Transparency as Answerability: Role-Dependent Information Flow Modeling

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.

The European Union's Artificial Intelligence Act introduces a structured framework for governing high-risk AI systems, emphasizing transparency, risk management, and role-specific accountability. However, current assessment practices often rely on monolithic system views or disconnected checklists, limiting their ability to capture the socio-technical complexity of real-world deployments. We explore the use of the Information Flow Methodology (IFM), a modeling-based approach to AI Act compliance assessment. IFM represents decision systems -- whether algorithmic, human, or hybrid -- as networks of information sites and transformation channels, enabling structured analysis of how information, decisions, and responsibilities flow across organizational and technical boundaries. We apply IFM in a real-world case involving a recruitment support tool used by a public-sector organization, evaluating both the Provider's system and the Deployer's recruitment process. Our results demonstrate that IFM can serve as a scaffold to bridge both component-based and holistic perspectives, and how technical systems are situated within socio-technical contexts. In doing so, IFM supports transparency, identifies risk pathways, and enables alignment analysis between intended and actual use. We argue that such modeling provides a foundational tool for effective, context-sensitive AI governance and accountability -- offering capabilities beyond conventional checklist-based assessments.

Multi-agent large language model (LLM) systems are rapidly emerging, yet transparency, a cornerstone of responsible AI, remains under-defined in these distributed architectures, which have complexities of inter-agent coordination and orchestration. In this paper, we present one of the first empirical study of how early adopters of multi-agent LLM systems, who are both the builders and users, understand and practice transparency. We conducted semi-structured interviews with 13 early adopters in [Large Technology Organization] and applied thematic analysis to identify recurring patterns. Participants articulated divergent yet complementary framings of transparency, including reproducibility, debugging, boundary-setting, visualization, and auditing. These perspectives spanned questions of what transparency entails, why it matters, and how it is achieved. We synthesize these into a multidimensional framework, which is developer, user, and governance-focused positioning transparency as a situated socio-technical practice that informs future HCI and AI design and research around aligning expectations and capacities of their intended audiences.