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Ethics & Regulation

Explainable AI (XAI): Why Algorithmic Transparency Becomes Mandatory in 2026

Explainable AI (XAI): Why Algorithmic Transparency Becomes Mandatory in 2026
Guillaume Hochard
2026-01-08
7 min

Key takeaways: The AI Act mandates algorithmic transparency for high-risk AI systems in recruitment, credit scoring, public services, judicial support, and medical devices, with fines up to 35 million euros or 7% of global revenue for non-compliance. Explainability operates at three levels: global explainability showing which features matter most overall, local explainability using SHAP and LIME to justify individual decisions, and counterfactual explainability telling users what to change for a different outcome. A finance case study showed that adding SHAP-based explanations to credit scoring reduced customer complaints by 40% while achieving AI Act compliance. In healthcare, Grad-CAM visualization on diagnostic imaging achieved 85% radiologist adoption compared to 30% without explainability and reduced diagnostic time by 35%. Implementation follows a five-phase roadmap: audit and classification of AI systems in weeks one and two, XAI technique selection in weeks three and four, library integration in weeks five through eight, user testing and legal validation in weeks nine and ten, then production deployment with ongoing monitoring. Ikasia offers XAI audits for AI Act compliance and explainable AI training for decision-makers.

The era of "black box" AI is coming to an end. With the first AI Act obligations coming into force in 2025 and reinforcement planned for 2026, algorithmic transparency shifts from "nice to have" to "must have". But how do you make explainable a deep learning model with millions of parameters?

What is Explainable AI (XAI)?

Explainable AI (eXplainable AI or XAI) refers to all techniques enabling understanding, interpretation, and justification of decisions made by an artificial intelligence system.

Formal definition: An AI system is said to be "explainable" if it can provide justifications understandable by a human for its predictions or decisions.

Why Explainability is Critical

1. Regulatory Compliance The European AI Act requires that "high-risk" systems be transparent and interpretable. Fines can reach 35 million euros or 7% of global revenue.

2. User Trust According to multiple surveys, a majority of consumers are reluctant to use an AI service if they don't understand how decisions are made.

3. Bias Detection Without explainability, it's impossible to detect if a model discriminates against certain populations (gender, origin, age).

4. Audit and Accountability In case of litigation, the company must be able to explain why AI made a specific decision.


AI Act Explainability Requirements

The AI Act classifies AI systems into 4 risk levels. Explainability obligations vary by level:

High-Risk Systems

Affected domains:

  • Recruitment and HR management
  • Credit scoring and insurance
  • Access to public services
  • Judicial and police systems
  • Medical devices

Specific obligations (Article 13):

  • Detailed technical documentation
  • Decision logging
  • Output explainability: the user must understand how the decision was made
  • Human override possibility (human oversight)

Limited Risk Systems

Affected domains:

  • Chatbots
  • Recommendation systems

Obligations:

  • Inform the user they're interacting with an AI
  • General operation transparency (no technical detail required)

The 3 Levels of Explainability

Explainability is not binary. We distinguish three depth levels:

1. Global Explainability

Question: "How does the model generally work?"

It aims to understand the model's general behavior: which features are most important? What are the general decision rules?

Techniques:

  • Global Feature Importance
  • Simplified decision trees (surrogate models)
  • Model weight analysis

Example: "This credit scoring model assigns 35% importance to income, 25% to payment history, 20% to account age..."

2. Local Explainability

Question: "Why was this specific decision made?"

It explains an individual prediction for a specific case.

Techniques:

  • LIME (Local Interpretable Model-agnostic Explanations)
  • SHAP (SHapley Additive exPlanations)
  • Attention Maps (for transformers)

Example: "For this specific customer, credit was denied mainly because their debt-to-income ratio (contribution: -42%) and late payment history (contribution: -31%) weighed negatively."

3. Counterfactual Explainability

Question: "What would need to change to get a different decision?"

This is the most actionable form for the end user.

Techniques:

  • Counterfactual generation
  • What-if analysis

Example: "If your monthly income were €500 higher, or if you hadn't had a late payment in the last 6 months, your application would have been accepted."


XAI Techniques: SHAP, LIME and Attention Maps

SHAP (SHapley Additive exPlanations)

Principle: Based on game theory (Shapley values), SHAP calculates each feature's contribution to the final prediction.

Advantages:

  • Solid mathematical foundation
  • Guaranteed consistency and precision
  • Intuitive visualizations

Limits:

  • High computational cost for large models
  • Can be complex to interpret for non-experts

Example code (Python):

python
import shap

# Load model and data
explainer = shap.TreeExplainer(model)
shap_values = explainer.shap_values(X_test)

# Visualization
shap.summary_plot(shap_values, X_test)

LIME (Local Interpretable Model-agnostic Explanations)

Principle: LIME perturbs inputs around a prediction and observes how the model reacts, then creates a local linear model to approximate behavior.

Advantages:

  • Model agnostic (works with any ML)
  • Fast to compute
  • Easy to understand

Limits:

  • Local approximation (not always faithful to true model)
  • Results can vary depending on sampling

Attention Maps (for LLMs and Vision)

Principle: Visualize where the model "looks" to make its decision.

For LLMs: Which tokens in the prompt most influence the response?

For vision: Which image areas are determinant?

Advantages:

  • Intuitively understandable
  • Native to Transformer architectures

Limits:

  • Doesn't always capture true decision reasons
  • Can be manipulated (adversarial attention)

XAI for LLMs: The Generative Explainability Challenge

LLMs (ChatGPT, Claude, etc.) pose a particular challenge: how do you explain why a model with 175 billion parameters generates a specific response?

Current Approaches

1. Chain-of-Thought (CoT) Ask the LLM to explain its reasoning step by step.

text
Prompt: "Explain your reasoning step by step before giving your answer."

Limit: The LLM can "hallucinate" post-hoc justifications that don't reflect its true process.

2. Probing and Layer Analysis Analyze the model's internal representations at different layers to understand what it really "knows."

3. Constitutional AI (Anthropic) Claude uses explicit constitutional principles that guide and constrain its responses.

The Challenge: Explainability vs Performance

There's often a trade-off between explainability and performance:

  • The most performant models (deep learning) are the least interpretable
  • Interpretable models (decision trees, logistic regression) are often less accurate

2026 Solution: Hybrid models combining deep learning performance with explainability layers.


Case Study: XAI in Finance and Healthcare

Finance: Explainable Credit Scoring

Context (illustrative scenario): A European bank must justify its credit decisions according to the AI Act.

Deployed solution:

  1. XGBoost model for prediction (performance)
  2. SHAP layer for local explainability
  3. User interface showing the 3 main decision factors
  4. Automatic counterfactual generation ("what to do to improve my score")

Result:

  • AI Act compliance achieved
  • 40% reduction in customer complaints (they understand decisions)
  • Improved application quality (customers correct negative factors)

Healthcare: Explainable Diagnostic Aid

Context (illustrative scenario): A radiological diagnostic aid tool must be auditable by doctors.

Deployed solution:

  1. Vision model (CNN) for anomaly detection
  2. Grad-CAM to visualize analyzed image areas
  3. Auto-generated report listing detected visual indicators
  4. Confidence score with explanation of uncertainty cases

Result:

  • Class IIa medical device certification
  • 85% radiologist adoption rate (vs 30% without explainability)
  • 35% reduced diagnostic time

Roadmap for Implementing Explainable AI

Phase 1: Audit (Weeks 1-2)

  1. Inventory of AI systems in production
  2. Classification according to AI Act (high, limited, minimal risk)
  3. Gap identification for current explainability

Phase 2: Design (Weeks 3-4)

  1. Define required explainability level (global, local, counterfactual)
  2. Choose XAI techniques suited to each model
  3. Design interfaces to present explanations

Phase 3: Implementation (Weeks 5-8)

  1. Integrate XAI libraries (SHAP, LIME, Captum...)
  2. Develop explainability layers for each model
  3. Create dashboards for monitoring and audit

Phase 4: Validation (Weeks 9-10)

  1. User tests: Are explanations understood?
  2. Legal audit: AI Act compliance validated?
  3. Technical documentation for regulators

Phase 5: Production and Monitoring

  1. Progressive deployment
  2. Explanation quality monitoring
  3. Continuous improvement based on feedback

Recommended XAI Tools and Frameworks

ToolTypeSupported ModelsEase
SHAPPythonAll⭐⭐⭐⭐
LIMEPythonAll⭐⭐⭐⭐⭐
CaptumPyTorchDeep Learning⭐⭐⭐
What-If ToolTensorFlowTF models⭐⭐⭐⭐
AlibiPythonAll⭐⭐⭐
InterpretMLMicrosoftAll⭐⭐⭐⭐

Our XAI Support

At Ikasia, we support companies in their explainable AI journey:

XAI Audit and AI Act Compliance (2 days)

  • Inventory and classification of your AI systems
  • Explainability gap analysis
  • Compliance roadmap

"Explainable AI for Decision Makers" Training (1 day)

  • Understanding transparency challenges
  • Knowing how to challenge technical teams
  • Communicating about explainability to stakeholders

Conclusion

Explainable AI is no longer optional in 2026. Between AI Act requirements, user demand for more transparency, and the need to detect biases, mastering XAI becomes a strategic skill.

The good news: tools exist, methods are mature, and early feedback shows that explainability improves not only compliance but also adoption and quality of AI systems.

Start by auditing your current systems, identify those requiring explainability, and integrate XAI techniques suited to each use case.


Enjoyed this article? Check out our Generative AI Workshop — 3.5h hands-on session to master the tool with your team.

Tags

XAI Transparency AI Act Governance AI Ethics

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