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    Technical Guide

    AI Decision Explainability for Regulators

    To explain an AI-driven decision to a regulator, an organization needs a system-level decision record, not only model interpretability output. The record should show what was requested, what context and policies applied, which identity and permissions were in effect, what actions were taken, and which controls were enforced. This evidence has to be captured at runtime, because reconstructing it afterwards is rarely defensible.

    What an explanation request actually requires

    When a regulator asks how an AI-driven decision was made, the answer has to describe the system that produced the decision, not only the model. A defensible answer shows what was requested, what context and policies applied, which identity and permissions were in effect, what actions were taken, and which controls were enforced.

    Model interpretability output can contribute to that answer, but on its own it does not cover these points. Explainability to regulators is an evidence problem at the system and runtime layer.

    The decision record at a glance

    A system-level decision record is built from four elements.

    Elements of a system-level decision record
    ElementWhat it captures
    RequestWhat the user, system, or agent asked for, and where the request originated.
    Context and policyWhat information was retrieved and which policy versions were evaluated.
    Identity and permissionsWhich agent acted, for whom, and with what effective access.
    Actions and controlsWhich tool calls ran, and which controls allowed, blocked, or escalated them.

    Model interpretability versus system-level traceability

    Model interpretability output addresses the model. System-level traceability addresses the whole decision: the request, the retrieved context and evaluated policy versions, the acting agent and its effective access, the tool calls that ran, and the controls that allowed, blocked, or escalated them.

    A regulator reviewing an AI-driven decision needs the second kind of record. Interpretability output may sit alongside it, but it does not replace it.

    Why runtime enforcement is the source of the evidence

    The decision record has to be captured at runtime, because reconstructing it afterwards is rarely defensible. Runtime policy enforcement and audit logging produce the evidence as the decision happens: which policy versions were evaluated, which identity and permissions applied, and which controls allowed, blocked, or escalated each action.

    How to test whether your deployments can produce this evidence

    Select a decision made in one of your agent deployments and try to produce its record. For that decision, ask whether you can show each of the following:

    • The request: what was asked, and where the request originated.
    • Context and policy: what information was retrieved and which policy versions were evaluated.
    • Identity and permissions: which agent acted, for whom, and with what effective access.
    • Actions and controls: which tool calls ran, and which controls allowed, blocked, or escalated them.

    Assess your decision evidence

    If you want to review how runtime policy enforcement and audit logging could close the gaps in your agent deployments, speak with the Trussed AI team.

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