Deriving Neural Scaling Laws from the statistics of natural language

We inspect the deductive connection between the neural scaling law and Zipf's law -- two statements discussed in machine learning and quantitative linguistics. The neural scaling law describes how the cross entropy rate of a foundation model -- such as a large language model -- changes with respect to the amount of training tokens, parameters, and compute. By contrast, Zipf's law posits that the distribution of tokens exhibits a power law tail. Whereas similar claims have been made in more specific settings, we show that the neural scaling law is a consequence of Zipf's law under certain broad assumptions that we reveal systematically. The derivation steps are as follows: We derive Heaps' law on the vocabulary growth from Zipf's law, Hilberg's hypothesis on the entropy scaling from Heaps' law, and the neural scaling from Hilberg's hypothesis. We illustrate these inference steps by a toy example of the Santa Fe process that satisfies all four statistical laws.

Neural scaling laws approximate a language model's loss as a power-law function of parameter count $N$ and token count $D$. Following Chinchilla-style compute-optimal training, many studies fit scaling laws from runs performed under a fixed tokens-per-parameter (TPP) ratio $k$ and set $D = kN$. We show that this collinear design, combined with the empirically common near-equality of the exponents governing $N$ and $D$, induces an inherent ill-conditioning in the Gauss-Newton least-squares problem: the condition number of the design grows as the inverse square of the gap between the $N$ and $D$-exponents. The scale coefficients become practically unidentifiable, with confidence intervals inflating by an order of magnitude or more, yielding a ``sloppy'' model whose extrapolations degrade sharply off the training ray. We prove this for four scaling-law formalisms and derive a closed-form TPP-diversity threshold that is necessary and sufficient for well-conditioned estimation. Empirically, non-collinear designs outperform collinear ones on held-out splits with a 97.3% win rate across four laws, five corpora, multiple floating point precision modes. We further show the degeneracy is rooted in Jacobian geometry and is not an artifact of the loss function: any smooth estimation objective whose curvature involves the Jacobian inherits the same ill-conditioning.

Neural scaling laws describe how pre-training loss decays as power laws with training time, model size, and compute. This position paper argues that the exponents of these power laws are fixed by generic mechanisms: a one-third time scaling due to the strong nonlinearity of Softmax, an inverse width scaling due to representational superposition, and an inverse depth scaling due to ensemble averaging of Transformer layers. These mechanisms are robust to a wide range of data structures and architectural details, placing current large language models in a universality class with fixed exponents. The coefficients, however, are expected to be sensitive to data and architecture details, and directly determine practical quantities such as the optimal model shape and the compute-optimal frontier. We therefore argue that understanding the coefficients is the key to near-term performance improvements, and that a closer examination of the current universality class may reveal pathways to better universality classes.