A provider of a high-risk AI system must keep records that make a decision traceable, and for agentic systems it has not been established what those records must contain for post-hoc causal attribution to be possible. We give the estimator framework and then the conditions under which it fails. We separate the marginal total effect that prior work measures from a common-random-numbers total effect that isolates a step's own contribution, add the natural direct effect under a pinned downstream, and check the estimators against hand derivations. Both estimands then fail, in the same direction. Under the marginal estimand a causally inert step has the identical total effect to the decisive one on every run of our planted chain, an algebraic identity and not a coincidence at one draw. Under common random numbers the decisive step returns exactly zero on the runs where the executing step flips, about one in ten, while its direct effect there is 0.25 and it demonstrably acts; an exact zero does not certify that a step did nothing, and we put that here rather than in the limitations. We derive the coupling that keeps the direct effect estimable once contexts diverge, with a closed form for its degradation, and show that the mediated share on which a natural ranking is built is not a share under suppression: where the direct and mediated paths oppose, it exceeds one and ranks a suppressed component above a pure mediator. We publish the discrepancy experiment's pre-registration rather than a result, because the live pipeline it requires was not available in the study window. We contribute the traceability specification such a filing would need, against a gap the Act's calendar opens: Article 86's right to an explanation has applied since 2 August 2026, while the Article 12 logging and Annex IV documentation that could evidence one were deferred to 2 December 2027 by Regulation (EU) 2026/1744.
The EU AI Act requires providers of high-risk systems to file technical documentation describing how the system reaches its decisions. Mechanistic interpretability is the obvious source of such evidence, and circuit discovery is its most developed instrument. We ask whether that evidence survives the condition under which it would be relied upon: two competent analysts, the same system, the same tool, different defensible settings. We pre-registered a crossed grid of seven analytic axes, every level taken from a published implementation, and mapped each discovered circuit through a deterministic claim map to a structured Annex IV statement. Across 15,840 pre-registered specifications on GPT-2 small and the indirect object identification task, of which 7,561 produced a claim, the derived statement flips across 73.2% of specification pairs (95% CI 0.725 to 0.738) and the modal claim commands 41.1% of the space. The evidence fails a filability criterion at every tolerance a conformity assessment body would plausibly accept. Standardising the single most influential choice, the evaluation metric, leaves the flip rate at 59.4%. Removing circuit size from the claim entirely and holding it fixed leaves 27.1% (95% CI 0.255 to 0.286), still above the pre-registered threshold. The circuits underlying these claims are structurally near-disjoint, median pairwise Jaccard overlap 4%, and functionally uncorrelated at Cohen's kappa 0.015, so the instability is not one mechanism described in different words. We give the filability criterion as a standalone protocol, and we report that one of the seven documented discovery objectives does not execute at all on the library's own canonical task. The study covers one model and one task, and whether the conclusion holds at scale is untested.
Ajay Pravin Mahale· 1 citation
We use cookies to run the site and, with your consent, for analytics and to show ads.
See our Cookie Policy.