Source: SSRN

This systematic literature review examines the socio-legal frameworks governing artificial intelligence (AI) transparency in the European Union (EU) and the United Kingdom (UK). The study highlights the critical importance of transparency in mitigating risks associated with opaque AI systems, such as unfair outcomes, privacy violations, and lack of accountability.

Post-Brexit, the EU and UK have adopted divergent approaches to AI regulation. The EU employs a tiered, risk-based framework, while the UK adopts a more flexible, sector-specific strategy. The review categorizes its findings into five themes: the necessity of transparency, challenges in achieving it, governance techniques, transparency laws, and soft law toolkits.

The study advocates for a comprehensive organizational approach to embedding transparency, emphasizing the need for cultural and operational alignment within companies. It also promotes the development of AI transparency toolkits, particularly for small and medium-sized enterprises (SMEs), to address socio-technical barriers and ensure practical implementation of transparency in diverse contexts.