ExplainabilityAccountabilityTransparencycs.LG
Explanation Beyond Intuition: A Testable Criterion for Inherent Explainability
Michael Merry, Pat Riddle, Jim Warren
December 19, 2025
arXiv.org
Key Takeaways
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Explainability needs a testable definition, not just intuition: The paper addresses a critical gap in AI regulation by proposing the first formally testable criterion for "inherent explainability" rather than relying on subjective judgments. This provides regulators and organizations with a rigorous framework for compliance, moving beyond the current "we know it when we see it" approach.
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Model size and complexity don't determine explainability: The research demonstrates that a large regression model may fail explainability tests while a sparse neural network could pass them. This challenges common assumptions that simpler models are automatically more explainable and suggests that model structure matters more than model size.
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Explainability requires verified evidence, not just capability: The paper distinguishes between "explainable" (a model that allows for explanation) and "explained" (one with verified explanation). This distinction is important for responsible AI deployment—having the potential to explain a model is insufficient; organizations must actually provide and verify those explanations.
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Real-world medical AI can meet rigorous explainability standards: The authors provide a complete explanation of PREDICT, a cardiovascular disease risk model actively used in New Zealand clinics, demonstrating that inherent explainability is achievable in high-stakes applications. This provides a concrete example that rigorous explainability standards are practical, not theoretical.
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A flexible framework can serve regulatory needs: The proposed criterion uses graph theory and hypothesis-evidence structures that allow multiple explanation methods while maintaining rigor, offering regulators a tool that is both flexible enough for diverse AI systems and strict enough to ensure genuine accountability.