# AI Explainability Templates and Validation Checklist

Setting and delivering the right level of explanation per system. A requirements matrix, a customer-facing adverse-action explanation template, a regulator explanation document, and a validation checklist that asks whether an explanation is actually faithful to the model.

**Who this is for:** The owner deciding what explanation each AI system must produce, for whom, and how it is validated.

Source playbook: https://aigovernance.com/playbook/explainability-standards-for-ai

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## Explainability requirements matrix

_System by risk tier, mapped to the explanation type and audiences it owes._

### Template

| System | Risk tier | Explanation approach | Audiences owed an explanation | Legal driver |
|---|---|---|---|---|
| <system> | Minimal / Limited / High | none / global feature importance / per-decision factors / inherently interpretable | customer / regulator / internal reviewer | GDPR Art. 22 / FCRA / EU AI Act Art. 13 / none |

### Worked example

| System | Risk tier | Explanation approach | Audiences | Legal driver |
|---|---|---|---|---|
| resume-screener | High | per-decision top factors + counterfactual; inherently interpretable scoring head | internal reviewer; candidate on request | EU AI Act Art. 13-14; local hiring transparency |
| credit-decisioning | High | per-decision reason codes | customer (adverse action); regulator | FCRA / ECOA; GDPR Art. 22 |
| support-copilot | Limited | none per-decision; system-level description | internal | none |

### Acceptance criteria

- Every system has a stated explanation approach tied to its risk tier.
- The audiences are named, and the legal driver for each is identified.
- Where the law requires a specific format (FCRA reason codes, GDPR meaningful information), the matrix says so.

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## Customer-facing explanation template

_Plain-language, adverse-action-style explanation an individual can act on._

### Template

> Plain language. No model jargon. Actionable where possible.

- **Decision:** what was decided
- **Main reasons:** the top 3-4 factors, in everyday terms, most important first
- **What would have helped:** the closest change that could have altered the outcome, if one exists
- **Human involvement:** whether a person reviewed it and how to reach one
- **How to contest:** the appeal or reconsideration route, with a timeframe
- **Data used:** the categories of information considered, and how to request the specifics

### Worked example

- **Decision:** Your application was not advanced to interview at this stage.
- **Main reasons:** (1) The listed experience was below what the role requires. (2) Fewer of the role's core skills were evidenced in the application. (3) No portfolio or work samples were included.
- **What would have helped:** Adding work samples and listing the core skills explicitly tends to change this outcome for similar applications.
- **Human involvement:** A recruiter reviewed this decision. You can reply to this email to reach them.
- **How to contest:** Request a reconsideration within 14 days by replying with any additional information.
- **Data used:** Your application form and any attached documents. To request the specific factors, contact privacy@company.example.

### Acceptance criteria

- The explanation uses everyday language and avoids feature names or scores.
- It states whether a human was involved and how to reach one.
- It gives a concrete route and timeframe to contest.
- It is generated as part of the decision flow, not written by hand after a complaint.

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## Regulator / auditor explanation document

_The technical explanation a regulator expects: how the system reaches decisions, and the evidence the explanations are sound._

### Template

> One per high-risk system. Part of the documentation package.

- **System and version:**
- **Decision logic overview:** model type, inputs, how outputs map to decisions
- **Explanation method:** inherently interpretable, or the post-hoc method (SHAP, LIME, reason codes) and its configuration
- **Fidelity evidence:** how you validated that explanations reflect actual model behaviour, with results
- **Worked examples:** 2-3 real decisions with their explanations
- **Known limits of the explanation:** where it is approximate or can mislead
- **Change control:** how explanations are kept in sync when the model changes

### Worked example

- **System:** resume-screener v2.4.0
- **Decision logic:** VendorLM-4 features feed a linear scoring head; score bands map to advance / hold / review.
- **Explanation method:** the scoring head is inherently interpretable (signed coefficients); per-decision output lists the top contributing features and a nearest counterfactual.
- **Fidelity evidence:** because the head is linear, per-decision attributions are exact for the head; feature-embedding stability tested by perturbation (mean rank change 0.4 across 1,000 cases).
- **Worked examples:** dec-...823 (score 2, factors: experience, skill match), dec-...901 (score 4), dec-...733 (override case).
- **Known limits:** attributions describe the scoring head, not the upstream embedding; portfolio content is not an input, so the model cannot weigh it.
- **Change control:** any change to features or the head triggers regeneration of the explanation spec and this document.

### Acceptance criteria

- The document explains the actual decision logic, not a generic description of ML.
- It includes evidence that explanations are faithful, not just that they are produced.
- It states where the explanation is approximate or could mislead.

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## Explanation validation checklist

_Confirms an explanation method actually represents the model before you rely on it._

### Template

| Check | Result | Evidence |
|---|---|---|
| Removing the top-cited feature materially changes the output | Y / N | perturbation test |
| Explanations are stable across near-identical inputs | Y / N | stability test |
| Explanations agree with a second method (e.g. SHAP vs. permutation importance) at the global level | Y / N | comparison |
| Counterfactuals offered are actually attainable and do flip the outcome when applied | Y / N | counterfactual check |
| The explanation covers the whole pipeline, or its scope limit is disclosed | Y / N | scope note |
| Non-experts can act on the customer-facing version (tested with real users) | Y / N | user test |

### Worked example

| Check | Result | Evidence |
|---|---|---|
| Top-feature removal changes output | Y | mean score shift 0.7 band on removal |
| Stable across near-identical inputs | Y | rank change < 1 for 96% of pairs |
| Agrees with a second method globally | Y | top-5 features match permutation importance |
| Counterfactuals attainable and effective | Partial | 82% flip when applied; 18% blocked by interaction effects, disclosed |
| Whole-pipeline or scope disclosed | Y | scope limited to scoring head, stated |
| Non-experts can act on it | Y | 9/10 test users identified a next step |

### Acceptance criteria

- The method passed a perturbation or ablation test showing cited features actually drive the output.
- Explanation stability was measured, not assumed.
- The customer-facing version was tested with people who are not model experts.

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## Governance controls this kit produces evidence for

- **ALC-004**: The matrix, regulator document, and validation checklist are the explainability documentation for each system.
- **HOC-001**: The required explanation level is derived from each system's risk classification.
- **HOC-003**: Per-decision factor explanations are the information the output review workflow depends on.
- **CMP-007**: The regulator explanation document supplies the transparency evidence an EU AI Act conformity assessment requires.
- **ALC-002**: Worked-example explanations attached to decisions strengthen the high-risk audit trail.
