What triggers a legal right to an explanation?

Under GDPR Article 22, decisions based solely on automated processing that produce legal or similarly significant effects give people the right to meaningful information about the logic, plus human intervention. Higher-impact, fully automated decisions raise the bar.

Does the EU AI Act require explainability?

Yes, for many systems. High-risk AI systems must be transparent enough for users to interpret outputs and use them appropriately, and some systems must disclose to people that they are interacting with AI or seeing AI-generated content.

What is the difference between global and local explanations?

A global explanation describes how the model behaves in general (features, training, limitations). A local explanation tells an affected individual why their specific decision came out the way it did. Individual decisions usually need local explanations.

Is this legal advice?

No. It is a structured checklist based on published EU AI Act, GDPR, and ICO guidance to help you scope the work. Confirm obligations for your specific system with a qualified adviser.

We have a human reviewer — are we exempt?

Only if the human review is meaningful, not a rubber stamp. The reviewer must have authority and competence to override the system. Token oversight does not remove Article 22 obligations.

AI Explainability & Transparency Checklist

AI explainability & transparency checklist

If your AI system makes or supports decisions about people, you almost certainly owe them some level of explanation — and the amount depends on how impactful and how automated the decision is. This tool turns three questions about your system into a prioritised checklist of explainability and transparency requirements, mapped to the EU AI Act, GDPR Article 22, and UK ICO guidance, so you can see what is legally required versus good practice.

How it works

You select the decision type (informational, eligibility/access, financial/credit, employment, safety/health, or law-enforcement), the impact on the affected person, and how automated the decision is — from human-led with AI assistance through to fully automated with no human in the loop. The tool then assembles requirements: notice that AI is involved, the right to a meaningful explanation, local (individual) explanations, human-review and contest rights, documentation and model cards, and ongoing monitoring. Higher impact and fuller automation surface more, higher-priority items, especially the GDPR Article 22 safeguards.

Notes and priorities

Tackle the legally required items first: telling people AI is involved, providing meaningful information about the logic, and offering human intervention where Article 22 applies. A “human in the loop” only counts if that human can genuinely override the system — a rubber-stamp does not discharge the obligation. Document your reasoning either way: maintaining a model card, decision logs, and a record of the explainability measures you implemented is both an EU AI Act expectation and your best evidence of compliance.