# Does Accountability Require Agency? Comment on Responsibility and Accountability in the Algorithmic Society

## TL;DR

This paper discusses whether accountability in algorithmic systems requires agency, commenting on a prior work about responsibility and accountability.

## Contribution

The paper highlights an ambiguity in the concept of accountability and explores its implications when applied to algorithmic systems.

## Key findings

- Accountability can be seen as purely instrumental or as involving agent scaffolding.
- The distinction affects how responsibility is assigned in algorithmic systems.
- The ambiguity in accountability's definition has significant ethical and practical consequences.

## Abstract

In their intriguing paper Responsibility and Accountability in an Algorithmic Society (2025) the authors argue that the debate on how to deal with responsibility related issues with algorithmic agents requires a distinction between responsibility and accountability. In this comment to their paper, it is argued that while the notion of accountability as understood by the authors brings some significant benefits it also is ambiguous in an important way. Accountability could be understood as being purely instrumental with regard to general morally desirable consequences or it could be understood as necessarily containing an element of scaffolding for the agent who is held to account. The comment develops the options and discusses the consequences of choosing either of them.