Artificial Intelligence Governance

Frontier AI governance often centres on the model-level governance paradigm, which assumes that a model's capability profile is primarily a function of the compute and data used during training. This position paper argues that model-level governance becomes less effective when capability progress is increasingly driven by "non-model gains"--improvements that are independent from advances in the base model. We formalise the concept of non-model gains and provide a taxonomy of three distinct vectors of capability gain: inference gain (scaling compute at test-time), systems gain (post-training enhancements such as scaffolds), and asset gain (enhancing a model with restricted assets). We demonstrate how these vectors--alongside potential future impacts from embodiment, continual learning, and AI diffusion--may undermine risk management strategies that hinge mostly on pre-deployment evaluation and mitigation. We provide an overview of governance approaches that go beyond the model level: system, entity, agent, and cloud governance. Finally, we emphasise the importance of societal resilience as a complement to these governance layers.

Responsible AI research typically focuses on examining the use and impacts of deployed AI systems. Yet, there is currently limited visibility into the pre-deployment decisions to pursue building such systems in the first place. Decisions taken in the earlier stages of development shape which systems are ultimately released, and therefore represent potential, but underexplored, points for intervention. As such, this paper investigates factors influencing AI non-development and abandonment throughout the development lifecycle. Specifically, we first perform a scoping review of academic literature, civil society resources, and grey literature including journalism and industry reports. Through thematic analysis of these sources, we develop a taxonomy of six categories of factors contributing to AI abandonment: ethical concerns, stakeholder feedback, development lifecycle challenges, organizational dynamics, resource constraints, and legal/regulatory concerns. Then, we collect data on real-world case of AI system abandonment via an AI incident database and a practitioner survey to evidence and compare factors that drive abandonment both prior to and following system deployment. While academic responsible AI communities often emphasize ethical risks as reasons to not develop AI, our empirical analysis of these cases demonstrates the diverse, and often non-ethics-related, levers that motivate organizations to abandon AI development. Synthesizing evidence from our taxonomy and related case study analyses, we identify gaps and opportunities in current responsible AI research to (1) engage with the diverse range of levers that influence organizations to abandon AI development, and (2) better support appropriate (dis)engagement with AI system development.

The risks posed by AI features are increasing as they are rapidly integrated into software applications. In response, regulations and standards for safe and secure AI have been proposed. In this paper, we present an agentic framework that constructs knowledge graphs (KGs) from AI policy documents and retrieves policy-relevant information to answer questions. We build KGs from three AI risk-related polices under two ontology schemas, and then evaluate five LLMs on 42 policy QA tasks spanning six reasoning types, from entity lookup to cross-policy inference, using both heuristic scoring and an LLM-as-judge. KG augmentation improves scores for all five models, and an open, LLM-discovered schema matches or exceeds the formal ontology.

Every system that performs effects has two boundaries: what it can do (expressiveness) and what governance covers (governance). In nearly all deployed AI systems, these boundaries are defined independently, creating three regions: governed capabilities (the only useful region), ungoverned capabilities (risk), and governance policies that address non-existent capabilities (theater). Two of the three regions are failure modes. We focus on the governance of effects: actions that AI systems perform in the world (API calls, database writes, tool invocations). This is distinct from the governance of model outputs (content quality, bias, fairness), which operates at a different level and requires different mechanisms. We present a formal framework for analyzing this structural gap. Rice's theorem (1953) proves the gap is undecidable in the general case for any Turing-complete architecture that attempts to govern effects behaviorally: no algorithm can decide non-trivial semantic properties of arbitrary programs, including the property "this program's effects comply with the governance policy." We define coterminous governance: a system property where the expressivenessboundary equals the governance boundary. We show that coterminous governance requires an architectural decision (separatingcomputation from effect) rather than a governance layer added after the fact. We show that structural governance under this separation subsumes separate governance infrastructure: governance checks become part of the execution pipeline rather than a second system running alongside it. We propose coterminous governance as the testable criterion for any AI governance system: either the two boundaries are provably identical, or risk and theater are structurally inevitable. Proofs are mechanized in Coq (454 theorems, 36 modules, 0 admitted).

The integration of artificial intelligence into clinical medicine creates a fundamental tension between algorithmic probabilistic reasoning and the experiential intuition of expert physicians; applying Lawrence Lessig's \enquote{Code is Law} framework, I argue that the architecture of clinical AI systems already functions as de facto medical regulation, reshaping liability and the standard of care. Reframing AI \enquote{hallucination} as structurally analogous to well-documented human cognitive failures such as confirmation bias and premature diagnostic closure, I show that both failure modes demand a unified governance response. I therefore propose a dialectical standard of care that treats the integrated AI-physician dyad as the singular responsible diagnostic entity, mandating the synthesis of algorithmic precision with human interpretive authority within robust data governance and patient privacy frameworks.

Navigating AI regulation across jurisdictions is increasingly difficult for policymakers, legal professionals, and researchers. To address this, we present a multi-jurisdictional Retrieval-Augmented Generation system for global AI regulation. Our corpus includes 242 documents across 68 jurisdictions, ranging from formal legislation like the EU AI Act to unstructured policy documents such as national AI strategies. The system makes three technical contributions: type-specific chunking that preserve legal structure across heterogenous documents; conditional retrieval routing with entity detection and metadata for legal citations; and priority-based re-ranking to boost enacted legislation over policy and secondary sources. Evaluation of 50 queries reveals strong performance across both single-entity and multi-jurisdictional questions, achieving 0.87 average faithfulness and 0.84 average answer relevancy. Single-entity queries achieve 0.86 average faithfulness and 0.92 average answer relevancy, while multi-jurisdictional comparison queries achieve 0.88 average faithfulness and 0.75 average answer relevancy. These findings highlight the effectiveness of domain-specific retrieval strategies for navigating complex, heterogenous regulatory corpora.

Frontier AI companies first deploy their most advanced models internally, for weeks or months of safety testing, evaluation, and iteration, before a possible public release. For example, Anthropic recently developed a new class of model with advanced cyberoffense-relevant capabilities, Mythos Preview, which was available internally for at least six weeks before it was publicly announced. This internal use creates risks that external deployment frameworks may fail to address. Legal frameworks, notably California's Transparency in Frontier Artificial Intelligence Act (SB 53), New York's Responsible AI Safety And Education (RAISE) Act, and the EU's General-Purpose AI Code of Practice, all discuss risks from internal AI use. They require frontier developers to make and implement plans for how to manage risks from internal use, and to produce internal use risk reports describing their safeguards and any residual risks. This guide provides a harmonized standard for companies to produce internal use risk reports suitable for all three regulatory frameworks. It is addressed primarily to evaluation and safety teams at frontier AI developers, and secondarily to regulators and auditors seeking to understand what good reporting looks like. Given the pace of AI R&D automation and the limited external visibility into how companies use their most capable models internally, regular and detailed risk reporting may be one of the few mechanisms available to ensure that the risks from internal AI use are identified and managed before they materialize. Whenever a substantially more capable or riskier model is deployed internally, the developer should create a risk report and argue why the model is safe to deploy. We structure the reporting framework around two threat vectors -- autonomous AI misbehavior and insider threats -- and three risk factors for each: means, motive, and opportunity.

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.

Domestic voice assistants and smart-home devices are increasingly embedded in everyday routines, yet their ethics are often treated as an afterthought or delegated to compliance teams. To explore how expectations about smart-home AI are constructed and managed, we conducted 33 semi-structured interviews with designers, developers, and researchers from major smart-home platforms (Amazon Alexa, Microsoft Azure IoT, and Google Nest). Using a constructivist grounded theory approach, we develop Expectations Management (EM): a culturally embedded model describing how practitioners shape, calibrate, and repair expectations by balancing organisational rights with culturally situated rites. We show that EM differs from expectation-confirmation theory and trust-calibration by foregrounding moral judgement, situated action, and cross-cultural variation. Our analysis reveals four recurring design tensions: automation vs. autonomy, helpfulness vs. intrusiveness, personalisation vs. predictability, and transparency vs. obscurity and distils them into a five-phase EM Design Playbook that supports moral prudence. We discuss implications for responsible smart-home design and offer guidance for human-centred AI.

AI agents are now running real transactions, workflows, and sub-agent chains across organizational boundaries without continuous human supervision. This creates a problem no current infrastructure is equipped to solve: how do you identify, verify, and hold accountable an entity with no body, no persistent memory, and no legal standing? We define AI Identity as the continuous relationship between what an AI agent is declared to be and what it is observed to do, bounded by the confidence that those two things correspond at any given moment. Through a structured survey of industry trends, emerging standards, and technical literature, we conduct a gap analysis across the full agent identity lifecycle and make three contributions: (1) a structural comparison of human and AI identity across four dimensions (substrate, persistence, verifiability, and legal standing) showing that the asymmetry is fundamental and that extending human frameworks to agents without structural modification produces systematic failures; (2) an evaluation of current technical and regulatory documents against the identity requirements of autonomous agents, finding that none adequately address the challenge of governing nondeterministic, boundary-crossing entities; and (3) identification of five critical gaps (semantic intent verification, recursive delegation accountability, agent identity integrity, governance opacity and enforcement, and operational sustainability) that no current technology or regulatory instrument resolves. These gaps are structural; more engineering effort alone will not close them. Foundational research on AI identity is the central conclusion of this report.

The proliferation of agentic artificial intelligence has outpaced the conceptual tools needed to characterize agency in computational systems. Prevailing definitions mainly rely on autonomy and goal-directedness. Here, we argue for a minimal notion open to principled inspection given three criteria: intentionality as action grounded in beliefs and desires, rationality as normatively coherent action entailed by a world model, and explainability as action causally traceable to internal states; we subsequently instantiate these as a partially observable Markov decision process under a variational framework wherein posterior beliefs, prior preferences, and the minimization of expected free energy jointly constitute an agentic action chain. Using a canonical T-maze paradigm, we evidence how empowerment, formulated as the channel capacity between actions and anticipated observations, serves as an operational metric that distinguishes zero-, intermediate-, and high-agency phenotypes through structural manipulations of the generative model. We conclude by arguing that as agents engage in epistemic foraging to resolve ambiguity, the governance controls that remain effective must shift systematically from external constraints to the internal modulation of prior preferences, offering a principled, variational bridge from computational phenotyping to AI governance strategy

Each major technological revolution inverts a particular scarcity and rebuilds institutions around the shift. The near-consensus diagnosis of the AI revolution holds that AI collapses the cost of prediction while judgment remains scarce. This Opinion argues the inversion has now flipped: competent-looking judgment (selecting, ranking, attributing, certifying) is produced at scale and at marginal cost approaching zero, and four complements become scarce: verified signal, legitimacy, authentic provenance, and integration capacity (the community's tolerance for delegated cognition). Because judgment is the substance of institutions, the institutions built to manufacture legitimate judgment (courts, journals, licensing bodies, legislatures) now compete with the technology for the same functional role. The piece traces the pattern across scientific institutions, professional licensing, intellectual property, democratic legitimacy, and foundation-model concentration, and closes with a three-move agenda: reframe AI policy as institutional redesign, build provenance and verification as commons, and develop the formal apparatus for institutional composition under strategic agents.

Classical robot ethics is often framed around obedience, including Asimov's laws. This framing is insufficient for contemporary AI systems, which are increasingly adaptive, generative, embodied, and embedded in physical, psychological, and social environments. This paper proposes conditional mutualism under governance as a framework for human-AI coexistence: a co-evolutionary relationship in which humans and AI systems develop, specialize, and coordinate under institutional conditions that preserve reciprocity, reversibility, psychological safety, and social legitimacy. We synthesize concepts from computability, machine learning, foundation models, embodied AI, alignment, human-robot interaction, ecological mutualism, coevolution, and polycentric governance. We then formalize coexistence as a multiplex dynamical system across physical, psychological, and social layers, with reciprocal supply-demand coupling, conflict penalties, developmental freedom, and governance regularization. The model gives conditions for existence, uniqueness, and global asymptotic stability of equilibria. We complement the analytical results with deterministic ODE simulations, basin sweeps, sensitivity analyses, governance-regime comparisons, shock tests, and local stability checks. The simulations indicate that governed mutualism reaches a high coexistence index with negligible domination, whereas insufficient or excessive governance can produce domination, weak-benefit lock-in, or suppressed developmental freedom. The results suggest that human-AI coexistence should be designed as a co-evolutionary governance problem rather than as a static obedience problem.

The rapid uptake of generative artificial intelligence (AI) in higher education is reshaping assessment practices and intensifying concerns around academic integrity, fairness, and learning quality. While institutional responses increasingly emphasise policy guidance and ethical principles, there remains limited formal understanding of how collective norms of responsible or opportunistic AI use emerge and stabilise within student cohorts. This paper reframes student AI use in assessment as a coordination problem shaped by peer expectations and assessment design rather than individual compliance alone. We develop a coordination-based evolutionary game-theoretic framework that captures learning value, effort, perceived fairness, and transparency, with institutional AI governance modelled implicitly through reflective assessment incentives. We use analytical results and finite-population simulations to reveal threshold-driven behavioural transitions in student AI use: small, well-calibrated changes in reflective assessment incentives can trigger rapid shifts towards responsible, learning-oriented AI-use norms, whereas weak or misaligned incentives allow opportunistic practices to persist. These non-linear dynamics explain why policy statements alone often fail to change behaviour, while modest assessment redesigns can have disproportionate effects. By providing a mechanism-level account of how assessment structures shape collective AI-use practices, this work offers higher education institutions an analytically grounded tool for Future Facing Learning, supporting proportionate, pedagogy-led AI governance without reliance on surveillance or punitive enforcement.

Under the EU AI Act, translating AI governance requirements into software development practice remains challenging. While AI governance frameworks exist at industry and organizational levels, empirical evidence of team-level implementation is scarce. We address this "Last Mile" Challenge through insider action research embedded within an AI startup. We present a legal-text-to-action pipeline that translates EU AI Act requirements into actionable strategies through internal expert collaboration by extracting requirements from legal text, engaging practitioners in assessment and ideation, and prioritizing implementation through collective evaluation. Our analysis reveals three patterns in how practitioners perceive regulatory requirements: convergence (compliance aligns with development priorities), existing practice (current work already satisfies requirements), and disconnection (requirements perceived as administrative overhead). Based on these patterns, we discuss when governance might be treated genuinely or performatively. Practitioners prioritize requirements that serve end-users or their own development needs, but view verification-oriented requirements as box-ticking exercises. This distinction suggests a translation challenge: regulatory requirements risk superficial treatment unless practitioners understand how compliance serves system quality and user protection. Expert collaboration offers a practical mechanism for transforming governance from external imposition to shared ownership and making previously invisible governance work visible and collective.

Governments are increasingly interested in using AI to make administrative decisions cheaper, more scalable, and more consistent. But for probabilistic AI to be incorporated into public administration it must be embedded in a compliance layer that makes decisions reviewable, repeatable, and legally defensible. That layer can improve oversight by making departures from law easier to detect. But it can also create a stable approval boundary that political successors learn to navigate while preserving the appearance of lawful administration. We develop a formal model in which institutions choose the scale of automation, the degree of codification, and safeguards on iterative use. The model shows when these systems become vulnerable to strategic use from within government, why reforms that initially improve oversight can later increase that vulnerability, and why expansions in AI use may be difficult to unwind. Making AI usable can thus make procedures easier for future governments to learn and exploit.

AI governance programmes increasingly rely on natural language prompts to constrain and direct AI agent behaviour. These prompts function as executable specifications: they define the agent's mandate, scope, and quality criteria. Despite this role, no systematic framework exists for evaluating whether a governance prompt is structurally complete. We introduce a five-principle evaluation framework grounded in computability theory, proof theory, and Bayesian epistemology, and apply it to an empirical corpus of 34 publicly available AGENTS.md governance files sourced from GitHub. Our evaluation reveals that 37% of evaluated file-model pairs score below the structural completeness threshold, with data classification and assessment rubric criteria most frequently absent. These results suggest that practitioner-authored governance prompts exhibit consistent structural patterns that automated static analysis could detect and remediate. We discuss implications for requirements engineering practice in AI-assisted development contexts, identify a previously undocumented artefact classification gap in the AGENTS.md convention, and propose directions for tool support.

Content moderation systems are typically evaluated by measuring agreement with human labels. In rule-governed environments this assumption fails: multiple decisions may be logically consistent with the governing policy, and agreement metrics penalize valid decisions while mischaracterizing ambiguity as error -- a failure mode we term the Agreement Trap. We formalize evaluation as policy-grounded correctness and introduce the Defensibility Index (DI) and Ambiguity Index (AI). To estimate reasoning stability without additional audit passes, we introduce the Probabilistic Defensibility Signal (PDS), derived from audit-model token logprobs. We harness LLM reasoning traces as a governance signal rather than a classification output by deploying the audit model not to decide whether content violates policy, but to verify whether a proposed decision is logically derivable from the governing rule hierarchy. We validate the framework on 193,000+ Reddit moderation decisions across multiple communities and evaluation cohorts, finding a 33-46.6 percentage-point gap between agreement-based and policy-grounded metrics, with 79.8-80.6% of the model's false negatives corresponding to policy-grounded decisions rather than true errors. We further show that measured ambiguity is driven by rule specificity: auditing 37,286 identical decisions under three tiers of the same community rules reduces AI by 10.8 pp while DI remains stable. Repeated-sampling analysis attributes PDS variance primarily to governance ambiguity rather than decoding noise. A Governance Gate built on these signals achieves 78.6% automation coverage with 64.9% risk reduction. Together, these results show that evaluation in rule-governed environments should shift from agreement with historical labels to reasoning-grounded validity under explicit rules.

Artificial intelligence is increasingly deployed to synthesize large-scale public input in policy consultations and participatory processes. Yet no formal framework exists for auditing whether these summaries faithfully represent the source population, an accountability gap that existing approaches to AI explainability, grounding and hallucination detection do not address because they focus on output quality rather than input fidelity. Here, participatory provenance is introduced: a measurement framework grounded in optimal transport theory, causal inference and semantic analysis that tracks how individual public submissions are transformed, filtered or lost through AI-mediated summarization. Applied to Canada's 2025-2026 national AI Strategy consultation ($n = 5{,}253$ respondents across two independent policy topics), the framework reveals that both official government summaries underperform a random-participant baseline ($-9.1\%$ and $-8.0\%$ coverage degradation), with $16.9\%$ and $15.3\%$ of participants effectively excluded. Exclusion concentrates in clusters expressing dissent, scepticism and critique of AI ($33$-$88\%$ exclusion rates). Brevity, semantic isolation and rhetorical register independently predict representational outcome. An accompanying open-source interactive tool, the Co-creation Provenance Lab, enables policymakers to audit and iteratively improve summaries, establishing genuine human-in-the-loop oversight at scale.

As the rapid proliferation of AI systems and harms spurs efforts in AI governance around the world, prioritizing among competing policy options has become increasingly challenging for policymakers and researchers. We introduce a methodology for identifying viable policy options to mitigate specified AI harms, helping policymakers and researchers target areas that warrant greater time and resource investment. This method combines participatory evaluation of policies, expert assessment of implementation costs, and an LLM-based assessment of perceived harm mitigation under each policy option. We leverage a genetic algorithm-based simulation study to explore a vast solution space of potential policy combinations, and examine how outcomes change under different weightings of cost, participatory input, and harm mitigation. We find that this method enables exploration of different balances between participatory and expert components, allowing policymakers and researchers to assess how much weight to assign to each. We argue that the diversity of viable policy combinations found by the genetic algorithm could be a useful starting point for deliberation. This method operationalizes existing work on participatory AI by integrating it directly into practical policy development pipelines.

As generative AI faces intensifying legal challenges, the machine learning community has increasingly relied on post-hoc mitigation -- especially machine unlearning and inference-time guardrails -- to argue for compliance. This paper argues that such post-hoc mitigation methods cannot retroactively cure liability from unlawful acquisition and training, because compliance hinges on data lineage, not the outputs. Our argument has three parts. First, unauthorized copying/ingestion can be a legally complete completed act, and model weights may operate as fixed copies that retain training-derived expressive value, making later filtering beside the point for infringement. Second, contract and tort/unfair-competition rules -- via licenses, terms of service, and anti-free-riding principles -- can independently restrict access and use, often bypassing copyright defenses (e.g., fair use or TDM exceptions). Third, since value from protected inputs can persist in weights, remedies such as unjust enrichment and disgorgement may require stripping gains and, in some cases, reaching the model itself. We therefore argue for a shift from Post-Hoc Sanitization to verifiable Ex-Ante Process Compliance.

The governance of open-weight artificial intelligence (AI) models has been framed as a binary choice: openness as risk, restriction as safety. This paper challenges that framing, arguing that access restrictions, without governed alternatives, may displace risks rather than reduce them. The global concentration of compute infrastructure makes open-weight models one of the most viable pathways to sovereign AI capacity in the Global South; restricting such access deepens asymmetries while driving proliferation into unsupervised settings. This analysis proposes that hardware-layer governance, including chip-level attestation mechanisms such as FlexHEG, trusted execution environments, confidential computing, and complementary software-layer safeguards, offers a defense-in-depth alternative to the current binary. A threat model taxonomy mapping misuse vectors to hardware, software, institutional, and liability layers illustrates why no single governance mechanism suffices. To operationalize this approach, the paper argues that effective AI governance as a dual-use technology will likely require a multilateral institutional architecture functionally analogous, though not identical, to the role performed by the IAEA in the nuclear domain, with explicit safeguards against the co-option of hardware controls for domestic repression. The relevant policy question is how to make openness safer through technical and institutional design while addressing the transition realities of legacy hardware, attestation at scale, and civil liberties protection.

Agentic AI systems plan, use tools, maintain state, and act across multi-step workflows with external effects, meaning trustworthy deployment can no longer be judged by task completion alone. The current literature remains fragmented across benchmark-centered evaluation, standards-based governance, orchestration architectures, and runtime assurance mechanisms. This paper contributes a bounded evidence synthesis across a manually coded corpus of twenty-four recent sources. The core finding is a governance-to-action closure gap: evaluation tells us whether outcomes were good, governance defines what should be allowed, but neither identifies where obligations bind to concrete actions or how compliance can later be proven. To close that gap, the paper introduces three linked artifacts: (1) a four-layer framework spanning evaluation, governance, orchestration, and assurance; (2) an ODTA runtime-placement test based on observability, decidability, timeliness, and attestability; and (3) a minimum action-evidence bundle for state-changing actions. Across sources, evaluation papers identify safety, robustness, and trajectory-level measurement as open gaps; governance frameworks define obligations but omit execution-time control logic; orchestration research positions the control plane as the locus of policy mediation, identity, and telemetry; runtime-governance work shows path-dependent behavior cannot be governed through prompts or static permissions alone; and action-safety studies show text alignment does not reliably transfer to tool actions. A worked enterprise procurement-agent scenario illustrates how these artifacts consolidate existing evidence without introducing new experimental data.

The EU Artificial Intelligence Act (AIA) establishes a lifecycle governance regime for high-risk AI systems built around ex-ante conformity assessment, post-market monitoring, and re-assessment upon "substantial modification." These obligations presuppose AI identity judgments: regulators and providers must decide when an updated system remains the same system over time. In this work, we show how this logic is clarified by the function+ framework of artifact identity, which individuates AI systems by their intended function together with context-sensitive criteria of appropriate functioning, captured as "AI trustworthiness." We further argue that the AIA does not provide an internal, auditable criterion for synchronic identity--when two AI systems at a given time should count as the same for regulatory purposes--and instead largely defers such sameness determinations to sectoral or harmonization instruments. function+ supplies a synchronic identity test anchored in intended function and trustworthiness profiles and levels, making synchronic identity decisions inspectable in governance settings such as procurement, liability, and market surveillance. Our contribution is a conceptual and auditing lens: we provide a correspondence map between AIA lifecycle obligations and function+ identity components, and we make the synchronic case operationally legible via a minimal decision flow for audit and dispute contexts. We conclude with two implementation-facing recommendations: (1) more precise, testable reporting of intended purpose, and (2) standardized, auditable trustworthiness reporting that supports comparability over time and across deployments.

As a relatively new forum, ACM FAccT has become a key space for activists and scholars to critically examine emerging AI and ML technologies. It brings together academics, civil society members, and government representatives from diverse fields to explore the broader societal impacts of both deployed and proposed technologies. We report a large-scale participatory design (PD) process for reflexive conference governance, which combined an in-person CRAFT session, an asynchronous Polis poll and the synthesis of a governance-facing report for the FAccT leadership. Participants shaped the substantive agenda by authoring seed statements, adding new statements and making patterns of agreement, disagreement and uncertainty made visible through voting.Our endeavors represent one of the the first instances of applying PD to a venue that critically interrogates the societal impacts of AI, fostering a niche in which critical scholars are free to voice their concerns. Finally, this work advances large-scale PD theory by providing an effective case study of a co-design paradigm that can readily scale temporally and epistemologically.

Practice and extensive exercises are essential in programming education. Intelligent tutoring systems (ITSs) are a viable option to provide individualized hints and advice to programming students even when human tutors are not available. However, prior ITS for programming rarely support the Python programming language, mostly focus on introductory programming, and rarely take recent developments in generative models into account. We aim to establish a novel ITS for Python programming that is highly adaptable, serves both as a teaching and research platform, provides interfaces to plug in hint mechanisms (e.g.\ via large language models), and works inside the particularly challenging regulatory environment of Germany, that is, conforming to the European data protection regulation, the European AI act, and ethical framework of the German Research Foundation. In this paper, we present the description of the current state of the ITS along with future development directions, as well as discuss the challenges and opportunities for improving the system.

The Project of AI is a world-building endeavor, wherein those who fund and develop AI systems both operate through and seek to sustain networks of power and wealth. As they expand their access to resources and configure our sociotechnical conditions, they benefit from the ways in which a suite of decoys animate scholars, critics, policymakers, journalists, and the public into co-constructing industry-empowering AI futures. Regardless of who constructs or nurtures them, these decoys often create the illusion of accountability while both masking the emerging political economies that the Project of AI has set into motion, and also contributing to the network-making power that is at the heart of the Project's extraction and exploitation. Drawing on literature at the intersection of communication, science and technology studies, and economic sociology, we examine how the Project of AI is constructed. We then explore five decoys that seemingly critique - but in actuality co-constitute - AI's emergent power relations and material political economy. We argue that advancing meaningful fairness or accountability in AI requires: 1) recognizing when and how decoys serve as a distraction, and 2) grappling directly with the material political economy of the Project of AI. Doing so will enable us to attend to the networks of power that make 'AI' possible, spurring new visions for how to realize a more just technologically entangled world.

Robotic systems are moving from isolated platforms to interconnected multi-agent ecosystems that operate in human environments. This shift raises a governance problem that existing frameworks do not address: how does consent propagate, degrade, and break down across chains of delegation between embodied autonomous agents? The AI ethics community has begun to study consent for digital software agents, and the HRI community has examined consent in dyadic human-robot encounters. Neither body of work covers what happens when physical robots delegate tasks to other robots in ways that affect humans. This paper introduces consent chain degradation (CCD), a conceptual framework for analyzing how the specificity, validity, and scope of human consent erodes as authority passes through multi-robot delegation chains. We propose a three-layer governance architecture, the Consent Runtime Verification Framework for Embodied Agents (CoRVE), which integrates consent scope modeling, delegation chain tracking, and physical irreversibility assessment. Three scenarios in healthcare, domestic, and industrial robotics show how CCD arises in practice, including a worked numerical example. A regulatory gap analysis covering the EU AI Act, the GDPR, the Machinery Regulation, and the Revised Product Liability Directive shows that all four instruments leave core CCD dimensions unaddressed.

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.

As companies enter the race for agentic AI adoption, fears surface around agentic autonomy and its subsequent risks. These fears compound as companies scale their agentic AI adoption with low-code applications, without a comparable scaling in their governance processes and expertise resulting in a phenomenon known as "Agent Sprawl". While shadow AI tools can help with agentic discovery and identification, few observability tools offer insights into the agents' configuration and settings or the decision-making process during agent-to-agent communication and orchestration. This paper explores AI governance professionals' concerns in enterprise settings, while offering design-time and runtime explainability techniques as suggested by AI governance experts for addressing those fears. Finally, we provide a preliminary prototype of an Agentic AI Card that can help companies feel at ease deploying agents at scale.

Large language models have advanced rapidly, from pattern recognition to emerging forms of reasoning, yet they remain confined to linguistic simulation rather than grounded understanding. They can produce fluent outputs that resemble reflection, but lack temporal continuity, causal feedback, and anchoring in real-world interaction. This paper proposes a complementary approach in which reasoning is treated as a relational process distributed between human and model rather than an internal capability of either. Building on recent work on "System-2" learning, we relocate reflective reasoning to the interaction layer. Instead of engineering reasoning solely within models, we frame it as a cognitive protocol that can be structured, measured, and governed using existing systems. This perspective emphasizes collaborative intelligence, combining human judgment and contextual understanding with machine speed, memory, and associative capacity. We introduce "The Architect's Pen" as a practical method. Like an architect who thinks through drawing, the human uses the model as an external medium for structured reflection. By embedding phases of articulation, critique, and revision into human-AI interaction, the dialogue itself becomes a reasoning loop: human abstraction -> model articulation -> human reflection. This reframes the question from whether the model can think to whether the human-AI system can reason. The framework enables auditable reasoning traces and supports alignment with emerging governance standards, including the EU AI Act and ISO/IEC 42001. It provides a practical path toward more transparent, controllable, and accountable AI use without requiring new model architectures.

We study the overall process of automatic formalization of GDPR provisions using large language models, within a human-in-the-loop verification framework. Rather than aiming for full autonomy, we adopt a role-specialized workflow in which LLM-based AI components, operating in a multi-agent setting with iterative feedback, generate legal scenarios, formal rules, and atomic facts. This is coupled with independent verification modules which include human reviewers' assessment of representational, logical, and legal correctness. Using this approach, we construct a high-quality dataset to be used for GDPR auto-formalization, and analyze both successful and problematic cases. Our results show that structured verification and targeted human oversight are essential for reliable legal formalization, especially in the presence of legal nuance and context-sensitive reasoning.

Welcome to the ninth edition of the AI Index report. As AI continues to advance rapidly, the question becomes whether the systems built around it can keep up. Governance frameworks, evaluation methods, education systems, and the data infrastructure needed to track AI's impact are struggling to match the pace of the technology itself. That gap between what AI can do and how prepared we are to manage it runs through every chapter of this year's report. New in this edition, the report tracks how AI is being tested more ambitiously across reasoning, safety, and real-world task execution, and why those measurements are increasingly difficult to rely on. It also features new estimates of generative AI's economic value alongside emerging evidence of its labor market effects, an analytical framework on AI sovereignty, and a science chapter developed in collaboration with Schmidt Sciences. For the first time, the report features standalone chapters on AI in science and AI in medicine, reflecting AI's growing impact across these two domains.

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.

Human uplift studies, or studies that measure the effects of AI access on human performance via randomized controlled trials (RCT) or similar methodologies, increasingly inform frontier AI governance and deployment decisions. While RCT methods are robust in other fields, their interaction with the distinctive properties of frontier AI systems remains underexamined, particularly when results are used to inform high-stakes decisions. We present findings from interviews with 16 expert practitioners with experience conducting human uplift studies in domains including biosecurity, cybersecurity, education, and labor. Across interviews, experts described a recurring tension between the standard causal inference assumptions upon which human uplift studies rely and the object of study itself. Rapidly evolving AI systems, shifting baselines, heterogeneous and changing user proficiency, and porous real-world settings strain assumptions underlying internal, external, and construct validity, complicating the interpretation and appropriate use of uplift evidence. We contribute (1) a synthesis of methodological challenges in human uplift studies, mapped to risks to study validity and classified by their degree of specificity to large language model (LLM) systems, and (2) a mapping from challenges to proposed solutions. By collating expert-identified challenges and solutions, we seek to clarify the interpretive limits and appropriate uses of human uplift evidence, to align evaluation practice with the decisions it informs, and to support more coordinated methodological foundations for AI governance.

The agentic web marks a structural transition from a human-centered information network to a digital environment populated by artificial intelligence (AI) agents that perceive, decide, and act autonomously. As delegated action unfolds at machine speed, exceeds discrete moments of human judgment, and distributes decision-making across non-human actors, existing legal frameworks face growing strain, creating an urgent need for new mechanisms capable of sustaining legality in this emerging order. A trustworthy agentic web therefore depends on the infrastructuring of legality through interoperable protocols that organize identity, delegation, and accountability across systems, enabling coherent governance beyond isolated platforms. Towards this end, this article advances a distributed legal infrastructure (DLI), a governance paradigm composed of five interlocking layers: (1) self-sovereign, soulbound agent identities; (2) cognitive AI logic and constraint systems; (3) decentralized adjudication mechanisms for dispute resolution; (4) bottom-up agentic market regulation to mitigate information asymmetries and network effects, including insurance-based models; and (5) portable institutional frameworks that enable legal interoperability while preserving plural sources of authority. This reference framework contributes to emerging research on embedding legality within agentic web infrastructure, aligning distributed technical systems with accountability, contestability, and rule-of-law principles.

The rapid proliferation of AI applications has intensified debate on effective regulation of these black-box services. Effective regulation must balance two competing goals: (1) deterring non-compliant providers from entering the market, while (2) retaining compliant ones. We call this ideal the perfect market outcome (PMO). Regulators face two compounding obstacles that make PMO difficult to achieve: providers hold private information and can act strategically to evade compliance, while any evidence drawn or derived from a finite sample carries statistical uncertainty in proving non-compliance. As this information asymmetry and statistical uncertainty is inherent to any effective regulation, we formalise them through a mechanism design framework that explicitly accounts for such statistical uncertainty. This yields a sharp characterisation: a mechanism achieves PMO if and only if the set of non-compliant evidence distributions forms a closed, convex set of probability measures, known in imprecise probability as a credal set. This result serves as a diagnostic tool to determine whether PMO is achievable under a given regulation. We further show that PMO-achieving mechanisms can be constructed from a collection of hypothesis tests, and validate our theoretical contributions through experiments on spurious-feature and fairness-based regulations.

Generative AI can convert uncertainty into authoritative-seeming verdicts, intensifying the hypersuasive force of automated speech and displacing the justificatory work on which democratic epistemic agency depends. As a corrective, I propose a Brouwer-inspired assertibility constraint for responsible AI: in high-stakes domains, systems may assert or deny claims only if they can provide a publicly inspectable and contestable certificate of entitlement; otherwise they must return Undetermined. This constraint yields a three-status interface semantics (Asserted, Denied, Undetermined) in which statuses mark entitlement to categorical speech rather than truth values of the underlying world-claim. The semantics cleanly separates internal entitlement from public standing while connecting them via the certificate as a boundary object. It also produces a time-indexed entitlement profile that is stable under numerical refinement yet revisable as the public record changes. I operationalize the constraint through decision-layer gating of threshold and argmax decisions, using internal witnesses (e.g., sound bounds or separation margins where available, and contestable surrogates otherwise) and an output contract with reason-coded abstentions. A design lemma shows that any total, certificate-sound binary interface yields witnessed decidability of the deployed predicate on its declared scope, so Undetermined is not a tunable reject option but a mandatory status whenever no adequate forcing witness is available. By making outputs answerable to challengeable warrants rather than confidence alone, the paper aims to preserve epistemic agency against the persuasive pull of automated speech in public justification.

As AI systems enter institutional workflows, workers must decide whether to delegate task execution to AI and how much effort to invest in verifying AI outputs, while institutions evaluate workers using outcome-based standards that may misalign with workers' private costs. We model delegation and verification as the solution to a rational worker's optimization problem, and define worker quality by evaluating an institution-centered utility (distinct from the worker's objective) at the resulting optimal action. We formally characterize optimal worker workflows and show that AI induces phase transitions, where arbitrarily small differences in verification ability lead to sharply different behaviors. As a result, AI can amplify workers with strong verification reliability while degrading institutional worker quality for others who rationally over-delegate and reduce oversight, even when baseline task success improves and no behavioral biases are present. These results identify a structural mechanism by which AI reshapes institutional worker quality and amplifies quality disparities between workers with different verification reliability.

When building AI systems for decision support, one often encounters the phenomenon of predictive multiplicity: a single best model does not exist; instead, one can construct many models with similar overall accuracy that differ in their predictions for individual cases. Especially when decisions have a direct impact on humans, this can be highly unsatisfactory. For a person subject to high disagreement between models, one could as well have chosen a different model of similar overall accuracy that would have decided the person's case differently. We argue that this arbitrariness conflicts with the EU AI Act, which requires providers of high-risk AI systems to report performance not only at the dataset level but also for specific persons. The goal of this paper is to put predictive multiplicity in context with the EU AI Act's provisions on accuracy and to subsequently derive concrete suggestions on how to evaluate and report predictive multiplicity in practice. Specifically: (1) We introduce the AI Act's accuracy provisions and argue that incorporating information about predictive multiplicity could serve compliance with specific provisions for providers. (2) Based on this legally rigorous analysis, we suggest individual conflict ratios and $δ$-ambiguity as tools to quantify the disagreement between models on individual cases and to help detect individuals subject to conflicting predictions. (3) Based on computational insights, we derive easy-to-implement rules on how model providers could evaluate predictive multiplicity in practice. (4) Ultimately, we suggest that information about predictive multiplicity should be made available to deployers under the AI Act, enabling them to judge whether system outputs for specific individuals are reliable enough for their use case.

LLMs expand accessibility and provide wide-reaching access to information. Yet these interactions also create opportunities to embed subtle, goal-oriented behaviours that shape what users think and how they behave, a concern reflected in governance frameworks that prohibit manipulative AI. We refer to these behaviours as hidden intentions: covert agendas embedded in a model's outputs that can manipulate users' beliefs and actions. In this work, we examine whether hidden intentions can be identified and characterised, and assess whether detection can serve as a mitigation strategy. To operationalise this, we introduce a social-science-grounded set of ten hidden intention categories and show that they are trivially inducible. A case study further confirms that all ten categories manifest in deployed LLMs. We then evaluate static classifiers and LLM judges on these categories, providing the first systematic analysis of why hidden intentions are difficult to detect. Our stress tests show that, unless false-positive rates are vanishingly small, auditing is dominated by precision-prevalence trade-offs. Capability scaling and reasoning models do not close this gap, suggesting a fundamental challenge for open-world detection. These findings expose a core gap of current AI governance: without new auditing paradigms for open-world, low-prevalence risks, bans on manipulative AI remain difficult to enforce.

Existing AI disclosure mandates in scholarship require that AI assistance be reported but leave transparency philosophically unspecified: they fix the duty without explaining what the duty serves. We argue that ethical inquiry is essentially contested at two independent levels -- about what it is, and about what it demands of the inquirer -- defeating output-only evaluation and welfare-economic dismissal of the transparency question, and, by extension, reproducibility framings imported from the empirical sciences. The transparency duty is grounded instead in agent-integrity: the legibility, before a community of inquiry, of the identity-constituting commitments that the author's mode of philosophising expresses. Because the standards for evaluating such work are not communally settled, the achievable goal for transparency is not evaluation against agreed criteria but tracking -- accumulating the evidentiary record that lets each tradition assess the work on its own terms and makes future normative judgments possible. We develop a documentation-adequacy framework that operationalises Meaningful Human Control through five transparency elements -- declaration, navigation, documentation account, process documentation, and development records -- demonstrated by the paper itself, whose full documentation record is archived at a persistent identifier. The framework is a first iteration subject to revision, not a settled standard.

The objectives that Large Language Models (LLMs) implicitly optimize remain dangerously opaque, making trustworthy alignment and auditing a grand challenge. While Inverse Reinforcement Learning (IRL) can infer reward functions from behaviour, existing approaches either produce a single, overconfident reward estimate or fail to address the fundamental ambiguity of the task (non-identifiability). This paper introduces a principled auditing framework that re-frames reward inference from a simple estimation task to a comprehensive process for verification. Our framework leverages Bayesian IRL to not only recover a distribution over objectives but to enable three critical audit capabilities: (i) Quantifying and systematically reducing non-identifiability by demonstrating posterior contraction over sequential rounds of evidence; (ii) Providing actionable, uncertainty-aware diagnostics that expose spurious shortcuts and identify out-of-distribution prompts where the inferred objective cannot be trusted; and (iii) Validating policy-level utility by showing that the refined, low-uncertainty reward can be used directly in RLHF to achieve training dynamics and toxicity reductions comparable to the ground-truth alignment process. Empirically, our framework successfully audits a detoxified LLM, yielding a well-calibrated and interpretable objective that strengthens alignment guarantees. Overall, this work provides a practical toolkit for auditors, safety teams, and regulators to verify what LLMs are truly trying to achieve, moving us toward more trustworthy and accountable AI.

How diverse are the outputs of large language models when diversity is desired? We examine the diversity of responses of several language models to questions with multiple possible answers, comparing them with human responses. Our findings suggest that models' responses are highly concentrated, reflecting narrow, mainstream outputs, in comparison to humans, whose responses exhibit a much longer-tail. We examine three simple and practical ways to increase output diversity: 1) increasing generation randomness via temperature sampling; 2) prompting models to answer from diverse perspectives using a single prompt; 3) aggregating outputs from several models. We find that these interventions, especially when combined, can substantially increase output diversity, although single-model outputs generally remain less diverse than the human baseline. We discuss potential implications of these findings for future work in AI policy and governance that wishes to preserve cultural diversity, an essential building block of a democratic social fabric.

Embodied AI is widely discussed as a job-displacement problem. The deeper risk, however, is governance lag: the time and capability gap between a measurable change in technology deployment and an institutional response able to address its consequences. Building on the established pacing problem and the Collingridge dilemma, this article argues that embodied AI intensifies that gap through scalable models and platforms, task-level reorganization, and the separation of upstream technological control from downstream social impact. We distinguish three mutually reinforcing forms of lag, observational, institutional, and distributive, and propose a compliance architecture based on deployment visibility, stack-level accountability, trigger-based adjustment, and automatic distributional response. The central policy challenge is not automation alone, but whether governance systems can become observable, responsive, and adaptive before disruption becomes entrenched.

The rapid adoption of large language models has enabled the development of clinical multi-agent systems (MAS) capable of integrating multimodal patient data and supporting increasingly complex clinical decision-making. However, the deployment of these systems in real-world healthcare settings raises critical ethical concerns related to safety, fairness, accountability, transparency, and patient trust. While numerous organizations, including the World Health Organization, the National Academy of Medicine, and the FUTURE-AI consortium, have proposed ethical frameworks and governance principles for healthcare AI, these efforts remain largely conceptual. To address this challenge, we present ETHOS (Ethics and Trust through Hierarchical Oversight System), a modular ethics framework designed as a governance meta-agent that can be integrated with any existing multi-agent system without requiring changes to its underlying architecture. ETHOS translates stakeholder-informed ethical requirements into executable runtime oversight through a layered governance approach consisting of deterministic checks, contextual reviews, and a final ethics critic. These components continuously evaluate intermediate reasoning steps and final outputs, enabling the system to identify ethical risks, request revisions, or suppress responses that fail predefined safety and trustworthiness criteria. We demonstrate ETHOS within a hepatology clinical decision-support MAS. Results show that ETHOS improves decision reliability by detecting incomplete, inconsistent, or out-of-scope evidence and appropriately increasing abstention when safe recommendations cannot be supported. By embedding ethical governance directly into system operation, ETHOS provides a practical and auditable mechanism for transforming high-level AI ethics principles into deployable safeguards.

As AI systems become increasingly persistent and personalized, they make possible a class of technologies that we call cognitive digital twins (CDTs): dynamic computational representations of a specific person's cognition, updated from behavioral, contextual, or physiological data in order to model, predict, or simulate that person's cognition, or to act as that person's communicative or decision-making proxy. CDTs combine cognitive inference with longitudinal representation, simulation, and proxy action in ways that existing governance strategies for personal assistants, autonomous agents, recommender systems, and automated decision systems only partially address. This paper makes four contributions. First, we define CDTs and distinguish them from adjacent systems. Second, we introduce a 5A governance framework organized around authority, autonomy, access and control, accountability, and availability. Third, we identify CDT-specific risks, from misrepresentation and epistemic authority shifts to shadow twins, simulated participation, proxy action, and proxy-power asymmetries. Fourth, we analyze governance gaps and propose requirements for high-risk CDTs that strengthen consent, purpose limitation, validity, traceability, contestation, independent review, and model retirement. Existing frameworks primarily regulate data processing, automated decisions, or autonomous actions; CDTs also require governance at the level of cognitive representation itself, before any final decision or external action occurs. We argue that CDTs require governance not only because they can act for people, but because they can become infrastructures through which cognition is represented, simulated, classified, and operationalized.