Transparent Information Flow Modeling for Role-Aware AI Act Assessment

Transparency in AI-supported decision systems is widely required but poorly defined. Existing approaches treat transparency as a property of systems or components, producing characteristic failures: assessments that do not transfer across organizational boundaries, stakeholder questions that cannot be formulated within the available frame of analysis, and component-level findings that say nothing about system-level behavior. We propose treating transparency as a relation: a system is transparent to a stakeholder to the degree that their legitimate questions are answerable from its structure. We formalize this using information flow networks, in which transparency questions are expressed in terms of network structure and answerability is the condition that the system settles them. The framework supports three dimensions of analysis: structural answerability from the network alone, compositional answerability across organizational boundaries for deployed systems, and role-dependent answerability given a stakeholder's accessible sub-network. We demonstrate the framework on a real pre-integration assessment of an AI recruitment tool in a public sector municipality. The assessment uses participatory design and interviews to model the decision system structure. We show how structural and role-dependent transparency questions can be formally stated and analyzed across the Provider and Deployer boundary where the AI system is composed together with the deployer's decision process.

The EU AI Act (Regulation 2024/1689) imposes technical obligations on high-risk AI providers, yet Articles 8-15 were drafted for predictive AI and leave seven technical gaps when applied to generative systems, spanning non-deterministic data governance, training-data provenance, continuous conformity, human oversight, open-ended robustness, emergent risk, and generative fairness. We deliver Governance-as-Code (GaC), a framework of 43 machine-checkable acceptance criteria across six compliance modules that run in a CI/CD pipeline and emit Article-indexed audit evidence, and we show the actual Rego policy code rather than merely describing it. Our central commitment is that the Act's open-textured standards ("appropriate levels," "possible biases") become declared, auditable numbers: robustness thresholds are derived from the provider's documented baseline and a state-of-the-art floor, and framing bias is collapsed into eight measurable proxies tested by counterfactual demographic probing. We also correct who owes what, since under Article 25 and Chapter V a downstream deployer relies on the upstream provider's Article 53 training-data summary and documents only the layers it controls, so GaC verifies that summary rather than demanding per-sample documentation the deployer never had. We validate on two enterprise deployments, a high-risk advisory chatbot and a limited-risk content generator, benchmarking against a manual expert audit rather than documentation artifacts that were never designed to enforce compliance. GaC reproduces all of the manual audit's findings, including three penalty-triggering violations, while cutting audit labor by roughly 75%.

The systematic assessment of AI systems is increasingly vital as these technologies enter high-stakes domains. To address this, the EU's Artificial Intelligence Act introduces AI Regulatory Sandboxes (AIRS): supervised environments where AI systems can be tested under the oversight of Competent Authorities (CAs), balancing innovation with compliance, particularly for startups and SMEs. Yet significant challenges remain: assessment methods are fragmented, tests lack standardisation, and feedback loops between developers and regulators are weak. This paper operationalises the AIRS lifecycle. We map the sandbox journey into 29 concrete activities, from pre-participation guidance through application, preparation, participation, exit, and post-participation monitoring, and we distinguish between a Core AIRS centred on regulatory oversight and an Extended AIRS that additionally embeds structured technical testing through an AI Technical Sandbox (AITS). From this mapping we derive 15 infrastructural and governance requirements that an AITS must satisfy, each linked to the activities it supports and, for high-risk systems, to the provider obligations set out in Articles 9-15 of the AI Act. The framework aims to address multiple stakeholders: CAs gain structured workflows for applying legal obligations; technical experts can integrate robust evaluation methods; and AI providers access a transparent pathway to compliance. We conclude by outlining the Sandbox Configurator, an open-source framework intended to instantiate AITS environments from these requirements, and by discussing how a shared technical foundation can support a scalable and innovation-friendly European infrastructure for trustworthy AI governance.