new

Get trending papers in your email inbox!

Subscribe

Daily Papers

byAK and the research community

Jul 9

Hugging Carbon: Quantifying the Training Carbon Emissions of AI Models at Scale

The scaling-law era has transformed artificial intelligence (AI) from research into a global industry, but its rapid growth also raises concerns over energy usage, carbon emissions, and environmental sustainability. Unlike traditional sectors, the AI industry still lacks systematic carbon accounting methods that support large-scale estimates without reproducing the original training process. This leaves open questions about how large the problem is today and how large it might be in the near future. Given its central role in hosting open-source AI models, the Hugging Face (HF) platform provides a large-scale and publicly accessible corpus for carbon accounting. We estimate aggregate training emissions of HF open-source models using available emissions, energy, compute, and model metadata. To address uneven disclosure quality, we introduce a tiered approach to handle incomplete metadata, supported by empirical regressions that assess estimation reliability. We further introduce AI training carbon intensity (ATCI, emissions per compute), a metric to assess the sustainability efficiency of model training. Our results show that training the most popular open-source models (with over 5,000 downloads) has already resulted in approximately 6.0times10^4 metric tons of carbon emissions. Overall, this paper provides a scalable, empirically grounded framework for estimating training emissions from incomplete disclosures and informing future carbon reporting standards in the AI industry. Data and code are available at https://github.com/insait-institute/HuggingCarbon.

  • 5 authors
·
Jul 1

Exploring the Carbon Footprint of Hugging Face's ML Models: A Repository Mining Study

The rise of machine learning (ML) systems has exacerbated their carbon footprint due to increased capabilities and model sizes. However, there is scarce knowledge on how the carbon footprint of ML models is actually measured, reported, and evaluated. In light of this, the paper aims to analyze the measurement of the carbon footprint of 1,417 ML models and associated datasets on Hugging Face, which is the most popular repository for pretrained ML models. The goal is to provide insights and recommendations on how to report and optimize the carbon efficiency of ML models. The study includes the first repository mining study on the Hugging Face Hub API on carbon emissions. This study seeks to answer two research questions: (1) how do ML model creators measure and report carbon emissions on Hugging Face Hub?, and (2) what aspects impact the carbon emissions of training ML models? The study yielded several key findings. These include a stalled proportion of carbon emissions-reporting models, a slight decrease in reported carbon footprint on Hugging Face over the past 2 years, and a continued dominance of NLP as the main application domain. Furthermore, the study uncovers correlations between carbon emissions and various attributes such as model size, dataset size, and ML application domains. These results highlight the need for software measurements to improve energy reporting practices and promote carbon-efficient model development within the Hugging Face community. In response to this issue, two classifications are proposed: one for categorizing models based on their carbon emission reporting practices and another for their carbon efficiency. The aim of these classification proposals is to foster transparency and sustainable model development within the ML community.

  • 4 authors
·
May 18, 2023

SSKG Hub: An Expert-Guided Platform for LLM-Empowered Sustainability Standards Knowledge Graphs

Sustainability disclosure standards (e.g., GRI, SASB, TCFD, IFRS S2) are comprehensive yet lengthy, terminology-dense, and highly cross-referential, hindering structured analysis and downstream use. We present SSKG Hub (Sustainability Standards Knowledge Graph Hub), a research prototype and interactive web platform that transforms standards into auditable knowledge graphs (KGs) through an LLM-centered, expert-guided pipeline. The system integrates automatic standard identification, configurable chunking, standard-specific prompting, robust triple parsing, and provenance-aware Neo4j storage with fine-grained audit metadata. LLM extraction produces a provenance-linked Draft KG, which is reviewed, curated, and formally promoted to a Certified KG through meta-expert adjudication. A role-based governance framework covering read-only guest access, expert review and CRUD operations, meta-expert certification, and administrative oversight ensures traceability and accountability across draft and certified states. Beyond graph exploration and triple-level evidence tracing, SSKG Hub supports cross-KG fusion, KG-driven tasks, and dedicated modules for insights and curated resources. We validate the platform through a comprehensive expert-led KG review case study that demonstrates end-to-end curation and quality assurance. The web application is publicly available at www.sskg-hub.com.

  • 13 authors
·
Feb 27

FLARE-AI: Flaw Reporting for AI

Flaw reporting for deployed AI systems is fundamental to identifying system failures and improving AI safety. Yet the AI reporting ecosystem is fragmented: researchers who identify flaws often do not know what or where to report, and groups who receive reports rarely share them with other relevant stakeholders. As a result, good-faith reporters duplicate effort by submitting many different forms, and recipients lack standardized, triage-ready information. We audit 12 reporting systems published by AI developers, cybersecurity groups, and AI flaw aggregators, identifying five recurring design challenges spanning discoverability, scope, information collection, coordination, and guidance for strict-liability cases. Building on this analysis and feedback from 49 experts across 32 organizations representing developers, security researchers, and ecosystem coordinators, we introduce FLARE-AI, an open-source AI flaw reporting system designed for interoperability with existing systems. FLARE-AI streamlines flaw report creation by collecting triage-relevant information through conditional logic and early classification, then enables optional dissemination of standardized, machine-readable reports to multiple developers, coordinators, and incident registries from a single submission. By lowering barriers to reporting AI flaws and improving interoperability across stakeholders, FLARE-AI helps break down silos and accelerate remediation across the AI ecosystem.

  • 18 authors
·
Jun 29

Group Reasoning Emission Estimation Networks

Accurate greenhouse gas (GHG) emission reporting is critical for governments, businesses, and investors. However, adoption remains limited particularly among small and medium enterprises due to high implementation costs, fragmented emission factor databases, and a lack of robust sector classification methods. To address these challenges, we introduce Group Reasoning Emission Estimation Networks (GREEN), an AI-driven carbon accounting framework that standardizes enterprise-level emission estimation, constructs a large-scale benchmark dataset, and leverages a novel reasoning approach with large language models (LLMs). Specifically, we compile textual descriptions for 20,850 companies with validated North American Industry Classification System (NAICS) labels and align these with an economic model of carbon intensity factors. By reframing sector classification as an information retrieval task, we fine-tune Sentence-BERT models using a contrastive learning loss. To overcome the limitations of single-stage models in handling thousands of hierarchical categories, we propose a Group Reasoning method that ensembles LLM classifiers based on the natural NAICS ontology, decomposing the task into multiple sub-classification steps. We theoretically prove that this approach reduces classification uncertainty and computational complexity. Experiments on 1,114 NAICS categories yield state-of-the-art performance (83.68% Top-1, 91.47% Top-10 accuracy), and case studies on 20 companies report a mean absolute percentage error (MAPE) of 45.88%. The project is available at: https://huggingface.co/datasets/Yvnminc/ExioNAICS.

  • 4 authors
·
Feb 8, 2025

Green Algorithms: Quantifying the carbon footprint of computation

Climate change is profoundly affecting nearly all aspects of life on earth, including human societies, economies and health. Various human activities are responsible for significant greenhouse gas emissions, including data centres and other sources of large-scale computation. Although many important scientific milestones have been achieved thanks to the development of high-performance computing, the resultant environmental impact has been underappreciated. In this paper, we present a methodological framework to estimate the carbon footprint of any computational task in a standardised and reliable way, based on the processing time, type of computing cores, memory available and the efficiency and location of the computing facility. Metrics to interpret and contextualise greenhouse gas emissions are defined, including the equivalent distance travelled by car or plane as well as the number of tree-months necessary for carbon sequestration. We develop a freely available online tool, Green Algorithms (www.green-algorithms.org), which enables a user to estimate and report the carbon footprint of their computation. The Green Algorithms tool easily integrates with computational processes as it requires minimal information and does not interfere with existing code, while also accounting for a broad range of CPUs, GPUs, cloud computing, local servers and desktop computers. Finally, by applying Green Algorithms, we quantify the greenhouse gas emissions of algorithms used for particle physics simulations, weather forecasts and natural language processing. Taken together, this study develops a simple generalisable framework and freely available tool to quantify the carbon footprint of nearly any computation. Combined with a series of recommendations to minimise unnecessary CO2 emissions, we hope to raise awareness and facilitate greener computation.

  • 3 authors
·
Jul 15, 2020

More than Carbon: Cradle-to-Grave environmental impacts of GenAI training on the Nvidia A100 GPU

The rapid expansion of AI has intensified concerns about its environmental sustainability. Yet, current assessments predominantly focus on operational carbon emissions using secondary data or estimated values, overlooking environmental impacts in other life cycle stages. This study presents the first comprehensive multi-criteria life cycle assessment (LCA) of AI training, examining 16 environmental impact categories based on detailed primary data collection of the Nvidia A100 SXM 40GB GPU. The LCA results for training BLOOM reveal that the use phase dominates 11 of 16 impact categories including climate change (96\%), while manufacturing dominates the remaining 5 impact categories including human toxicity, cancer (99\%) and mineral and metal depletion (85\%). For training GPT-4, the use phase dominates 10 of 16 impact categories, contributing about 96\% to both the climate change and resource use, fossils category. The manufacturing stage dominates 6 of 16 impact categories including human toxicity, cancer (94\%) and eutrophication, freshwater (81\%). Assessing the cradle-to-gate environmental impact distribution across the GPU components reveals that the GPU chip is the largest contributor across 10 of 16 of impact categories and shows particularly pronounced contributions to climate change (81\%) and resource use, fossils (80\%). While primary data collection results in modest changes in carbon estimates compared to database-derived estimates, substantial variations emerge in other categories. Most notably, minerals and metals depletion increases by 33\%, demonstrating the critical importance of primary data for non-carbon accounting. This multi-criteria analysis expands the Sustainable AI discourse beyond operational carbon emissions, challenging current sustainability narratives and highlighting the need for policy frameworks addressing the full spectrum of AI's environmental impact.

  • 8 authors
·
Aug 27, 2025

Air Quality and Greenhouse Gas Emissions Assessment of Data Centers in Texas: Quantifying Impacts and Environmental Tradeoffs

This study assesses air quality (AQ) and greenhouse gas (GHG) emissions from the rapid expansion of data centers in Texas, a major hub due to infrastructure, electricity markets, and business conditions. AQ impacts were separated from GHG emissions to clarify sources, regulations, and mitigation strategies. Electricity consumption and cooling systems dominate GHG emissions, with a 10 megawatt data center generating about 37,668 metric tons CO2 annually, while construction materials and IT equipment add substantial embodied emissions. Local AQ impacts, often overlooked, arise from diesel backup generators, construction equipment, and commuting. Generator testing alone can emit about 12 metric tons of NOx annually per facility, worsening ozone issues in regions such as Houston and Dallas-Fort Worth. Mitigation strategies include advanced cooling, renewable energy procurement, cleaner backup power (fuel cells, batteries), sustainable construction, and standardized reporting. ERCOT forecasts project 39 to 78 gigawatts of new data center load by 2030, potentially leading to 170 to 205 million metric tons of annual CO2 emissions. Aggressive adoption of renewables and advanced technologies could cut emissions by 50 to 80 percent, avoiding 85 to 165 million metric tons of CO2. The study identifies research and policy gaps, including the need for cumulative air dispersion modeling, AQ-specific regulations, and mandatory efficiency standards. Findings underscore the importance of aligning Texas digital infrastructure growth with environmental and community health protections.

  • 1 authors
·
Sep 25, 2025

MMESGBench: Pioneering Multimodal Understanding and Complex Reasoning Benchmark for ESG Tasks

Environmental, Social, and Governance (ESG) reports are essential for evaluating sustainability practices, ensuring regulatory compliance, and promoting financial transparency. However, these documents are often lengthy, structurally diverse, and multimodal, comprising dense text, structured tables, complex figures, and layout-dependent semantics. Existing AI systems often struggle to perform reliable document-level reasoning in such settings, and no dedicated benchmark currently exists in ESG domain. To fill the gap, we introduce MMESGBench, a first-of-its-kind benchmark dataset targeted to evaluate multimodal understanding and complex reasoning across structurally diverse and multi-source ESG documents. This dataset is constructed via a human-AI collaborative, multi-stage pipeline. First, a multimodal LLM generates candidate question-answer (QA) pairs by jointly interpreting rich textual, tabular, and visual information from layout-aware document pages. Second, an LLM verifies the semantic accuracy, completeness, and reasoning complexity of each QA pair. This automated process is followed by an expert-in-the-loop validation, where domain specialists validate and calibrate QA pairs to ensure quality, relevance, and diversity. MMESGBench comprises 933 validated QA pairs derived from 45 ESG documents, spanning across seven distinct document types and three major ESG source categories. Questions are categorized as single-page, cross-page, or unanswerable, with each accompanied by fine-grained multimodal evidence. Initial experiments validate that multimodal and retrieval-augmented models substantially outperform text-only baselines, particularly on visually grounded and cross-page tasks. MMESGBench is publicly available as an open-source dataset at https://github.com/Zhanglei1103/MMESGBench.

  • 8 authors
·
Jul 24, 2025

Identifying Climate Targets in National Laws and Policies using Machine Learning

Quantified policy targets are a fundamental element of climate policy, typically characterised by domain-specific and technical language. Current methods for curating comprehensive views of global climate policy targets entail significant manual effort. At present there are few scalable methods for extracting climate targets from national laws or policies, which limits policymakers' and researchers' ability to (1) assess private and public sector alignment with global goals and (2) inform policy decisions. In this paper we present an approach for extracting mentions of climate targets from national laws and policies. We create an expert-annotated dataset identifying three categories of target ('Net Zero', 'Reduction' and 'Other' (e.g. renewable energy targets)) and train a classifier to reliably identify them in text. We investigate bias and equity impacts related to our model and identify specific years and country names as problematic features. Finally, we investigate the characteristics of the dataset produced by running this classifier on the Climate Policy Radar (CPR) dataset of global national climate laws and policies and UNFCCC submissions, highlighting the potential of automated and scalable data collection for existing climate policy databases and supporting further research. Our work represents a significant upgrade in the accessibility of these key climate policy elements for policymakers and researchers. We publish our model at https://huggingface.co/ClimatePolicyRadar/national-climate-targets and related dataset at https://huggingface.co/datasets/ClimatePolicyRadar/national-climate-targets.

  • 7 authors
·
Apr 3, 2024

Bridging the Gap: Integrating Ethics and Environmental Sustainability in AI Research and Practice

As the possibilities for Artificial Intelligence (AI) have grown, so have concerns regarding its impacts on society and the environment. However, these issues are often raised separately; i.e. carbon footprint analyses of AI models typically do not consider how the pursuit of scale has contributed towards building models that are both inaccessible to most researchers in terms of cost and disproportionately harmful to the environment. On the other hand, model audits that aim to evaluate model performance and disparate impacts mostly fail to engage with the environmental ramifications of AI models and how these fit into their auditing approaches. In this separation, both research directions fail to capture the depth of analysis that can be explored by considering the two in parallel and the potential solutions for making informed choices that can be developed at their convergence. In this essay, we build upon work carried out in AI and in sister communities, such as philosophy and sustainable development, to make more deliberate connections around topics such as generalizability, transparency, evaluation and equity across AI research and practice. We argue that the efforts aiming to study AI's ethical ramifications should be made in tandem with those evaluating its impacts on the environment, and we conclude with a proposal of best practices to better integrate AI ethics and sustainability in AI research and practice.

  • 4 authors
·
Apr 1, 2025

Sustainable Aviation Fuels: Opportunities, Alternatives and Challenges for Decarbonizing the Aviation Industry and Foster the Renewable Chemicals

Sustainable Aviation Fuels (SAF) are pivotal in the global effort to decarbonize the aviation sector and meet greenhouse gas (GHG) reduction targets established by international frameworks such as CORSIA and Brazil ProBioQAV. This study evaluates SAF potential to reduce lifecycle carbon emissions by up to 80% while being compatible with existing aviation infrastructure. Through bibliometric analysis, scenario evaluation, legal and regulatory framework analysis and economic modeling, the research examines two key SAF production technologies: Hydroprocessed Esters and Fatty Acids Synthetic Paraffinic Kerosene (HEFA-SPK) and Alcohol-to-Jet (ATJ) pathways in the Brazilian context. The findings reveal significant economic challenges, particularly high feedstock and production costs, which hinder SAF competitiveness with fossil fuels at recent and current market prices in Brazil, leading to the analysis of potential incentives and commercial conditions aiming to increase economic attractiveness of SAF production. Based on interviews with relevant stakeholders and decision makers in the industry, scenarios incorporating tax incentives, carbon credits, capital grants, and premium pricing for SAF and its biogenic by-products demonstrate that combined policy interventions and commercial arrangements, along with a regulated Carbon Market are essential for SAF economic viability. Future research is suggested to look at regional assessments of feedstock availability, supply chain logistics, and global market eligibility. This research provides insights for guiding public policy and private investment to support the transition to sustainable aviation in Brazil and beyond.

  • 5 authors
·
Apr 4, 2025

Green AI: Exploring Carbon Footprints, Mitigation Strategies, and Trade Offs in Large Language Model Training

Prominent works in the field of Natural Language Processing have long attempted to create new innovative models by improving upon previous model training approaches, altering model architecture, and developing more in-depth datasets to better their performance. However, with the quickly advancing field of NLP comes increased greenhouse gas emissions, posing concerns over the environmental damage caused by training LLMs. Gaining a comprehensive understanding of the various costs, particularly those pertaining to environmental aspects, that are associated with artificial intelligence serves as the foundational basis for ensuring safe AI models. Currently, investigations into the CO2 emissions of AI models remain an emerging area of research, and as such, in this paper, we evaluate the CO2 emissions of well-known large language models, which have an especially high carbon footprint due to their significant amount of model parameters. We argue for the training of LLMs in a way that is responsible and sustainable by suggesting measures for reducing carbon emissions. Furthermore, we discuss how the choice of hardware affects CO2 emissions by contrasting the CO2 emissions during model training for two widely used GPUs. Based on our results, we present the benefits and drawbacks of our proposed solutions and make the argument for the possibility of training more environmentally safe AI models without sacrificing their robustness and performance.

  • 2 authors
·
Apr 1, 2024

Exploring the sustainable scaling of AI dilemma: A projective study of corporations' AI environmental impacts

The rapid growth of artificial intelligence (AI), particularly Large Language Models (LLMs), has raised concerns regarding its global environmental impact that extends beyond greenhouse gas emissions to include consideration of hardware fabrication and end-of-life processes. The opacity from major providers hinders companies' abilities to evaluate their AI-related environmental impacts and achieve net-zero targets. In this paper, we propose a methodology to estimate the environmental impact of a company's AI portfolio, providing actionable insights without necessitating extensive AI and Life-Cycle Assessment (LCA) expertise. Results confirm that large generative AI models consume up to 4600x more energy than traditional models. Our modelling approach, which accounts for increased AI usage, hardware computing efficiency, and changes in electricity mix in line with IPCC scenarios, forecasts AI electricity use up to 2030. Under a high adoption scenario, driven by widespread Generative AI and agents adoption associated to increasingly complex models and frameworks, AI electricity use is projected to rise by a factor of 24.4. Mitigating the environmental impact of Generative AI by 2030 requires coordinated efforts across the AI value chain. Isolated measures in hardware efficiency, model efficiency, or grid improvements alone are insufficient. We advocate for standardized environmental assessment frameworks, greater transparency from the all actors of the value chain and the introduction of a "Return on Environment" metric to align AI development with net-zero goals.

  • 6 authors
·
Jan 24, 2025 3

Uncovering Drivers of EU Carbon Futures with Bayesian Networks

The European Union Emissions Trading System (EU ETS) is a key policy tool for reducing greenhouse gas emissions and advancing toward a net-zero economy. Under this scheme, tradeable carbon credits, European Union Allowances (EUAs), are issued to large emitters, who can buy and sell them on regulated markets. We investigate the influence of financial, economic, and energy-related factors on EUA futures prices using discrete and dynamic Bayesian networks to model both contemporaneous and time-lagged dependencies. The analysis is based on daily data spanning the third and fourth ETS trading phases (2013-2025), incorporating a wide range of indicators including energy commodities, equity indices, exchange rates, and bond markets. Results reveal that EUA pricing is most influenced by energy commodities, especially coal and oil futures, and by the performance of the European energy sector. Broader market sentiment, captured through stock indices and volatility measures, affects EUA prices indirectly via changes in energy demand. The dynamic model confirms a modest next-day predictive influence from oil markets, while most other effects remain contemporaneous. These insights offer regulators, institutional investors, and firms subject to ETS compliance a clearer understanding of the interconnected forces shaping the carbon market, supporting more effective hedging, investment strategies, and policy design.

  • 2 authors
·
May 15, 2025

AGBD: A Global-scale Biomass Dataset

Accurate estimates of Above Ground Biomass (AGB) are essential in addressing two of humanity's biggest challenges, climate change and biodiversity loss. Existing datasets for AGB estimation from satellite imagery are limited. Either they focus on specific, local regions at high resolution, or they offer global coverage at low resolution. There is a need for a machine learning-ready, globally representative, high-resolution benchmark. Our findings indicate significant variability in biomass estimates across different vegetation types, emphasizing the necessity for a dataset that accurately captures global diversity. To address these gaps, we introduce a comprehensive new dataset that is globally distributed, covers a range of vegetation types, and spans several years. This dataset combines AGB reference data from the GEDI mission with data from Sentinel-2 and PALSAR-2 imagery. Additionally, it includes pre-processed high-level features such as a dense canopy height map, an elevation map, and a land-cover classification map. We also produce a dense, high-resolution (10m) map of AGB predictions for the entire area covered by the dataset. Rigorously tested, our dataset is accompanied by several benchmark models and is publicly available. It can be easily accessed using a single line of code, offering a solid basis for efforts towards global AGB estimation. The GitHub repository github.com/ghjuliasialelli/AGBD serves as a one-stop shop for all code and data.

  • 4 authors
·
Jun 7, 2024

Reporting and Analysing the Environmental Impact of Language Models on the Example of Commonsense Question Answering with External Knowledge

Human-produced emissions are growing at an alarming rate, causing already observable changes in the climate and environment in general. Each year global carbon dioxide emissions hit a new record, and it is reported that 0.5% of total US greenhouse gas emissions are attributed to data centres as of 2021. The release of ChatGPT in late 2022 sparked social interest in Large Language Models (LLMs), the new generation of Language Models with a large number of parameters and trained on massive amounts of data. Currently, numerous companies are releasing products featuring various LLMs, with many more models in development and awaiting release. Deep Learning research is a competitive field, with only models that reach top performance attracting attention and being utilized. Hence, achieving better accuracy and results is often the first priority, while the model's efficiency and the environmental impact of the study are neglected. However, LLMs demand substantial computational resources and are very costly to train, both financially and environmentally. It becomes essential to raise awareness and promote conscious decisions about algorithmic and hardware choices. Providing information on training time, the approximate carbon dioxide emissions and power consumption would assist future studies in making necessary adjustments and determining the compatibility of available computational resources with model requirements. In this study, we infused T5 LLM with external knowledge and fine-tuned the model for Question-Answering task. Furthermore, we calculated and reported the approximate environmental impact for both steps. The findings demonstrate that the smaller models may not always be sustainable options, and increased training does not always imply better performance. The most optimal outcome is achieved by carefully considering both performance and efficiency factors.

  • 4 authors
·
Jul 24, 2024

METER-ML: A Multi-Sensor Earth Observation Benchmark for Automated Methane Source Mapping

Reducing methane emissions is essential for mitigating global warming. To attribute methane emissions to their sources, a comprehensive dataset of methane source infrastructure is necessary. Recent advancements with deep learning on remotely sensed imagery have the potential to identify the locations and characteristics of methane sources, but there is a substantial lack of publicly available data to enable machine learning researchers and practitioners to build automated mapping approaches. To help fill this gap, we construct a multi-sensor dataset called METER-ML containing 86,599 georeferenced NAIP, Sentinel-1, and Sentinel-2 images in the U.S. labeled for the presence or absence of methane source facilities including concentrated animal feeding operations, coal mines, landfills, natural gas processing plants, oil refineries and petroleum terminals, and wastewater treatment plants. We experiment with a variety of models that leverage different spatial resolutions, spatial footprints, image products, and spectral bands. We find that our best model achieves an area under the precision recall curve of 0.915 for identifying concentrated animal feeding operations and 0.821 for oil refineries and petroleum terminals on an expert-labeled test set, suggesting the potential for large-scale mapping. We make METER-ML freely available at https://stanfordmlgroup.github.io/projects/meter-ml/ to support future work on automated methane source mapping.

  • 10 authors
·
Jul 22, 2022

Jurisdiction as Structural Barrier: How Privacy Policy Organization May Reduce Visibility of Substantive Disclosures

Privacy policies are supposed to provide notice. But what if substantive information appears only where users skip it? We identify a structural pattern we call jurisdiction-siloed disclosure: information about data practices appearing in specific, actionable form only within regional compliance sections labeled "California Residents" or "EU/UK Users," while general sections use vague or qualified language for the same practices. Our audit of 123 major companies identifies 282 potential instances across 77 companies (62.6% of this purposive sample). A conservative estimate restricted to practice categories validated against OPP-115 human annotations finds 138 instances across 54 companies (44%); post-2018 categories central to our findings await independent validation. If users skip jurisdiction-labeled sections as information foraging theory predicts, users outside regulated jurisdictions would receive less specific information about practices affecting them--a transparency failure operating through document architecture rather than omission. We propose universal substantive disclosure: practices affecting all users should appear in the main policy body, with regional sections containing only procedural rights information. This standard finds support in analogous disclosure regimes (securities, truth-in-lending, nutritional labeling) where material information must reach all affected parties. Regulators could operationalize this through the FTC's "clear and conspicuous" standard and GDPR transparency principles. This work is hypothesis-generating: we establish that the structural pattern exists and ground the transparency concern in behavioral theory, but direct measurement of jurisdiction-specific section skipping remains the critical validation priority. We release our methodology and annotated dataset to enable replication.

  • 1 authors
·
Jan 28