Risk · R-156 · Transparency & Explainability

Unfaithful explanations

An explanation given for a model's output does not reflect how the model actually reached it.

Severity
Medium
Audience
Heads-of · Practitioner
Frameworks
Article 86 · MEASURE 2 · Articles 22A to 22D
Responsible AI domain
Reviewed
2026-11-11

What it is

Explanation methods produce an account of a model's behaviour, and the account can be wrong. Feature-attribution techniques approximate a complex model with a simpler one and can disagree with each other on the same decision. A language model asked to explain its answer writes a plausible rationale, which is generated in the same way as any other text and need not correspond to what produced the answer. Reason codes may be assigned by a separate rule that only loosely tracks the model.

How it happens

  • An explanation tool is adopted and its output is taken at face value.
  • A model's own account of its reasoning is presented as the reason.
  • Reason codes are mapped from scores by a table nobody has tested.
  • Different methods give different answers and one is chosen for convenience.

Why it matters

People act on explanations: a customer changes what they were told mattered, a validator signs off a model, a reviewer accepts an output. If the explanation is unfaithful, each of those acts rests on a mistake. An organisation that gives a false reason for a decision may be in a worse position than one that gave none.

Warning signs

  • Explanation methods have never been tested against known model behaviour.
  • Two methods disagree on the main factors.
  • Changing the factor named in an explanation does not change the outcome.
  • The system's self-explanation is logged as the reason for a decision.

Mitigating controls

Primary controls

Explanation method validation Detective
Tests explanations against the model's behaviour before they are relied on. The techniques used to explain a model are tested to confirm that they reflect the model's actual behaviour before explanations are relied on internally or given to anyone.

Supporting controls

Independent model validation Detective
Independent review of the explanation method. A function independent of the developers tests each model's conceptual soundness, data, performance and limitations before approval and periodically afterwards, to a depth set by the model's tier.

Framework and clause references

FrameworkClauseTitle
EU AI ActArticle 86Right to explanation of individual decision-making An explanation must reflect the main elements of the decision.
NIST AI Risk Management Framework (AI RMF 1.0)MEASURE 2Systems are evaluated for trustworthy characteristics Evaluation of explainability.
UK General Data Protection RegulationArticles 22A to 22DAutomated processing and significant decisions Information about the decision must be meaningful.

Sources

EU AI Act: Regulation (EU) 2024/1689 European Union (EUR-Lex) · official text

Related terms

How to cite

Axiom Verity (2026). Unfaithful explanations. Reference Library, R-156. https://axiom-verity.com/risks/unfaithful-explanations. Reviewed 2026-11-11.