AIR-OP-017
AI Governance Framework Icon

Lack of Explainability

Summary

AI systems, particularly those using complex foundation models, often lack transparency, making it difficult to interpret how decisions are made. This limits firms’ ability to explain outcomes to regulators, stakeholders, or customers, raising trust and compliance concerns. Without explainability, errors and biases can go undetected, increasing the risk of inappropriate use, regulatory scrutiny, and undiagnosed failures.

Description

A key challenge in deploying AI systems—particularly those based on complex foundation models—is the difficulty of interpreting and understanding how decisions are made. These models often operate as “black boxes,” producing outputs without a clear, traceable rationale. This lack of transparency in decision-making can make it challenging for firms to explain or justify AI-driven outcomes to internal stakeholders, regulators, or affected customers.

The opaque nature of these models makes it hard for firms to articulate the rationale behind AI-driven decisions to stakeholders, including customers, regulators, and internal oversight bodies. This can heighten regulatory scrutiny and diminish consumer trust, as the basis for outcomes (e.g., loan approvals, investment recommendations, fraud alerts) cannot be clearly explained.

Furthermore, the inability to peer inside the model can conceal underlying errors, embedded biases, or vulnerabilities that were not apparent during initial development or testing. This opacity complicates the assessment of model soundness and reliability, a critical aspect of risk management in financial services. Without a clear understanding of how a model arrives at its conclusions, firms risk deploying AI systems that they do not fully comprehend.

This can lead to inappropriate application, undiagnosed failures in specific scenarios, or an inability to adapt the model effectively to changing market conditions or regulatory requirements. Traditional validation and testing methodologies may prove insufficient for these complex, non-linear models, making it difficult to ensure they are functioning as intended and in alignment with the institution’s ethical guidelines and risk appetite.

Transparency and accountability are paramount in financial services; the lack of explainability directly undermines these principles, potentially exposing firms to operational, reputational, and compliance risks.