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AI Transparency in Trustworthy AI : From Metaphor to Governance Tool in EU Technology Regulation

Söderlund, Kasia LU (2025)
Abstract
Transparency has emerged as a fundamental component of ethical AI guidelines around the world. In the European Union (EU), it is recognised as one of the core principles for fostering Trustworthy AI, and serves as a cornerstone in building an ecosystem of trust within the AI governance framework.

However, to support these ambitious policy objectives, the concept of transparency must be translated into clearly defined and implementable measures. Thus, by employing a combination of legal-doctrinal and socio-legal approaches, this compilation thesis aims to contribute to a clarified understanding of the concept of AI transparency in the EU’s AI governance discourses. I examine the concept of AI transparency across four levels of... (More)
Transparency has emerged as a fundamental component of ethical AI guidelines around the world. In the European Union (EU), it is recognised as one of the core principles for fostering Trustworthy AI, and serves as a cornerstone in building an ecosystem of trust within the AI governance framework.

However, to support these ambitious policy objectives, the concept of transparency must be translated into clearly defined and implementable measures. Thus, by employing a combination of legal-doctrinal and socio-legal approaches, this compilation thesis aims to contribute to a clarified understanding of the concept of AI transparency in the EU’s AI governance discourses. I examine the concept of AI transparency across four levels of abstraction: as a stand-alone objective, as a governance ideal, as a governance tool, and as a ‘floating signifier’. Focusing in particular on AI transparency as a governance ideal and as a governance tool in relation to the EU’s policymaking objective of Trustworthy AI, I analyse how AI transparency has been conceptualised, designed, and implemented for two stakeholder groups — individuals and oversight bodies — within the governance frameworks of the General Data Protection Regulation (GDPR), the Digital Services Act (DSA), and the Artificial Intelligence Act (AIA).

The main argument advanced in the thesis is that while AI transparency directed at individuals (understood as data subjects, service recipients, and natural persons) remains relevant, it is the effectiveness of oversight-oriented AI transparency that is crucial to the enforcement of the EU technology regulation and is, ultimately, foundational in the EU’s pursuit of Trustworthy AI. Although transparency is central to the EU’s vision for Trustworthy AI, its effectiveness depends on how legal obligations are interpreted, implemented, and enforced in practice.
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author
supervisor
opponent
  • Assoc. Prof. Enqvist, Lena, Umeå University, Sweden.
organization
publishing date
type
Thesis
publication status
published
subject
keywords
Transparency, Artificial intelligence, AI, AI transparency, Trustworthy AI, European Union, EU, AI Act, Digital Services Act, General Data Protection Regulation, GDPR
pages
155 pages
publisher
Department of Technology and Society, Lund University
defense location
Lecture Hall E:1406, building E, Klas Anshelms väg 10, Faculty of Engineering LTH, Lund University, Lund.
defense date
2025-06-10 09:15:00
ISBN
978-91-8104-550-5
978-91-8104-549-9
language
English
LU publication?
yes
id
ef074d8e-1073-45a4-9342-c73dee5783f3
date added to LUP
2025-05-08 12:07:13
date last changed
2025-06-30 18:09:26
@phdthesis{ef074d8e-1073-45a4-9342-c73dee5783f3,
  abstract     = {{Transparency has emerged as a fundamental component of ethical AI guidelines around the world. In the European Union (EU), it is recognised as one of the core principles for fostering Trustworthy AI, and serves as a cornerstone in building an ecosystem of trust within the AI governance framework.<br/><br/>However, to support these ambitious policy objectives, the concept of transparency must be translated into clearly defined and implementable measures. Thus, by employing a combination of legal-doctrinal and socio-legal approaches, this compilation thesis aims to contribute to a clarified understanding of the concept of AI transparency in the EU’s AI governance discourses. I examine the concept of AI transparency across four levels of abstraction: as a stand-alone objective, as a governance ideal, as a governance tool, and as a ‘floating signifier’. Focusing in particular on AI transparency as a governance ideal and as a governance tool in relation to the EU’s policymaking objective of Trustworthy AI, I analyse how AI transparency has been conceptualised, designed, and implemented for two stakeholder groups — individuals and oversight bodies — within the governance frameworks of the General Data Protection Regulation (GDPR), the Digital Services Act (DSA), and the Artificial Intelligence Act (AIA).<br/><br/>The main argument advanced in the thesis is that while AI transparency directed at individuals (understood as data subjects, service recipients, and natural persons) remains relevant, it is the effectiveness of oversight-oriented AI transparency that is crucial to the enforcement of the EU technology regulation and is, ultimately, foundational in the EU’s pursuit of Trustworthy AI. Although transparency is central to the EU’s vision for Trustworthy AI, its effectiveness depends on how legal obligations are interpreted, implemented, and enforced in practice.<br/>}},
  author       = {{Söderlund, Kasia}},
  isbn         = {{978-91-8104-550-5}},
  keywords     = {{Transparency; Artificial intelligence; AI; AI transparency; Trustworthy AI; European Union; EU; AI Act; Digital Services Act; General Data Protection Regulation; GDPR}},
  language     = {{eng}},
  month        = {{06}},
  publisher    = {{Department of Technology and Society, Lund University}},
  school       = {{Lund University}},
  title        = {{AI Transparency in Trustworthy AI : From Metaphor to Governance Tool in EU Technology Regulation}},
  url          = {{https://lup.lub.lu.se/search/files/218764646/KSo_derlund_PhD_Thesis_frame_electronic_version.pdf}},
  year         = {{2025}},
}