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
- Lifecycle stage
- 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
| Framework | Clause | Title |
|---|---|---|
| EU AI Act | Article 86 | Right 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 2 | Systems are evaluated for trustworthy characteristics Evaluation of explainability. |
| UK General Data Protection Regulation | Articles 22A to 22D | Automated 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
- NIST AI Risk Management Framework (AI RMF 1.0) NIST · framework
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.
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