Making Things Explainable vs Explaining: Requirements and Challenges Under the GDPR

Abstract. The European Union (EU) through the High-Level Expert Group on Artificial Intelligence (AI-HLEG) and the General Data Protection Regulation (GDPR) has recently posed an interesting challenge to the eXplainable AI (XAI) community, by demanding a more user-centred approach to explain Automated Decision-Making systems (ADMs). Looking at the relevant literature, XAI is currently focused on producing explainable software and explanations that generally follow an approach we could term One-Size-Fits-All, that is unable to meet a requirement of centring on user needs. One of the causes of this limit is the belief that making things explainable alone is enough to have pragmatic explanations. Thus, insisting on a clear separation between explainabilty (something that can be explained) and explanations, we point to explanatorY AI (YAI) as an alternative and more powerful approach to win the AI-HLEG challenge. YAI builds over XAI with the goal to collect and organize explainable information, articulating it into something we called user-centred explanatory discourses. Through the use of explanatory discourses/narratives we represent the problem of generating explanations for Automated Decision-Making systems (ADMs) into the identification of an appropriate path over an explanatory space, allowing explainees to interactively explore it and produce the explanation best suited to their needs.