Causal Attribution for Agentic Decisions: Estimators, Coupling, and a Traceability Specification

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A provider of a high-risk AI system must keep records that make a decision traceable, and for agentic systems it has not been established what those records must contain for post-hoc causal attribution to be possible. We give the estimator framework and then the conditions under which it fails. We separate the marginal total effect that prior work measures from a common-random-numbers total effect that isolates a step's own contribution, add the natural direct effect under a pinned downstream, and check the estimators against hand derivations. Both estimands then fail, in the same direction. Under the marginal estimand a causally inert step has the identical total effect to the decisive one on every run of our planted chain, an algebraic identity and not a coincidence at one draw. Under common random numbers the decisive step returns exactly zero on the runs where the executing step flips, about one in ten, while its direct effect there is 0.25 and it demonstrably acts; an exact zero does not certify that a step did nothing, and we put that here rather than in the limitations. We derive the coupling that keeps the direct effect estimable once contexts diverge, with a closed form for its degradation, and show that the mediated share on which a natural ranking is built is not a share under suppression: where the direct and mediated paths oppose, it exceeds one and ranks a suppressed component above a pure mediator. We publish the discrepancy experiment's pre-registration rather than a result, because the live pipeline it requires was not available in the study window. We contribute the traceability specification such a filing would need, against a gap the Act's calendar opens: Article 86's right to an explanation has applied since 2 August 2026, while the Article 12 logging and Annex IV documentation that could evidence one were deferred to 2 December 2027 by Regulation (EU) 2026/1744.