Black-Box Access is Insufficient for Rigorous AI Audits
This addresses the problem of inadequate AI governance audits for policymakers and auditors, highlighting the need for improved access to ensure rigorous evaluations.
The paper examines the limitations of black-box audits for AI systems, arguing that white-box and outside-the-box access enable stronger attacks, better interpretation, and more thorough evaluations, concluding that transparency in audit methods and broader access are essential for effective scrutiny.
External audits of AI systems are increasingly recognized as a key mechanism for AI governance. The effectiveness of an audit, however, depends on the degree of access granted to auditors. Recent audits of state-of-the-art AI systems have primarily relied on black-box access, in which auditors can only query the system and observe its outputs. However, white-box access to the system's inner workings (e.g., weights, activations, gradients) allows an auditor to perform stronger attacks, more thoroughly interpret models, and conduct fine-tuning. Meanwhile, outside-the-box access to training and deployment information (e.g., methodology, code, documentation, data, deployment details, findings from internal evaluations) allows auditors to scrutinize the development process and design more targeted evaluations. In this paper, we examine the limitations of black-box audits and the advantages of white- and outside-the-box audits. We also discuss technical, physical, and legal safeguards for performing these audits with minimal security risks. Given that different forms of access can lead to very different levels of evaluation, we conclude that (1) transparency regarding the access and methods used by auditors is necessary to properly interpret audit results, and (2) white- and outside-the-box access allow for substantially more scrutiny than black-box access alone.