Disclosure or Marketing? Analyzing the Efficacy of Vendor Self-reports for Vetting Public-sector AI

TL;DR

This study examines how vendor self-reports like FactSheets are used in public-sector AI procurement, revealing their strengths and limitations in fostering trust and accountability.

Contribution

It provides empirical insights into the production, interpretation, and practical use of AI disclosure artifacts in government contexts.

Findings

FactSheets serve multiple purposes, including showcasing offerings and supporting evaluation.

Structural constraints limit FactSheets' effectiveness as standalone risk tools.

When viewed as relational artifacts, FactSheets can foster trust and ongoing dialogue.

Abstract

Documentation-based disclosure has become a central governance strategy for responsible AI, particularly in public-sector procurement. Tools such as model cards, datasheets, and AI FactSheets are increasingly expected to support accountability, risk assessment, and informed decision-making across organizational boundaries. Yet there is limited empirical evidence about how these artifacts are produced, interpreted, and used in practice. In this paper, we present a qualitative study of the GovAI Coalition FactSheet, a widely adopted transparency document designed to support AI procurement and governance in government contexts. Drawing on semi-structured interviews with vendors and public-sector practitioners, alongside a systematic analysis of completed FactSheets, we examine how FactSheets are used, what information they surface, and where they fall short. We find that FactSheets are asked to serve multiple and conflicting purposes simultaneously: showcasing vendor offerings, supporting evaluation and due diligence, and facilitating early-stage dialogue between vendors and agencies. These competing expectations, combined with the structural constraints of voluntary and public self-disclosure, limit the ability of FactSheets to function as standalone evaluation or risk-assessment tools. At the same time, our findings suggest that when understood as relational artifacts used to establish trust, shared understanding, and ongoing dialogue, FactSheets can help create conditions that support more meaningful disclosure and governance over time.