When Do Data-Driven Systems Exhibit the Capability to Infer?

The European AI Act is the first comprehensive regulation of artificial intelligence (AI), setting out extensive obligations, particularly for so-called high-risk and general-purpose AI systems. A key distinguishing feature of AI systems under the AI Act is the capability to infer. Since the AI Act does not clearly define what inference is, there is a gray area for certain data-driven systems. A specific example is credit scoring systems, which are listed by Annex III of the AI Act. At the same time, however, these are often implemented using statistical models for which it is unclear whether they have the capability to infer and thus fall under the AI definition of the AI Act at all. Motivated by statistical learning theory, this work develops a framework for grading different levels of the capability to infer. Based on the AI Act and the Commission Guidelines on the definition of an artificial intelligence system, we analyze which levels constitute sufficient capability to infer within the meaning of the AI Act and where further regulatory clarity is needed. We illustrate the framework by creating two realistic credit scoring workflows and show whether and where inference occurs in them. Our analysis illustrates that not only individual models but the entire data processing workflow must be considered. It also shows that the involvement of human experts during development can have significant influence on the capability to infer. Code can be found at https://github.com/fraunhofer-iais/inference-framework-creditscorecards.

Textual Data Bias Detection and Mitigation -- An Extensible Pipeline with Experimental Evaluation

Textual data used to train large language models (LLMs) exhibits multifaceted bias manifestations encompassing harmful language and skewed demographic distributions. Regulations such as the European AI Act require identifying and mitigating biases against protected groups in data, with the ultimate goal of preventing unfair model outputs. However, practical guidance and operationalization are lacking. We propose a comprehensive data bias detection and mitigation pipeline comprising four components that address two data bias types, namely representation bias and (explicit) stereotypes for a configurable sensitive attribute. First, we leverage LLM-generated word lists created based on quality criteria to detect relevant group labels. Second, representation bias is quantified using the Demographic Representation Score. Third, we detect and mitigate stereotypes using sociolinguistically informed filtering. Finally, we compensate representation bias through Grammar- and Context-Aware Counterfactual Data Augmentation. We conduct a two-fold evaluation using the examples of gender, religion and age. First, the effectiveness of each individual component on data debiasing is evaluated through human validation and baseline comparison. The findings demonstrate that we successfully reduce representation bias and (explicit) stereotypes in a text dataset. Second, the effect of data debiasing on model bias reduction is evaluated by bias benchmarking of several models (0.6B-8B parameters), fine-tuned on the debiased text dataset. This evaluation reveals that LLMs fine-tuned on debiased data do not consistently show improved performance on bias benchmarks, exposing critical gaps in current evaluation methodologies and highlighting the need for targeted data manipulation to address manifested model bias.