Co-constructing sociotechnical AI governance: participatory system mapping using algorithm registers
Authors: Íñigo de Troya, Maurus Enbergs, Neelke Doorn, Roel Dobbe
Organizations: TU Delft
Abstract
Algorithm registers have been championed as a means of providing transparency on the use of algorithms in public services. Yet potential publics differ in their expectations of what should be made transparent and how, as well as in their interest in and ability to parse the information currently published in the registers. Moreover, it remains unclear how these instruments can represent the sociotechnical systems in which these algorithms are embedded, and how system-level transparency can facilitate accountability. In this paper, we ask, what do algorithm registers reveal (and occlude) about the sociotechnical systems governing algorithmic systems, and how can diverse stakeholder perspectives inform a more pluralistic system-theoretic safety analysis? To do this, we probe the municipal algorithm register of a Dutch city through a case study of a decision-support tool for caseworkers' assessment of citizens' welfare benefits eligibility based on legal automation through a business rule engine. Through interviews, surveys, and participatory system mapping workshops (with municipal staff, civil society organisations, and ombudsmen, N=8), we seek to understand to what extent the register allows stakeholders to map the algorithmic system in question. These maps inform a System-Theoretic Process Analysis (STPA) that situates the register within a wider sociotechnical governance structure. Participants' contributions allow us to identify potential safety hazards which would not have been possible to see using the algorithm register alone, including benefits eligibility denial, system performance deterioration, and inability to contest wrongful decisions. By engaging both direct and indirect stakeholders, we reflect on the normative dimensions of algorithm governance efforts and how politics shape the practice of system safety analysis.
In November 2025, the Government of Canada operationalized its commitment to transparency by releasing its first Federal AI Register. In this paper, we argue that such registers are not neutral mirrors of government activity, but active instruments of ontological design that configure the boundaries of accountability. We analyzed the Register's complete dataset of 409 systems using the Algorithmic Decision-Making Adapted for the Public Sector (ADMAPS) framework, combining quantitative mapping with deductive qualitative coding. Our findings reveal a sharp divergence between the rhetoric of "sovereign AI" and the reality of bureaucratic practice: while 86% of systems are deployed internally for efficiency, the Register systematically obscures the human discretion, training, and uncertainty management required to operate them. By privileging technical descriptions over sociotechnical context, the Register constructs an ontology of AI as "reliable tooling" rather than "contestable decision-making." We conclude that without a shift in design, such transparency artifacts risk automating accountability into a performative compliance exercise, offering visibility without contestability.
Dipto Das, Christelle Tessono, Syed Ishtiaque Ahmed +1
This paper examines how algorithmic accountability in Canada's visa system is articulated institutionally and experienced by applicants across borders. We analyzed Immigration, Refugees and Citizenship Canada (IRCC)'s Algorithmic Impact Assessment (AIA) for the temporary resident visa (TRV) triage system using the algorithmic decision-making adapted for the public sector (ADMAPS) framework and analyzed Reddit discussions among applicants using a mixed-methods approach. We show that while institutional artifacts emphasize transparency, procedural safeguards, and bounded impacts, applicants engage in collective sensemaking to interpret opaque decisions, often relying on peer knowledge amid uncertainty. We identify three asymmetries between how institutional accountability is structured and how people perceive the process: epistemic asymmetry in access to decision logic, jurisdictional asymmetry in exposure shaped by geopolitical positioning, and temporal--relational asymmetry in how waiting and uncertainty are experienced. We emphasize why it is important to shift attention from institutional design to the uneven distribution of experiences with public-sector algorithmic governance. Together, these contributions demonstrate how algorithmic governance systems in the context of transnational migration produce structured asymmetries not captured by institutional disclosure frameworks, and how extending ADMAPS can account for those uneven translations of accountability.
Dipto Das, Matthew Tamura, Syed Ishtiaque Ahmed +1
Transparency is increasingly mandated for public-sector AI systems, with organisations required to publish statements describing their AI use and oversight arrangements. However, the existence of such artefacts is often treated as equivalent to transparency itself, despite limited evidence that they proportionately serve relevant stakeholder groups. From a requirements engineering perspective, this raises a validation concern: compliance with mandated disclosure criteria does not necessarily ensure transparency adequacy for stakeholders with different levels of risk exposure, decision control, and involvement. This paper presents an empirical analysis of 92 publicly available AI transparency statements published by Australian Government agencies under the national AI governance mandate. We introduce the stakeholder Risk--Control--Involvement--Need (RCIN) framework to differentiate stakeholder classes according to their structural position and transparency needs. Using a structured rubric derived from the mandated criteria, we evaluate how both the mandate and published statements are calibrated to each stakeholder class. The findings show that while structural compliance is widespread, transparency calibration is uneven. Criteria serving high-control stakeholders are consistently realised, whereas criteria most critical for high-risk, low-control stakeholders are fewer and less substantively addressed. We conceptualise this as the Transparency Illusion: a condition in which transparency appears satisfied through compliant artefacts yet remains unevenly calibrated to stakeholders bearing the greatest exposure to AI-supported decisions. The study frames transparency as a stakeholder-calibrated validation problem, demonstrating that artefact-level compliance does not constitute requirements validation in this context.