Accountability gaps appear inevitable in large organizations. A project fails and no one is clearly responsible. A system produces harmful outcomes and no single party can be held accountable. A decision leads to losses and responsibility is distributed across so many actors that consequences are diluted to irrelevance.
This looks like a coordination failure. It’s typically treated as coordination failure. Organizations hire consultants to “clarify accountability structures” and implement RACI matrices and responsibility frameworks.
The interventions fail because the diagnosis is wrong.
Accountability gaps aren’t coordination failures. They’re coordination successes optimizing for different objectives than stated ones.
Organizations don’t accidentally create ambiguous responsibility structures. They deliberately engineer them to protect individuals from consequences while maintaining organizational deniability.
The Function of Ambiguity
Clear accountability creates risk for decision-makers. If you’re clearly responsible for an outcome, negative outcomes attach to you personally. Your reputation suffers. Your career progression slows. Your decisions get scrutinized.
Ambiguous accountability distributes risk. If ten people share responsibility, each bears one-tenth of the consequences. More accurately, each bears none of the consequences because attribution becomes impossible.
This is valuable to everyone involved. Executives avoid career risk. Middle managers avoid scrutiny. Individual contributors avoid blame. The organization avoids liability.
Ambiguity serves all parties better than clarity. The only party disadvantaged by accountability gaps is the external stakeholder affected by organizational failures. But external stakeholders don’t set internal structures.
Organizations that successfully maintain ambiguous accountability structures aren’t failing at coordination. They’re succeeding at risk distribution.
Designed Gaps vs Accidental Gaps
Accidental accountability gaps have specific signatures. They emerge from oversight. They get closed when discovered. They create visible dysfunction that leadership wants to eliminate.
Designed accountability gaps have different signatures. They persist despite repeated attempts at clarification. They exist in critical areas where clear accountability would be most valuable. They’re defended with process-focused language when challenged.
The signature of design is persistence in the face of awareness.
An accidental gap: a new product team launches without clear ownership of customer support responsibilities. Customers complain. Leadership realizes the gap and assigns responsibility. The gap closes.
A designed gap: an algorithmic system makes consequential decisions. When outcomes are harmful, responsibility is distributed across data scientists who built the model, engineers who deployed it, product managers who defined requirements, executives who approved it, and the algorithm itself. The gap persists through multiple incidents. Attempts at clarification add more parties to the responsibility chain rather than narrowing it.
The persistence reveals intent. Not conscious intent necessarily, but systemic intent. The organization’s immune system fights clarification because clarity would concentrate risk that currently benefits from distribution.
The RACI Theater
Organizations implement responsibility frameworks like RACI matrices—Responsible, Accountable, Consulted, Informed—as accountability interventions. These frameworks rarely clarify accountability. Often they formalize ambiguity.
RACI matrices for complex decisions frequently show:
- Multiple parties as “Accountable”
- Accountability assigned to committees rather than individuals
- “Consulted” categories so broad that consensus becomes impossible
- Responsibility distributed across organizational boundaries where enforcement is weak
This isn’t an accidental misuse of the framework. This is the framework being used for its actual purpose: creating the appearance of accountability structure while preserving accountability diffusion.
The story is what happens when RACI produces clear individual accountability. The individual pushes back. They request joint accountability. They insist other parties need to be co-accountable. They escalate until the accountability is sufficiently distributed.
Leadership typically approves these modifications. Not because clear individual accountability is wrong, but because individual accountability concentrates risk the organization prefers distributed.
The RACI matrix serves its function. The function isn’t clear. The function is defensible documentation that responsibility was considered and assigned—to everyone and therefore no one.
Committee Accountability as Null Accountability
Committees are accountability sinks. When a committee is accountable, no individual is accountable.
This is obvious but bears making it explicit. A committee decides to launch a product with known security flaws. The product gets breached. Who is accountable?
The committee. Which means:
- The committee members who advocated most strongly for launch aren’t individually accountable
- The members who raised concerns aren’t accountable for failing to prevent it
- The committee chair isn’t more accountable than members
- The executive who chartered the committee shares diffused accountability
Everyone contributed to the decision. No one is responsible for the outcome.
This structure doesn’t emerge from coordination failure. It emerges from successful coordination around the goal of preventing individual attribution.
Organizations know committees diffuse accountability. That’s why consequential decisions requiring genuine accountability are assigned to individuals. That’s also why consequential decisions requiring accountability diffusion are assigned to committees.
The choice between individual and committee accountability reveals whether the organization wants attribution or wants to prevent it.
Cross-Functional Accountability Diffusion
Modern organizations operate through cross-functional collaboration. A product requires engineering, design, product management, legal, compliance, security, and data science input.
This creates natural accountability diffusion. When something fails:
- Engineering blames unclear requirements from product management
- Product management blames technical constraints from engineering
- Design blames both for not implementing the intended experience
- Legal blames everyone for not consulting them properly
- Compliance points to the risk documentation they provided that was ignored
- Security notes the threat model they shared that wasn’t addressed
Each party has defensible reasoning. Each party contributed but wasn’t individually responsible for the outcome. Each party can point to other parties whose decisions were more proximate to failure.
This isn’t a coordination failure. This is the predictable result of structuring work to require coordination across parties with different success metrics, different time horizons, and different accountability structures.
Organizations could structure work to consolidate accountability. Small, autonomous teams with end-to-end ownership exist in some contexts. They’re not universal because end-to-end accountability concentrates risk.
Cross-functional work distributes risk. When a project involves eight functions, responsibility is diluted eightfold. That’s valuable to everyone involved.
The persistence of cross-functional work structures despite well-documented coordination costs reveals the structure is solving for something other than efficiency.
The Consultant Buffer
Organizations hire consultants for many reasons. One reason is accountability buffering.
Consultants make recommendations. The organization implements them. The implementation fails. Who is accountable?
The consultants recommended it. But they don’t work there and weren’t responsible for implementation. The organization implemented it. But they were following expert advice. The implementation team executed it. But they were following the leadership direction. Leadership approved it. But they relied on consultant analysis.
Accountability is distributed across an internal organization and an external firm with contractual protections against liability.
This structure is expensive. Consultants cost more than internal employees doing equivalent work. If the goal were only expertise access, organizations could hire those experts.
The premium pays for accountability buffering. When recommendations fail, the organization can point to consultant analysis. When execution fails, consultants can point to implementation gaps. Both parties have defensible positions. Neither is fully accountable.
Organizations that repeatedly hire consultants for strategic decisions aren’t failing to build internal capabilities. They’re maintaining strategic ambiguity about who is responsible for strategic outcomes.
Algorithmic Accountability Gaps
AI systems create accountability structures that look designed for maximal diffusion.
An algorithmic lending system denies credit to qualified applicants. Who is accountable?
- Data scientists who built the model? They optimized the objective function they were given.
- Engineers who deployed it? They met the technical specifications.
- Product managers who defined requirements? They based requirements on business goals.
- Executives who approved it? They relied on technical experts.
- The algorithm itself? It has no agency or liability.
This distribution isn’t accidental. It’s the result of sequential decisions, each reasonable individually, that collectively create accountability diffusion.
Organizations could concentrate accountability. A senior decision-maker could own all algorithmic outcomes and be empowered to override technical recommendations. That person would need authority over data science, engineering, product, and business strategy.
Such concentration is rare. Not because it’s impossible to structure, but because it concentrates risk that organizational design prefers distributed.
The question “who is responsible when AI systems fail?” has no clear answer by design. The ambiguity protects all human parties from consequences.
Measurement Systems That Prevent Attribution
Organizations measure what they want to manage. Except when they don’t want attribution.
Consider measuring individual contribution to collaborative work. Technology exists to track who contributed what to group projects. Version control systems track individual changes. Project management tools track individual task completion. Communication platforms track who participated in decisions.
Organizations could use this data to attribute outcomes to decisions and decisions to decision-makers. They don’t.
Instead, organizations measure team-level outcomes, celebrate collective success, and distribute blame for failure across the collective.
This isn’t a technical limitation. This is a choice. Individual attribution data exists. Organizations choose not to use it for accountability.
The choice reveals preference. Organizations prefer ambiguity to attribution.
When attribution would support organizational goals—like identifying high performers for promotion—attribution mechanisms suddenly become available. Performance reviews attribute individual contribution. Promotion committees evaluate individual impact.
But when attribution would concentrate risk—like identifying decision-makers responsible for failures—the measurement system provides only collective metrics.
The measurement system’s asymmetry reveals its design. Attribution when beneficial, ambiguity when risky.
Process as Accountability Shield
Organizations with accountability problems implement processes. The processes rarely clarify accountability. Often they obscure it.
A process for approving algorithmic systems requires sign-offs from security, legal, compliance, ethics review, and executive sponsors. Each party reviews their domain. The system gets approved through collective sign-off.
The system fails. Who is accountable?
Everyone signed off. No one had veto authority. Each party reviewed their specific domain but not the system holistically. Collective approval created collective responsibility, which functionally means no responsibility.
This process structure is common. It looks like rigorous governance. It functions as accountability diffusion.
An alternative structure: one accountable owner makes the approval decision after consulting others. Others provide input but the owner decides. This concentrates accountability on the owner.
Organizations resist this structure. Not because it’s less rigorous, but because it concentrates risk. The multi-sign-off process distributes risk while creating documentation that multiple parties reviewed the decision.
The documentation serves a purpose. The purpose isn’t accountability. It’s demonstrating that accountability was considered and distributed.
When Clarity Threatens
Some organizations genuinely attempt accountability clarification. The attempts fail in predictable ways.
Leadership announces new accountability framework. Individual roles are assigned clear ownership. Initial implementation proceeds. Then edge cases emerge.
Edge cases are where accountability clarification fails. An outcome is negative. The assigned owner claims it wasn’t within their scope. They point to dependencies on other parties. They escalate to leadership. Leadership mediates. The mediation expands accountability back to multiple parties.
The edge cases become the norm. Every situation has dependencies. Every outcome has multiple contributing factors. Every individual accountability holder successfully argues for shared accountability.
The clarification attempt results in accountability structures identical to what existed before, but with more documentation.
This pattern reveals what the organization actually wants. If the organization wanted clarity, edge cases would be resolved by reinforcing individual accountability—the owner is responsible even when outcomes involve dependencies.
Instead, edge cases are resolved by redistributing accountability. This reveals the organization’s preference. Clarity threatens more than ambiguity costs.
The Liability Distribution Network
Legal liability motivates much organizational behavior. Accountability structures often optimize for liability distribution rather than operational clarity.
Corporations are liability shields. Individual decision-makers aren’t personally liable for corporate outcomes in most cases. But reputational damage, regulatory scrutiny, and career consequences still attach to individuals.
Organizations respond by creating internal liability shields—accountability structures that prevent attribution of negative outcomes to individuals.
These structures include:
- Committee decision-making for high-risk choices
- Cross-functional approval processes with no single veto authority
- Consultant recommendations for decisions with strategic liability
- Algorithmic systems that obscure decision-making processes
- Documentation practices that distribute responsibility across many parties
- Escalation procedures that involve leadership without giving them decision authority
Each structure is rational individually. Collectively they create an accountability gap that protects every internal party from consequences.
This isn’t accidental. This is the network effect of many actors optimizing for personal risk minimization. The result is organizational structures that systematically prevent attribution.
Coordination Without Accountability
Organizations coordinate complex work effectively in many domains. The same organizations fail to maintain accountability clarity in those domains.
This is paradoxical if you believe accountability requires coordination. If you understand accountability as risk concentration that parties prefer to avoid, the pattern makes sense.
Organizations coordinate shipping software, manufacturing products, and delivering services. These coordination successes don’t translate to accountability clarity because coordination is necessary for operational outcomes while accountability is a constraint on individual behavior.
Coordination serves everyone’s interests when the goal is shipping. Accountability serves external stakeholder interests but threatens internal parties when outcomes are negative.
Organizations optimize for what benefits internal actors. Coordination benefits internal actors by enabling work. Accountability threatens internal actors by concentrating consequences.
The result is organizations that coordinate well but maintain accountability ambiguity. Both outcomes serve organizational interests as experienced by internal parties.
When Gaps Are Features
Accountability gaps serve functions. Understanding the functions explains their persistence.
Gaps protect individuals from career risk associated with negative outcomes. This enables risk-taking. Organizations need risk-taking for innovation. Clear individual accountability for negative outcomes would create risk aversion.
Gaps protect organizations from liability by preventing attribution of organizational failures to specific individuals who made specific decisions. This limits regulatory penalties and legal exposure.
Gaps prevent blame cultures by making it impossible to single out individuals for failures. This maintains team cohesion and prevents defensive behavior.
Gaps enable collaborative work by preventing individual parties from having veto authority that could block progress. This maintains operational momentum.
Each function is defensible. Each function benefits from accountability ambiguity. The organization that wants these benefits needs accountability gaps.
The gaps aren’t bugs. They’re features optimizing for these objectives rather than for external accountability.
The Honest Design
If organizations acknowledged accountability gaps as designed features, they would stop trying to eliminate them and start being explicit about trade-offs.
Explicit design would say: “We distribute accountability across committees because we prioritize risk distribution over individual attribution. This means external parties can’t identify who is responsible for specific decisions. We accept this trade-off because it enables risk-taking internally.”
Or: “We structure cross-functional work in ways that diffuse accountability because we prioritize collaborative coordination over clear attribution. This means failure analysis won’t identify responsible individuals. We accept this because operational efficiency benefits from shared ownership.”
This honesty would make visible what’s currently obscured: organizations choose ambiguity because ambiguity serves organizational interests.
The choice isn’t neutral. External stakeholders—customers, users, regulators, affected populations—bear costs of accountability ambiguity. They can’t get redress because they can’t identify responsible parties. They can’t prevent recurrence because they can’t apply consequences to decision-makers.
Internal stakeholders benefit. External stakeholders pay. That’s not a coordination failure. That’s feature distribution optimized for internal interests.
The Regulatory Response
Regulators increasingly recognize accountability gaps as designed rather than accidental. Regulatory response has evolved.
Early regulation assumed organizational good faith. If accountability wasn’t clear, regulators would require clarity. Organizations would implement it.
This didn’t work. Organizations implemented processes that appeared to clarify accountability while maintaining ambiguity.
Modern regulation increasingly assigns accountability externally rather than relying on organizational internal structures. Regulations specify that CEOs are accountable, regardless of internal delegation. Or chief security officers. Or designated compliance officers.
This works better. Not because organizations suddenly prefer clarity, but because regulators bypass organizational internal structures and assign accountability to specific roles externally.
Even this has limits. Individuals in designated roles build internal structures to distribute risk even when external regulation assigns them accountability. But external assignment at least concentrates regulatory pressure.
The regulatory evolution from “clarify internal accountability” to “we’re assigning it to you directly” reflects learning. Regulators learned that organizations optimize for accountability ambiguity and won’t voluntarily clarify.
The Exception That Proves the Rule
Some organizations maintain clear individual accountability even when it creates risk concentration. These organizations are exceptions worth examining.
Small organizations often have clear accountability by necessity. The CEO is accountable. Delegation is explicit. Attribution is obvious. This clarity persists until organizations grow large enough that diffusion becomes possible.
Founder-led organizations often maintain founder accountability even as they scale. The founder’s identity is tied to the organization. They can’t credibly diffuse accountability because everyone knows they’re responsible.
Military organizations maintain clear command accountability. Commanders are responsible for unit outcomes. This clarity is structural and enforced through court martial systems for accountability failure.
High-reliability organizations like nuclear power plants and air traffic control maintain clear individual accountability because failure consequences are severe and external pressure is intense.
What these exceptions share: external pressure preventing accountability diffusion or structural constraints making diffusion impossible.
The exceptions prove the rule. When organizations can diffuse accountability, they do. When they can’t, they maintain clarity. The default is diffusion. Clarity requires constraints.
Misaligned Incentives
The persistence of accountability gaps reveals deep incentive misalignment.
Organizations nominally want accountability because external stakeholders demand it and because clear accountability theoretically improves decision quality through consequences.
Organizations actually want to minimize individual risk, enable collaboration, maintain operational momentum, and protect against liability. These goals benefit from accountability ambiguity.
The stated goal and revealed preference conflict. The revealed preference wins because it serves internal actor interests.
This misalignment persists because external stakeholders lack power to impose accountability structures. Customers can stop buying products. Users can switch platforms. But they can’t force internal organizational restructuring.
Regulators have more power but face limitations. They can assign accountability to specific roles. They can’t redesign internal organizational structures. Organizations comply with external assignments while maintaining internal diffusion.
The incentive misalignment is structural. Until external stakeholders gain power to impose accountability structures or until consequences for ambiguity exceed benefits, organizations will continue optimizing for ambiguity.
The Cost of Pretending
Organizations pretend accountability gaps are accidental. This pretense is costly.
Resources go to accountability “improvement” initiatives that don’t improve anything because the underlying structure is designed to prevent improvement. Consultants implement frameworks that formalize existing ambiguity. Leadership announces accountability clarifications that edge cases quickly erode.
These interventions are expensive and accomplish nothing. Not because they’re poorly executed, but because they’re fighting organizational immune systems defending desired ambiguity.
The pretense also costs credibility. External stakeholders recognize the pattern. Accountability gaps persist. Organizations claim to address them. Nothing changes. Stakeholders learn organizations aren’t acting in good faith.
This credibility loss makes regulation more adversarial and stakeholder relationships more antagonistic. Organizations lose the benefit of the doubt because the pattern of accountability gap persistence reveals intent.
Honest acknowledgment would at least be credible. “We maintain accountability ambiguity because it serves our internal coordination goals” is at least honest. Dishonest claims about seeking clarity while maintaining ambiguity damage trust.
The Alternative Structure
Organizations could design for clarity. What would that require?
Individual accountability for consequential decisions. One person decides. Others provide input. The decider is accountable.
No committee decision-making for decisions with significant downside risk. Committees can coordinate. They can’t be accountable.
Clear escalation chains with accountability at each level. If a decision is escalated, the person who escalates transfers responsibility to the person above. The person above is now accountable.
Measurement systems that track individual contribution to outcomes. Not for punishment, but for learning and calibration.
Override authority that carries responsibility. If someone overrides another’s decision, they own the outcome.
Documentation that identifies who decided what when. Not for blame, but for accountability and learning.
These structures are feasible. Organizations could implement them. They don’t, in most cases, because clarity concentrates risk that organizational actors prefer distributed.
The fact that alternative structures exist but aren’t adopted reveals choice, not constraint.
The Truth About Design
Accountability gaps persist in areas where clear accountability would be most valuable. They persist despite awareness. They persist despite repeated attempts at clarification. They persist because they serve the interests of the parties who create organizational structures.
This is design.
Not necessarily conscious conspiracy. But design nonetheless. The emergent result of many actors optimizing for risk minimization creates structures that systematically prevent accountability attribution.
Organizations know this. Leadership knows this. Individuals within organizations know this. The collective fiction is that accountability gaps are coordination failures that better frameworks will solve.
The fiction serves a purpose. It allows continued investment in accountability theater while maintaining actual accountability diffusion.
Recognizing accountability gaps as designed features rather than accidental bugs changes the conversation. It shifts from “how do we clarify accountability?” to “why do we maintain accountability ambiguity and who benefits?”
That’s a more honest conversation. Also a more threatening one. Which is why most organizations prefer to keep treating designed features as bugs they’re definitely going to fix. Eventually. After the next consultant engagement produces the next framework that won’t change anything.
The gaps aren’t accidental. They never were.