism prediction instruments](https://mlsanity.com/paper/1610.07524/) (2016)
- [Algorithmic decision making and the cost of fairness](https://mlsanity.com/paper/1701.08230/) (2017)
- [Closing the AI Accountability Gap: Defining an End-to-End Framework for Internal Algorithmic Auditing](https://mlsanity.com/paper/2001.00973/) (2020)
- [Path-Specific Counterfactual Fairness](https://mlsanity.com/paper/1802.08139/) (2018)
- [Auditing large language models: a three-layered approach](https://mlsanity.com/paper/2302.08500/) (2023)
- [The Sensitivity of Counterfactual Fairness to Unmeasured Confounding](https://mlsanity.com/paper/1907.01040/) (2019)

## Abstract (arXiv)

Machine learning systems deployed for credit, hiring, and resource distribution are increasingly subject to regulatory oversight from policies such as the EU AI Act and GDPR. Current fairness governance practices rely on observational fairness metrics, post-hoc explainability, and immutable audit logs, but provide limited support for causal attribution and efficient evidentiary verification. We introduce Causal Evidentiary Governance (CEG), a framework in which regulated institutions commit to a versioned directed acyclic graph (DAG) that partitions causal pathways into allowable and disallowed groups. The Causal Harm Rate measures prediction variation attributable to disallowed causal pathways. Each decision is accompanied by a signed Decision-Evidence Packet (DEP), cryptographically binding the prediction to a digest of the published DAG and path-specific attributions. DEP digests can be appended to a Merkle tree to enable logarithmic-cost inclusion proofs. We validate CEG through a two-layer empirical methodology using demographic summaries from four years of PMA credit supervisory data to construct 10,000 synthetic credit applicants across four strategic DAG counterfactuals. Causal Harm Rate isolates injected causal effects more clearly than demographic parity or equalized odds. Cross-model validation and ablation studies assess robustness. Evaluation on the German Credit dataset shows that harm associated with specific causal pathways can be substantially understated by associational fairness metrics. Finally, a proof-of-concept implementation demonstrates operationally plausible throughput and highlights relevant performance tradeoffs.