Risk · R-078 · Model Performance & Reliability

Poor quality or unrepresentative training data

Training or reference data is inaccurate, incomplete, out of date or unrepresentative of the population the system serves, and the model inherits the defect.

Severity
High
Audience
Heads-of · Practitioner
Frameworks
Article 10 · Data minimisation · Annex A.7 · Principle 3
Reviewed
2026-11-10

What it is

A model can be no better than its data. Quality has several dimensions: whether records are correct, whether fields are complete, whether the data is current, whether labels are right, and whether the data covers the people and situations the system will meet. This entry concerns defects with no deliberate cause. Deliberate manipulation is covered in data and model poisoning; data that under-represents particular groups is also a fairness risk, covered in training data bias.

How it happens

  • Data is taken from an operational system built for another purpose.
  • Labels were assigned inconsistently or by an earlier, flawed process.
  • Historical data reflects products, customers or rules that no longer apply.
  • Records with missing values are dropped, removing a whole segment.

Why it matters

Errors in data become errors in every output, and they are hard to see because the model fits the data it was given. Remedying the defect requires better data and retraining, which may not be possible quickly.

Warning signs

  • No data quality assessment exists for the training set.
  • The origin and meaning of fields are known only to one person.
  • The training population differs visibly from current customers.
  • Performance in production is below performance in testing.

Who owns it

The data owner is accountable for the quality of data supplied. The model owner is accountable for judging whether it is adequate for the purpose.

In practice

A claims triage model is trained on five years of handled claims. For two of those years a backlog meant that complex claims were coded with a default category. The model learns that the default category is routine and routes complex claims to the fast track. The same pattern generalises to any model trained on operational data whose history was not examined.

Mitigating controls

Primary controls

Data quality and representativeness checks Detective
Assesses accuracy, completeness, currency and coverage before use and on refresh. Training, test and reference data are assessed for accuracy, completeness, currency and coverage of the population the system will serve, before use and at each refresh.

Supporting controls

Dataset documentation Directive
Records known limitations of each dataset. Each dataset used for AI has a maintained record of its source, collection method, contents, rights, lawful basis, known limitations and permitted uses.
Training data provenance checks Preventive
Establishes origin as part of judging quality. The source, collection method, rights and integrity of every dataset are verified and recorded before it is used for training, fine-tuning or retrieval.

Framework and clause references

FrameworkClauseTitle
EU AI ActArticle 10Data and data governance The duty this risk is a failure of.
Guidance on AI and data protectionData minimisationData minimisation and accuracy Accuracy of data.
ISO/IEC 42001:2023Annex A.7Data for AI systems Data for AI systems.
SS1/23: Model Risk Management Principles for BanksPrinciple 3Model development, implementation and use Data quality in development.

Sources

EU AI Act: Regulation (EU) 2024/1689 European Union (EUR-Lex) · official text
SS1/23: Model Risk Management Principles for Banks Bank of England PRA · official text

Related terms

How to cite

Axiom Verity (2026). Poor quality or unrepresentative training data. Reference Library, R-078. https://axiom-verity.com/risks/poor-quality-or-unrepresentative-training-data. Reviewed 2026-11-10.