AR
arXiv CS.AI
8/5/2026

Explainable AI for the EU Right to Explanation: A Systematic Review of the Law-XAI Translation Gap
Short summary
This systematic review examines whether Explainable AI can satisfy the EU Right to Explanation under GDPR Art. 15(1)(h) and AI Act Art. 86. Of 57 reviewed papers, only 19 substantively integrate both legal and technical perspectives. The authors identify three recurring problems: misidentification of GDPR legal basis, lack of engagement with the Dun & Bradstreet judgment, and conflation of explanation form versus content. They propose an Addressee/Purpose Framework and a four-phase operationalization blueprint with six open research questions.
- •Only 19 of 57 reviewed papers meaningfully bridge legal and technical XAI perspectives
- •Common errors include misidentifying GDPR legal basis and conflating explanation form vs. content
- •Proposes Addressee/Purpose Framework and four-phase compliance blueprint
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