Scaling, Lock-In, and Proxy Compliance: A Political Economy of Responsible AI

Post-deployment accountability has become central to AI governance, yet little empirical evidence shows whether monitoring, incident reporting, and impact assessment obligations are visible when AI systems fail. This study analyzes real-world AI incidents from the AI Incident Database (2020--2026) and codes them against nine post-deployment provisions from the EU AI Act, the NIST AI Risk Management Framework, and the GDPR. The findings show substantial accountability gaps: 77.1% of incidents lack evidence of EU AI Act post-market monitoring, and 99.6% lack documented Data-Protection Impact Assessment evidence. Governance gaps are also systemic, with 9.8% of incidents simultaneously non-compliant under two or more regimes. Incidents detected through internal monitoring show much higher compliance than externally detected incidents (87.5% vs 5.3% under the EU AI Act; 95.8% vs 58.1% under NIST), suggesting that monitoring capacity is a key condition for effective post-deployment governance. Building on these findings, the paper proposes the Proactive AI Governance Compliance Framework (PAGCF), a four-phase lifecycle for pre-deployment assessment, continuous monitoring, incident preparedness, and cross-framework verification.

AI deployment in sensitive domains such as health care, credit, employment, and criminal justice is often treated as unsafe to authorize until model internals can be explained. This often leads to an excessive reliance on mechanistic interpretability to address a deployment challenge beyond its intended scope. We argue that the gate should instead be calibrated verification: authorization should be domain-scoped, independently checkable, monitored after release, accountable, contestable, and revocable. The reason is twofold. First, model capability is uneven across nearby tasks, so authorization must attach to a specific use rather than to a model in general. Second, societies have long governed opaque expertise through credentials, monitoring, liability, appeal, and revocation rather than mechanism-level explanation. Recent evidence reinforces this distinction between mechanistic understanding and deployment authority: a 53-percentage-point gap between internal representations and output correction shows that understanding may not translate into action, while one scoping review found that only 9.0% of FDA-approved AI/ML device documents contained a prospective post-market surveillance study. We propose Verification Coverage, a six-component reportable standard with a minimum-composition rule, as the metric that should sit beside capability scores in model cards, leaderboards, and regulatory disclosures.

LLM agents call tools, query databases, delegate tasks, and trigger external side effects. Once an agent system can act in the world, the question is no longer only whether harmful actions can be prevented--it is whether those actions remain answerable after deployment. We distinguish accountability (the ability to determine compliance and assign responsibility), auditability (the system property that makes accountability possible), and auditing (the process of reconstructing behavior from trustworthy evidence). Our claim is direct: no agent system can be accountable without auditability. To make this operational, we define five dimensions of agent auditability, i.e., action recoverability, lifecycle coverage, policy checkability, responsibility attribution, and evidence integrity, and identify three mechanism classes (detect, enforce, recover) whose temporal information-and-intervention constraints explain why, in practice, no single approach suffices. We support the position with layered evidence rather than a single benchmark: lower-bound ecosystem measurements suggest that even basic security prerequisites for auditability are widely unmet (617 security findings across six prominent open-source projects); runtime feasibility results show that pre-execution mediation with tamper-evident records adds only 8.3 ms median overhead; and controlled recovery experiments show that responsibility-relevant information can be partially recovered even when conventional logs are missing. We propose an Auditability Card for agent systems and identify six open research problems organized by mechanism class.