Engaged AI Governance: Addressing the Last Mile Challenge Through Internal Expert Collaboration
Authors: Simon Jarvers, Orestis Papakyriakopoulos
Organizations: Technical University of Munich, Professorship for Societal Computing, Munich, Germany
Abstract
Under the EU AI Act, translating AI governance requirements into software development practice remains challenging. While AI governance frameworks exist at industry and organizational levels, empirical evidence of team-level implementation is scarce. We address this "Last Mile" Challenge through insider action research embedded within an AI startup. We present a legal-text-to-action pipeline that translates EU AI Act requirements into actionable strategies through internal expert collaboration by extracting requirements from legal text, engaging practitioners in assessment and ideation, and prioritizing implementation through collective evaluation. Our analysis reveals three patterns in how practitioners perceive regulatory requirements: convergence (compliance aligns with development priorities), existing practice (current work already satisfies requirements), and disconnection (requirements perceived as administrative overhead). Based on these patterns, we discuss when governance might be treated genuinely or performatively. Practitioners prioritize requirements that serve end-users or their own development needs, but view verification-oriented requirements as box-ticking exercises. This distinction suggests a translation challenge: regulatory requirements risk superficial treatment unless practitioners understand how compliance serves system quality and user protection. Expert collaboration offers a practical mechanism for transforming governance from external imposition to shared ownership and making previously invisible governance work visible and collective.
Ensuring software compliance with regulations such as the General Data Protection Regulation (GDPR) and the Artificial Intelligence Act (EU AI Act) poses a significant challenge, as requirements engineers must translate complex legal text into actionable software requirements - a process that remains largely manual and error-prone in practice. We present an automated regulation-to-requirements pipeline that identifies requirement-bearing clauses in regulatory documents and derives system-agnostic software requirements, accompanied by plain-language explanations, traceable to their legal sources. We evaluate the pipeline on the full clause sets of the GDPR (398 clauses) and the EU AI Act (574 clauses). For requirement-bearing clause identification, the approach achieves macro-averaged F1 scores of 0.82 and 0.78, respectively, outperforming a SetFit-based baseline. Human evaluation shows high completeness (4.60 and 4.45) and correctness (3.74 and 3.54) of derived requirements, while explanation clarity scores are near-ceiling (4.92 and 4.94) on a 1-5 scale. We implement the approach in Reg2Req, a publicly released tool that further supports requirement classification, use case seeding, cross-reference analysis, definition indexing, and a traceability matrix to operationalize regulatory compliance in practice. A user study with 25 practitioners shows that the plain-language explanations significantly improve comprehension of derived requirements and confidence in acting on them (p < 0.001), and that all participants would use Reg2Req as a starting point for deriving software requirements from a regulation.
When algorithms make or influence consequential decisions---about loan eligibility, hiring, or healthcare---EU law grants affected individuals a Right to Explanation. Yet whether (and how) Explainable AI (XAI) can satisfy this right in practice remains poorly understood, with direct implications for individuals' ability to contest automated decisions that affect their lives. This paper presents a systematic literature review of XAI in the context of the EU Right to Explanation, with particular focus on Art. 15(1)(h) GDPR, Art. 86 AI Act (AIA), and related instruments. We consider papers published from 2024 onwards, as the final version of the AIA was published in July 2024---with Art. 86 being added late. From 2643 initial records identified by a deliberately broad search, we review 57 full texts, of which only 19 papers demonstrate substantive integration of both legal and technical perspectives, showing gaps in the interdisciplinary synthesis of the current regulatory framework. We document three problematic patterns across the corpus: Most misidentify the GDPR legal basis; few engage with the CJEU's Dun & Bradstreet judgment (likely due to publication timing); and the distinction between explanation form (governed by addressee) and content (governed by legal purpose) is often conflated. We conceptualize this as the Addressee/Purpose Framework, propose a four-phase blueprint for operationalization, and identify six concrete open research questions. Without further progress, the Right to Explanation risks remaining a formal obligation without a technically realizable path to compliance.
Benjamin Fresz, Elena Dubovitskaya, Marco F. Huber
AI governance programmes increasingly rely on natural language prompts to constrain and direct AI agent behaviour. These prompts function as executable specifications: they define the agent's mandate, scope, and quality criteria. Despite this role, no systematic framework exists for evaluating whether a governance prompt is structurally complete. We introduce a five-principle evaluation framework grounded in computability theory, proof theory, and Bayesian epistemology, and apply it to an empirical corpus of 34 publicly available AGENTS.md governance files sourced from GitHub. Our evaluation reveals that 37% of evaluated file-model pairs score below the structural completeness threshold, with data classification and assessment rubric criteria most frequently absent. These results suggest that practitioner-authored governance prompts exhibit consistent structural patterns that automated static analysis could detect and remediate. We discuss implications for requirements engineering practice in AI-assisted development contexts, identify a previously undocumented artefact classification gap in the AGENTS.md convention, and propose directions for tool support.