Sequential Fairness Auditing with Limited Output Access
Authors: Ioannis Pitsiorlas, Martha V. Sourla, Marios Kountouris
Organizations: EURECOM, France · DaSCI, University of Granada, Spain
Abstract
External evaluations are becoming increasingly central to the governance of AI systems. In practice, however, independent auditors often have limited access to deployed models and must rely on query-based interactions. Most existing fairness evaluation methods assume static datasets and fixed-sample statistical tests, making them poorly suited to real-world auditing scenarios in which evidence must be collected sequentially under query constraints. In this work, we formulate fairness auditing as a tolerance-aware sequential hypothesis-testing problem under limited model output access. We develop a sequential generalized likelihood-ratio framework that allows auditors to accumulate evidence from a finite audit pool and stop once sufficient support for compliance or violation has been obtained. The framework is instantiated for decision-based Statistical Parity and Equal Opportunity audits, and extended to score- and logit-based proxy audits when richer observables are available. Our results show that both the fairness metric and the level of model access significantly affect audit efficiency, and that the benefits of richer output information are not uniform across auditing settings. In particular, richer outputs can substantially reduce the number of queries required for some fairness metrics and operating regimes, while offering limited gains in near-threshold cases. This work provides a practical statistical framework for sequential fairness auditing under realistic deployment constraints.
Fairness audits are increasingly mandated in high-stakes applications such as hiring, lending, and automated decision-making. Recent work has established fundamental impossibility results for black-box fairness auditing, showing that sufficiently expressive models can evade any auditing strategy. We complement these results by quantifying the extent of unavoidable post-audit manipulation under finite audit resources. We formulate fairness auditing as a min-max optimization between a computationally unbounded company and a budget-constrained auditor. We study two auditing regimes: (i) a budgeted auditor that certifies fairness using a fixed-size audit set, and (ii) a budgeted α-tolerant auditor that additionally requires the audit set to estimate the fairness of the certified model within an α approximation. For both settings, we derive explicit lower bounds on the worst-case post-audit demographic parity deviation as functions of the audit budget, group imbalance, and fairness tolerance. Finally, we empirically illustrate these theoretical limits using simple audit-set construction heuristics with linear and neural network classifiers. Our results demonstrate that increasing audit resources reduces, but does not eliminate, the scope for post-audit manipulation, highlighting fundamental limitations of finite-budget fairness certification.
Large Language Models (LLMs) exhibit systematic biases across demographic groups. Auditing is proposed as an accountability tool for black-box LLM applications, but suffers from resource-intensive query access. We conceptualise auditing as uncertainty estimation over a target fairness metric and introduce BAFA, the Bounded Active Fairness Auditor for query-efficient auditing of black-box LLMs. BAFA maintains a version space of surrogate models consistent with queried scores and computes uncertainty intervals for fairness metrics (e.g., Δ AUC) via constrained empirical risk minimisation. Active query selection narrows these intervals to reduce estimation error. We evaluate BAFA on two standard fairness dataset case studies: \textsc{CivilComments} and \textsc{Bias-in-Bios}, comparing against stratified sampling, power sampling, and ablations. BAFA achieves target error thresholds with up to 40× fewer queries than stratified sampling (e.g., 144 vs 5,956 queries at ε=0.02 for \textsc{CivilComments}) for tight thresholds, demonstrates substantially better performance over time, and shows lower variance across runs. These results suggest that active sampling can reduce resources needed for independent fairness auditing with LLMs, supporting continuous model evaluations.
Fairness audits are a key component of responsible machine-learning deployment. Yet, audit-recommendation reliability under incomplete protected-label access is still poorly understood. In this work, we focused on protected-label missingness in fairness mitigation audits. We introduced a seed-calibrated stress test to separate missingness effects from seed-to-seed movement already present under complete labels. Across ACS/Folktables tasks, missingness settings that retain some protected labels usually do not move selected mitigation methods beyond a complete-label seed-to-seed baseline. At 0 protected-label access, candidates collapse to an empirical-risk-minimization baseline and deterministic tie-breaking rather than revealing a broad missingness effect. We also found that threshold optimization can turn fairness gains on a single protected axis into intersectional harm above a seed baseline, and this threshold-optimizer finding persists under random-forest validation. Overall, our results highlight that protected-label missingness should be reported with seed-null calibration, candidate-set context, and intersectional consequences before it is treated as evidence of audit fragility.