Are Algorithm Registers Transparent? Perspectives from Germany
For policymakers and practitioners designing or auditing algorithm transparency registers, this work provides a concrete evaluation framework and reveals gaps in existing German initiatives.
The paper audits two German algorithm registers (MaKI and Lernende Systeme) using a framework derived from a recent proposal, finding that several adaptations are needed for them to serve as useful transparency instruments.
Algorithm registers are public-facing databases that display basic information about algorithms employed in public administration. While several such registers exist across Europe and globally, their capacity to deliver meaningful transparency remains contested. In Germany, the landscape is notably fragmented: no federal-level register exists, yet at least five state- and federal-level initiatives publish information about AI systems with varying scopes and objectives. A recent conceptual proposal by Alina Lorenz (2025), outlines technical and governance requirements for a national AI transparency register in Germany. We repurpose this proposal as an audit instrument, extracting structured checklists from the transparency goals and subgoals it formulates. The resulting checklists, translated from German into English, is made publicly available to support practitioners auditing existing registers or designing new ones. We apply this framework to conduct an external audit of the two main existing German transparency initiatives, MaKI and Lernende Systeme, evaluating the extent to which they fulfill the proposed goals. Our audit reveals that several adaptations are likely needed for these registers to serve as an useful transparency instrument. We further propose a visualization of register transparency levels and derive concrete action items for improving existing German platforms.