Update Opacity: Epistemic Accessibility and Governance Under AI System Change
Machine learning models embedded in deployed AI systems are routinely updated to maintain correct functioning over time. Yet such updates can generate update opacity: users may not be able to understand why the same input now yields a different output. We argue that update opacity is best understood as a diachronic failure of epistemic accessibility: the problem is that materially relevant changes may fail to remain accessible to human users in forms that support understanding, calibrated reliance, and appropriate action under real role- and time-specific constraints. This makes update opacity a governance problem. Not all change is equally relevant, and disclosing every update would itself undermine use through overload. To address this problem, we combine two complementary governance approaches: the EU AI Act, which helps specify the system-level perimeter of normatively relevant change, and Machine Learning Operations, which provides operational tools for tracking and comparing change over time. On this basis, we propose a framework that models system change through trustworthiness profiles and trustworthiness levels, and uses threshold-based disclosure to surface materially relevant within-envelope change to different stakeholders over time. We illustrate the approach with a medical AI example and derive practical implications for lifecycle documentation, post-market monitoring, and update disclosure.