Assessing Model-Agnostic XAI Methods against EU AI Act Explainability Requirements
Organizations: University of Italian-Speaking Switzerland (USI) · Analog Devices International · CRIDS, NADI, University of Namur
Abstract
Explainable AI (XAI) has evolved in response to expectations and regulations, such as the EU AI Act, which introduces regulatory requirements on AI-powered systems. However, a persistent gap remains between existing XAI methods and society's legal requirements, leaving practitioners without clear guidance on how to approach compliance in the EU market. To bridge this gap, we study model-agnostic XAI methods and relate their interpretability features to the requirements of the AI Act. We then propose a qualitative-to-quantitative scoring framework: qualitative expert assessments of XAI properties are aggregated into a regulation-specific compliance score. This helps practitioners identify when XAI solutions may support legal explanation requirements while highlighting technical issues that require further research and regulatory clarification.
Figures & tables
| Cluster | Description | Sub-properties |
|---|---|---|
| Faithfulness/ Correctness | How accurately an explanation reflects the underlying model’s true reasoning. | Necessity/No False Positives: Only features or elements that actually influence the model’s outcome. Sufficiency/No False Negatives: Only features irrelevant to the model’s outcome are ignored. Completeness/Coverage: The explanation covers the model’s full rationale, not leaving out relevant factors. |
| Robustness/ Sensitivity | Stability of the explanation under changes in inputs. | Stability/Continuity: Similar instances or minor perturbations yield similar explanations. Adversarial Robustness: Explanation should not be easily manipulated by adversarial examples. |
| Complexity | Complexity of an explanation. | Sparsity/Few Features & Rule/Predicate Size . Dimensionality/Granularity/Level of Detail . |
| XAI Algorithm | Faithfulness | Robustness | Complexity | ||||
| No FP | No FN | Completeness | Stability | Adv. Rob. | Sparsity | Level of Detail | |
| Decision Trees | 2 | 3 | 3 | 1 | 2 | 3 | 5 |
| RuleFit | 3 | 3 | 4 | 3 | 3 | 2 | 4 |
| RuleSHAP | 4 | 4 | 4 | 3 | 3 | 3 | 4 |
| PDP | 3 | 3 | 3 | 4 | 3 | 2 | 4 |
| ICE | 3 | 4 | 2 | 3 | 3 | 2 | 4 |
| XAI Algorithm | Best at (score > 3) | Worst at (score < 3) |
| Decision Trees | Level of Detail (5): Very fine-grained, per-leaf explanations. | Stability (1): Highly sensitive to small data changes. No FP (2): Splits may reflect spurious local patterns. Adv. Rob. (2): Vulnerable to adversarial perturbations. |
| RuleFit | Completeness (4): Blends rules and linear terms for broad coverage. Level of Detail (4): Detailed rule+coefficient breakdown. | Sparsity (2): Hundreds of trees still yield many rules. |
| RuleSHAP | No FP (4): SHAP-driven rules are highly faithful. No FN (4): Captures most true influences. Completeness (4): Rules cover the main decision rationale well. | (none < 3) |
| PDP | Stability (4): Averaging yields smooth, repeatable curves. Level of Detail (4): Full feature-effect curves. | Sparsity (2): Presents every feature’s curve. |
| ICE | No FN (4): Reveals more individual effects. Level of Detail (4): Full per-instance effect curves. | Completeness (2): One feature at a time; limited coverage. Sparsity (2): Still shows a full curve for each data point. |
| LIME | (none > 3) | Stability (1): Extremely sensitive to sampling. Adv. Rob. (1): Easily manipulated. Completeness (2): Local surrogate covers only a narrow neighborhood. |
| Art. 86 | Arts. 13–14 | Art. 11 & Annex IV | ||
| Faithfulness | No false positives | ✓ | preferable | ✓ |
| No false negatives | ✓ | ✓ | ✓ | |
| Completeness | ✗ | ✓(reasonable) | ✓ | |
| Robustness | Stability | ✓ | ✓ | ✓ |
| Adversarial robust. | ✓(partial) | ✓ | ✓ | |
| Complexity | Sparsity | ✓ | ✗ | ✗ |
| XAI method | Scope | Stage |
|---|---|---|
| Decision Trees (surrogate) | local, global | both |
| RuleFit | local, global | both |
| RuleSHAP | local, global | both |
| PDP | global | ex-ante |
| ICE | local, global | both |
| LIME | local | ex-post |
| Provision | Property | Top-3 algorithms (score) |
| Art. 86 | Robustness | SHAP (0.80), RuleFit (0.6) |
| Faithfulness | SHAP (1.), RuleSHAP (0.80), CEM (0.80) | |
| Complexity | Anchors (1.), CEM (0.80), DiCE (0.80) | |
| All | SHAP (0.8), Anchors (0.68), RuleSHAP (0.67) | |
| Arts. 13-14 | Robustness | SHAP (0.80), PDP (0.70), RuleFit (0.60) |
| Faithfulness | SHAP (0.88), RuleSHAP (0.80), CEM (0.78) |