The Limits of AI Data Transparency Policy: Three Disclosure Fallacies

Data transparency has emerged as a rallying cry for addressing concerns about AI: data quality, privacy, and copyright chief among them. Yet while these calls are crucial for accountability, current transparency policies often fall short of their intended aims. Similar to nutrition facts for food, policies aimed at nutrition facts for AI currently suffer from a limited consideration of research on effective disclosures. We offer an institutional perspective and identify three common fallacies in policy implementations of data disclosures for AI. First, many data transparency proposals exhibit a specification gap between the stated goals of data transparency and the actual disclosures necessary to achieve such goals. Second, reform attempts exhibit an enforcement gap between required disclosures on paper and enforcement to ensure compliance in fact. Third, policy proposals manifest an impact gap between disclosed information and meaningful changes in developer practices and public understanding. Informed by the social science on transparency, our analysis identifies affirmative paths for transparency that are effective rather than merely symbolic.

Who Evaluates AI's Social Impacts? Mapping Coverage and Gaps in First and Third Party Evaluations

Foundation models are increasingly central to high-stakes AI systems, and governance frameworks now depend on evaluations to assess their risks and capabilities. Although general capability evaluations are widespread, social impact assessments covering bias, fairness, privacy, environmental costs, and labor practices remain uneven across the AI ecosystem. To characterize this landscape, we conduct the first comprehensive analysis of both first-party and third-party social impact evaluation reporting across a wide range of model developers. Our study examines 186 first-party release reports and 183 post-release evaluation sources, and complements this quantitative analysis with interviews of model developers. We find a clear division of evaluation labor: first-party reporting is sparse, often superficial, and has declined over time in key areas such as environmental impact and bias, while third-party evaluators including academic researchers, nonprofits, and independent organizations provide broader and more rigorous coverage of bias, harmful content, and performance disparities. However, this complementarity has limits. Only model developers can authoritatively report on data provenance, content moderation labor, financial costs, and training infrastructure, yet interviews reveal that these disclosures are often deprioritized unless tied to product adoption or regulatory compliance. Our findings indicate that current evaluation practices leave major gaps in assessing AI's societal impacts, highlighting the urgent need for policies that promote developer transparency, strengthen independent evaluation ecosystems, and create shared infrastructure to aggregate and compare third-party evaluations in a consistent and accessible way.

Rigor in AI: Doing Rigorous AI Work Requires a Broader, Responsible AI-Informed Conception of Rigor

In AI research and practice, rigor remains largely understood in terms of methodological rigor -- such as whether mathematical, statistical, or computational methods are correctly applied. We argue that this narrow conception of rigor has contributed to the concerns raised by the responsible AI community, including overblown claims about AI capabilities. Our position is that a broader conception of what rigorous AI research and practice should entail is needed. We believe such a conception -- in addition to a more expansive understanding of (1) methodological rigor -- should include aspects related to (2) what background knowledge informs what to work on (epistemic rigor); (3) how disciplinary, community, or personal norms, standards, or beliefs influence the work (normative rigor); (4) how clearly articulated the theoretical constructs under use are (conceptual rigor); (5) what is reported and how (reporting rigor); and (6) how well-supported the inferences from existing evidence are (interpretative rigor). In doing so, we also aim to provide useful language and a framework for much-needed dialogue about the AI community's work by researchers, policymakers, journalists, and other stakeholders.

Measurement to Meaning: A Validity-Centered Framework for AI Evaluation

While the capabilities and utility of AI systems have advanced, rigorous norms for evaluating these systems have lagged. Grand claims, such as models achieving general reasoning capabilities, are supported with model performance on narrow benchmarks, like performance on graduate-level exam questions, which provide a limited and potentially misleading assessment. We provide a structured approach for reasoning about the types of evaluative claims that can be made given the available evidence. For instance, our framework helps determine whether performance on a mathematical benchmark is an indication of the ability to solve problems on math tests or instead indicates a broader ability to reason. Our framework is well-suited for the contemporary paradigm in machine learning, where various stakeholders provide measurements and evaluations that downstream users use to validate their claims and decisions. At the same time, our framework also informs the construction of evaluations designed to speak to the validity of the relevant claims. By leveraging psychometrics' breakdown of validity, evaluations can prioritize the most critical facets for a given claim, improving empirical utility and decision-making efficacy. We illustrate our framework through detailed case studies of vision and language model evaluations, highlighting how explicitly considering validity strengthens the connection between evaluation evidence and the claims being made.

Identities are not Interchangeable: The Problem of Overgeneralization in Fair Machine Learning

A key value proposition of machine learning is generalizability: the same methods and model architecture should be able to work across different domains and different contexts. While powerful, this generalization can sometimes go too far, and miss the importance of the specifics. In this work, we look at how fair machine learning has often treated as interchangeable the identity axis along which discrimination occurs. In other words, racism is measured and mitigated the same way as sexism, as ableism, as ageism. Disciplines outside of computer science have pointed out both the similarities and differences between these different forms of oppression, and in this work we draw out the implications for fair machine learning. While certainly not all aspects of fair machine learning need to be tailored to the specific form of oppression, there is a pressing need for greater attention to such specificity than is currently evident. Ultimately, context specificity can deepen our understanding of how to build more fair systems, widen our scope to include currently overlooked harms, and, almost paradoxically, also help to narrow our scope and counter the fear of an infinite number of group-specific methods of analysis.

Toward an Evaluation Science for Generative AI Systems

There is an increasing imperative to anticipate and understand the performance and safety of generative AI systems in real-world deployment contexts. However, the current evaluation ecosystem is insufficient: Commonly used static benchmarks face validity challenges, and ad hoc case-by-case audits rarely scale. In this piece, we advocate for maturing an evaluation science for generative AI systems. While generative AI creates unique challenges for system safety engineering and measurement science, the field can draw valuable insights from the development of safety evaluation practices in other fields, including transportation, aerospace, and pharmaceutical engineering. In particular, we present three key lessons: Evaluation metrics must be applicable to real-world performance, metrics must be iteratively refined, and evaluation institutions and norms must be established. Applying these insights, we outline a concrete path toward a more rigorous approach for evaluating generative AI systems.

Fairness through Difference Awareness: Measuring Desired Group Discrimination in LLMs

Algorithmic fairness has conventionally adopted a perspective of racial color-blindness (i.e., difference unaware treatment). We contend that in a range of important settings, group difference awareness matters. For example, differentiating between groups may be necessary in legal contexts (e.g., the U.S. compulsory draft applies to men but not women) and harm assessments (e.g., calling a girl a terrorist may be less harmful than calling a Muslim person one). In our work we first introduce an important distinction between descriptive (fact-based), normative (value-based), and correlation (association-based) benchmarks. This distinction is significant because each category requires distinct interpretation and mitigation tailored to its specific characteristics. Then, we present a benchmark suite composed of eight different scenarios for a total of 16k questions that enables us to assess difference awareness. Finally, we show results across ten models that demonstrate difference awareness is a distinct dimension of fairness where existing bias mitigation strategies may backfire.

Measuring Implicit Bias in Explicitly Unbiased Large Language Models

Large language models (LLMs) can pass explicit bias tests but still harbor implicit biases, similar to humans who endorse egalitarian beliefs yet exhibit subtle biases. Measuring such implicit biases can be a challenge: as LLMs become increasingly proprietary, it may not be possible to access their embeddings and apply existing bias measures; furthermore, implicit biases are primarily a concern if they affect the actual decisions that these systems make. We address both of these challenges by introducing two measures of bias inspired by psychology: LLM Implicit Association Test (IAT) Bias, which is a prompt-based method for revealing implicit bias; and LLM Decision Bias for detecting subtle discrimination in decision-making tasks. Using these measures, we found pervasive human-like stereotype biases in 6 LLMs across 4 social domains (race, gender, religion, health) and 21 categories (weapons, guilt, science, career among others). Our prompt-based measure of implicit bias correlates with embedding-based methods but better predicts downstream behaviors measured by LLM Decision Bias. This measure is based on asking the LLM to decide between individuals, motivated by psychological results indicating that relative not absolute evaluations are more related to implicit biases. Using prompt-based measures informed by psychology allows us to effectively expose nuanced biases and subtle discrimination in proprietary LLMs that do not show explicit bias on standard benchmarks.

Measuring machine learning harms from stereotypes: requires understanding who is being harmed by which errors in what ways

As machine learning applications proliferate, we need an understanding of their potential for harm. However, current fairness metrics are rarely grounded in human psychological experiences of harm. Drawing on the social psychology of stereotypes, we use a case study of gender stereotypes in image search to examine how people react to machine learning errors. First, we use survey studies to show that not all machine learning errors reflect stereotypes nor are equally harmful. Then, in experimental studies we randomly expose participants to stereotype-reinforcing, -violating, and -neutral machine learning errors. We find stereotype-reinforcing errors induce more experientially (i.e., subjectively) harmful experiences, while having minimal changes to cognitive beliefs, attitudes, or behaviors. This experiential harm impacts women more than men. However, certain stereotype-violating errors are more experientially harmful for men, potentially due to perceived threats to masculinity. We conclude that harm cannot be the sole guide in fairness mitigation, and propose a nuanced perspective depending on who is experiencing what harm and why.

Overcoming Bias in Pretrained Models by Manipulating the Finetuning Dataset

Transfer learning is beneficial by allowing the expressive features of models pretrained on large-scale datasets to be finetuned for the target task of smaller, more domain-specific datasets. However, there is a concern that these pretrained models may come with their own biases which would propagate into the finetuned model. In this work, we investigate bias when conceptualized as both spurious correlations between the target task and a sensitive attribute as well as underrepresentation of a particular group in the dataset. Under both notions of bias, we find that (1) models finetuned on top of pretrained models can indeed inherit their biases, but (2) this bias can be corrected for through relatively minor interventions to the finetuning dataset, and often with a negligible impact to performance. Our findings imply that careful curation of the finetuning dataset is important for reducing biases on a downstream task, and doing so can even compensate for bias in the pretrained model.