Ethics-based auditing of automated decision-making systems: considerations, challenges, na

Decisions impacting human lives and livelihoods are increasingly being automated. While the use of automated decision-making systems (ADMS) improves efficiency, it is coupled with ethical risks. Previous research has pointed towards ethics-based auditing (EBA) as a promising governance mechanism for managing the ethical risks ADMS pose. However, the affordances and limitations of EBA have yet to be substantiated by empirical research. This thesis seeks to clarify and resolve fundamental questions surrounding EBA. What are the limitations of EBA? How can feasible and effective EBA procedures be designed? These questions are approached on three levels. The conceptual level concerns what EBA is and how it works. The descriptive level focuses on the challenges organisations face when implementing EBA. The applied level concerns how to design EBA procedures that are feasible and effective in practice. This is an integrated thesis, in which the substantive chapters (3–7) are based on published journal articles. Chapter 3 provides a theoretical explanation of how EBA contributes to good governance; Chapter 4 presents new empirical data from a case study of a real-world EBA implementation; Chapter 5 analyses the role of auditing in the proposed EU AI Act; Chapter 6 provides guidance on how to demarcate the material scope of EBA; and Chapter 7 outlines a blueprint for how to audit ADMS with highly general capabilities. My findings suggest that EBA is subject to significant conceptual, technical, and institutional limitations. However, they also indicate that EBA – if properly designed and implemented – helps organisations identify and mitigate some of the ethical risks ADMS pose. I conclude by providing recommendations for how researchers, industry practitioners, auditors, and policymakers can facilitate the emergence of feasible and effective EBA procedures. This thesis thereby serves the purpose of better equipping societies to reap the benefits of ADMS while managing the associated risks