COMPL-AI Framework: A Technical Interpretation and LLM Benchmarking Suite for the EU Artificial Intelligence Act

The EU's Artificial Intelligence Act (AI Act) is a significant step towards responsible AI development, but lacks clear technical interpretation, making it difficult to assess models' compliance. This work presents COMPL-AI, a comprehensive framework consisting of (i) the first technical interpretation of the EU AI Act, translating its broad regulatory requirements into measurable technical requirements, with the focus on large language models (LLMs), and (ii) an open-source Act-centered benchmarking suite, based on thorough surveying and implementation of state-of-the-art LLM benchmarks. By evaluating 12 prominent LLMs in the context of COMPL-AI, we reveal shortcomings in existing models and benchmarks, particularly in areas like robustness, safety, diversity, and fairness. This work highlights the need for a shift in focus towards these aspects, encouraging balanced development of LLMs and more comprehensive regulation-aligned benchmarks. Simultaneously, COMPL-AI for the first time demonstrates the possibilities and difficulties of bringing the Act's obligations to a more concrete, technical level. As such, our work can serve as a useful first step towards having actionable recommendations for model providers, and contributes to ongoing efforts of the EU to enable application of the Act, such as the drafting of the GPAI Code of Practice.

Ward: Provable RAG Dataset Inference via LLM Watermarks

Retrieval-Augmented Generation (RAG) improves LLMs by enabling them to incorporate external data during generation. This raises concerns for data owners regarding unauthorized use of their content in RAG systems. Despite its importance, the challenge of detecting such unauthorized usage remains underexplored, with existing datasets and methodologies from adjacent fields being ill-suited for its study. In this work, we take several steps to bridge this gap. First, we formalize this problem as (black-box) RAG Dataset Inference (RAG-DI). To facilitate research on this challenge, we further introduce a novel dataset specifically designed for benchmarking RAG-DI methods under realistic conditions, and propose a set of baseline approaches. Building on this foundation, we introduce Ward, a RAG-DI method based on LLM watermarks that enables data owners to obtain rigorous statistical guarantees regarding the usage of their dataset in a RAG system. In our experimental evaluation, we show that Ward consistently outperforms all baselines across many challenging settings, achieving higher accuracy, superior query efficiency and robustness. Our work provides a foundation for future studies of RAG-DI and highlights LLM watermarks as a promising approach to this problem.

Discovering Clues of Spoofed LM Watermarks

LLM watermarks stand out as a promising way to attribute ownership of LLM-generated text. One threat to watermark credibility comes from spoofing attacks, where an unauthorized third party forges the watermark, enabling it to falsely attribute arbitrary texts to a particular LLM. While recent works have demonstrated that state-of-the-art schemes are in fact vulnerable to spoofing, they lack deeper qualitative analysis of the texts produced by spoofing methods. In this work, we for the first time reveal that there are observable differences between genuine and spoofed watermark texts. Namely, we show that regardless of their underlying approach, all current spoofing methods consistently leave observable artifacts in spoofed texts, indicative of watermark forgery. We build upon these findings to propose rigorous statistical tests that reliably reveal the presence of such artifacts, effectively discovering that a watermark was spoofed. Our experimental evaluation shows high test power across all current spoofing methods, providing insights into their fundamental limitations, and suggesting a way to mitigate this threat.

Back to the Drawing Board for Fair Representation Learning

The goal of Fair Representation Learning (FRL) is to mitigate biases in machine learning models by learning data representations that enable high accuracy on downstream tasks while minimizing discrimination based on sensitive attributes. The evaluation of FRL methods in many recent works primarily focuses on the tradeoff between downstream fairness and accuracy with respect to a single task that was used to approximate the utility of representations during training (proxy task). This incentivizes retaining only features relevant to the proxy task while discarding all other information. In extreme cases, this can cause the learned representations to collapse to a trivial, binary value, rendering them unusable in transfer settings. In this work, we argue that this approach is fundamentally mismatched with the original motivation of FRL, which arises from settings with many downstream tasks unknown at training time (transfer tasks). To remedy this, we propose to refocus the evaluation protocol of FRL methods primarily around the performance on transfer tasks. A key challenge when conducting such an evaluation is the lack of adequate benchmarks. We address this by formulating four criteria that a suitable evaluation procedure should fulfill. Based on these, we propose TransFair, a benchmark that satisfies these criteria, consisting of novel variations of popular FRL datasets with carefully calibrated transfer tasks. In this setting, we reevaluate state-of-the-art FRL methods, observing that they often overfit to the proxy task, which causes them to underperform on certain transfer tasks. We further highlight the importance of task-agnostic learning signals for FRL methods, as they can lead to more transferrable representations.

Watermark Stealing in Large Language Models

LLM watermarking has attracted attention as a promising way to detect AI-generated content, with some works suggesting that current schemes may already be fit for deployment. In this work we dispute this claim, identifying watermark stealing (WS) as a fundamental vulnerability of these schemes. We show that querying the API of the watermarked LLM to approximately reverse-engineer a watermark enables practical spoofing attacks, as suggested in prior work, but also greatly boosts scrubbing attacks, which was previously unnoticed. We are the first to propose an automated WS algorithm and use it in the first comprehensive study of spoofing and scrubbing in realistic settings. We show that for under $50 an attacker can both spoof and scrub state-of-the-art schemes previously considered safe, with average success rate of over 80%. Our findings challenge common beliefs about LLM watermarking, stressing the need for more robust schemes. We make all our code and additional examples available at https://watermark-stealing.org.

From Principle to Practice: Vertical Data Minimization for Machine Learning

Aiming to train and deploy predictive models, organizations collect large amounts of detailed client data, risking the exposure of private information in the event of a breach. To mitigate this, policymakers increasingly demand compliance with the data minimization (DM) principle, restricting data collection to only that data which is relevant and necessary for the task. Despite regulatory pressure, the problem of deploying machine learning models that obey DM has so far received little attention. In this work, we address this challenge in a comprehensive manner. We propose a novel vertical DM (vDM) workflow based on data generalization, which by design ensures that no full-resolution client data is collected during training and deployment of models, benefiting client privacy by reducing the attack surface in case of a breach. We formalize and study the corresponding problem of finding generalizations that both maximize data utility and minimize empirical privacy risk, which we quantify by introducing a diverse set of policy-aligned adversarial scenarios. Finally, we propose a range of baseline vDM algorithms, as well as Privacy-aware Tree (PAT), an especially effective vDM algorithm that outperforms all baselines across several settings. We plan to release our code as a publicly available library, helping advance the standardization of DM for machine learning. Overall, we believe our work can help lay the foundation for further exploration and adoption of DM principles in real-world applications.

Hiding in Plain Sight: Disguising Data Stealing Attacks in Federated Learning

Malicious server (MS) attacks have enabled the scaling of data stealing in federated learning to large batch sizes and secure aggregation, settings previously considered private. However, many concerns regarding client-side detectability of MS attacks were raised, questioning their practicality once they are publicly known. In this work, for the first time, we thoroughly study the problem of client-side detectability.We demonstrate that most prior MS attacks, which fundamentally rely on one of two key principles, are detectable by principled client-side checks. Further, we formulate desiderata for practical MS attacks and propose SEER, a novel attack framework that satisfies all desiderata, while stealing user data from gradients of realistic networks, even for large batch sizes (up to 512 in our experiments) and under secure aggregation. The key insight of SEER is the use of a secret decoder, which is jointly trained with the shared model. Our work represents a promising first step towards more principled treatment of MS attacks, paving the way for realistic data stealing that can compromise user privacy in real-world deployments.

Private and Reliable Neural Network Inference

Reliable neural networks (NNs) provide important inference-time reliability guarantees such as fairness and robustness. Complementarily, privacy-preserving NN inference protects the privacy of client data. So far these two emerging areas have been largely disconnected, yet their combination will be increasingly important. In this work, we present the first system which enables privacy-preserving inference on reliable NNs. Our key idea is to design efficient fully homomorphic encryption (FHE) counterparts for the core algorithmic building blocks of randomized smoothing, a state-of-the-art technique for obtaining reliable models. The lack of required control flow in FHE makes this a demanding task, as na\"ive solutions lead to unacceptable runtime. We employ these building blocks to enable privacy-preserving NN inference with robustness and fairness guarantees in a system called Phoenix. Experimentally, we demonstrate that Phoenix achieves its goals without incurring prohibitive latencies. To our knowledge, this is the first work which bridges the areas of client data privacy and reliability guarantees for NNs.

FARE: Provably Fair Representation Learning

Fair representation learning (FRL) is a popular class of methods aiming to produce fair classifiers via data preprocessing. However, recent work has shown that prior methods achieve worse accuracy-fairness tradeoffs than originally suggested by their results. This dictates the need for FRL methods that provide provable upper bounds on unfairness of any downstream classifier, a challenge yet unsolved. In this work we address this challenge and propose Fairness with Restricted Encoders (FARE), the first FRL method with provable fairness guarantees. Our key insight is that restricting the representation space of the encoder enables us to derive suitable fairness guarantees, while allowing empirical accuracy-fairness tradeoffs comparable to prior work. FARE instantiates this idea with a tree-based encoder, a choice motivated by inherent advantages of decision trees when applied in our setting. Crucially, we develop and apply a practical statistical procedure that computes a high-confidence upper bound on the unfairness of any downstream classifier. In our experimental evaluation on several datasets and settings we demonstrate that FARE produces tight upper bounds, often comparable with empirical results of prior methods, which establishes the practical value of our approach.

LAMP: Extracting Text from Gradients with Language Model Priors

Recent work shows that sensitive user data can be reconstructed from gradient updates, breaking the key privacy promise of federated learning. While success was demonstrated primarily on image data, these methods do not directly transfer to other domains such as text. In this work, we propose LAMP, a novel attack tailored to textual data, that successfully reconstructs original text from gradients. Our key insight is to model the prior probability of the text with an auxiliary language model, utilizing it to guide the search towards more natural text. Concretely, LAMP introduces a discrete text transformation procedure that minimizes both the reconstruction loss and the prior text probability, as provided by the auxiliary language model. The procedure is alternated with a continuous optimization of the reconstruction loss, which also regularizes the length of the reconstructed embeddings. Our experiments demonstrate that LAMP reconstructs the original text significantly more precisely than prior work: we recover 5x more bigrams and $23\%$ longer subsequences on average. Moreover, we are first to recover inputs from batch sizes larger than 1 for textual models. These findings indicate that gradient updates of models operating on textual data leak more information than previously thought.