Many regulatory and analytic problems require that a prohibited variable influence a decision only through a designated allowable channel -- a conditional-independence requirement that arises in path-specific fairness, the handling of classified information, and the regulation of trading on non-public information, among other settings. Such requirements may be enforced either stratum-by-stratum or, more commonly (and more efficiently), through a single averaged constraint on the conditional effect. We study the resulting enforcement problem from two perspectives. From the regulator's side, we formulate causal masking as a linear program and show that averaged-constraint optimization almost surely produces policies that violate the stratum-wise requirement while satisfying the averaged one exactly. The gains from masking grow with confounding and outcome heterogeneity, and detection requires precisely the conditional-independence tests that average constraints aim to avoid. From the optimizer's side, the same construction shows that masked policies recover most of the reward of unconstrained exploitation while being far harder to detect, making them attractive in any setting where the basis of decisions is itself sensitive. Together, these results argue that regulating direct dependence through averaged statistics on observed decisions is structurally limited, and that meaningful enforcement must operate at the level of the decision rule itself.
Figures & tables
x
p
Pr(x,p)
Pr(Y=1∣x,p)
Pr(Dmask=1∣x,p)
0
0
\nicefrac115
.5
.5
0
1
\nicefrac915
.5
0
1
0
\nicefrac415
.25
0
1
1
\nicefrac115
1
1
Table 1: A joint distribution on (X,P) , the conditional graduation rate Pr(Y=1∣x,p) , and a masking policy Dmask .
Figure 1: Causal diagrams for the two policy classes. Undirected edges indicate flexibility in causal direction and the possibility of unobserved confounding. The directed edge X→D represents the allowable use of X by the decision rule; the red edge P→D in the right panel is the prohibited direct dependence introduced by exploitative and masked policies.
Figure 2: Four canonical structures over (P,X,Y,D) . Masking generically improves on the unaware policy whenever at least one of X−Y heterogeneity or X−P confounding is present (red box): the leftmost panel has X−Y heterogeneity only, the second has X−P confounding only, and the third has both. When neither is present (blue box), masking provides no gain. Undirected edges indicate flexibility in causal direction and the possibility of unobserved confounding; the directed edges P→D and X→D represent the policy’s use of P and X as inputs.
Figure 3: Sample size required to reject each null hypothesis for the three strategies (mean ± standard error). The masked strategy rejects HATE at sample sizes comparable to the unaware strategy, while the exploitative strategy is rejected almost immediately. Even under the combined test (third panel), the masked strategy persists over twice as long as the exploitative one, and the gap widens with k . Cumulative unfairness (rightmost panel) is highest for the masked strategy because its concealment outlasts its detection.
Appendix figures & tables2 assets
Supplementary material from the paper’s appendix.
Appendix
Figure 4: Synthetic experiments comparing the utility achieved under three constraint configurations, for k=2 (top) and k=10 (bottom). The first column varies εuna alone; the second varies εmask alone; the third fixes εmask=0 and varies εuna .
Figure 5: Comparison of exploit, unaware, mask, and mixed strategies as the sample size N grows, on synthetic data with K=3 and ρ=0.3 . Left: Holm-adjusted p -value for HCATE (conditional independence). Middle: stratified-effect p -value using uniformly-weighted CATEs. Right: normalized cumulative utility per decision. The mask strategy retains the high conditional-independence p -value of the unaware policy while achieving utility comparable to the mixed strategy, demonstrating that masking dominates randomization on the utility-detectability frontier.
Conditional independence testing is a critical component of feature screening, invariant statistical models, and causal discovery. Many of these algorithms rely on the sequential application of conditional independence tests, and their stability hinges on how their outcomes interact. We study this meta-dependence'' between conditional independence properties using the following geometric intuition: satisfying each conditional independence property constrains the space of possible joint distributions to a manifold. The meta-dependence'' of multiple conditional independences in a probability distribution is informed by its position relative to these manifolds. We provide a simple-to-compute measure of this meta-dependence using moment projections, with a closed-form expression for multivariate Gaussian distributions, and consolidate our findings empirically using both synthetic and real-world data. Our measure of meta-dependence does not rely on graphical properties of the distribution and can be computed directly from summary statistics such as a covariance matrix, allowing for various applications. We demonstrate one use case of meta-dependence, using a simple redundancy metric to tune significance thresholds and improve causal discovery.
Bijan Mazaheri, Jiaqi Zhang, Caroline Uhler
Thayer School of Engineering, Dartmouth College, Hanover, New Hampshire, USA · Schmidt Center, Broad Institute of MIT and Harvard, Cambridge, Massachusetts, USA · Laboratory for Information and Decision Systems, Massachusetts Institute of Technology, Cambridge, Massachusetts, USA
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.
Samah Kareem, Barış Çeliktaş
Department of Computer Engineering, Isik University, Istanbul, Türkiye. · Department of Computer Engineering, I¸sık University, Istanbul, Türkiye.
We study causal logistic bandits with counterfactual fairness constraints. The causal structure is given through known factual and counterfactual feature maps that share an unknown logistic reward parameter, but the learner observes only factual rewards. Consequently, the directions determining counterfactual feasibility need not be identifiable from the available feedback. The closest prior analyses either omit a coverage condition or impose a comparatively strong one, and do not establish matching lower bounds. We first show that some coverage condition is necessary: without a coverage-type restriction, factually indistinguishable environments with different optimal fair actions force Ω(T) expected joint loss. Under a weaker full-rank condition on the factual covariance pooled across actions, we identify a target-specific information scale V⋆ that measures the difficulty of estimating rewards and counterfactual effects from factual feedback. We construct worst-case families satisfying this condition on which every policy incurs expected joint loss Ω([V⋆min{logK,d}]1/3T2/3). We also give an explore--then--exploit procedure tuned using V⋆ and an adaptive algorithm that does not require its value. Both algorithms achieve max{RT,VT}=O([V⋆min{logK,d}]1/3T2/3+κd/σ02), where RT is regret relative to the best fair action and VT denotes the cumulative stage-wise positive violations. Thus the upper and lower bounds match in their leading dependence on T, V⋆, and min{logK,d}, up to logarithmic factors.
Junhyuk Huh, Seoungbin Bae, Dabeen Lee
Faculty of Mathematics, University of Cambridge · Department of Industrial & Systems Engineering, KAIST · Department of Mathematical Sciences, Seoul National University