A Moral Agency Framework for Legitimate Integration of AI in Bureaucracies

Public-sector bureaucracies seek to reap the benefits of artificial intelligence (AI), but face important concerns about accountability and transparency when using AI systems. These concerns center on threats to the twin aims of bureaucracy: legitimate and faithful implementation of legislation, and the provision of stable, long-term governance. Both aims are threatened when AI systems are misattributed as either mere tools or moral subjects - a framing error that creates ethics sinks, constructs that facilitate dissipation of responsibility by obscuring clear lines of human moral agency. Here, we reject the notion that such outcomes are inevitable. Rather, where they appear, they are the product of structural design decisions across both the technology and the institution deploying it. We support this claim via a systematic application of conceptions of moral agency in AI ethics to Weberian bureaucracy. We establish that it is both desirable and feasible to render AI systems as tools for the generation of organizational transparency and legibility, which continue the processes of Weberian rationalization initiated by previous waves of digitalization. We present a three-point Moral Agency Framework for legitimate integration of AI in bureaucratic structures: (a) maintain clear and just human lines of accountability, (b) ensure humans whose work is augmented by AI systems can verify the systems are functioning correctly, and (c) introduce AI only where it doesn't inhibit the capacity of bureaucracies towards either of their twin aims of legitimacy and stewardship. We suggest that AI introduced within this framework can not only improve efficiency and productivity while avoiding ethics sinks, but also improve the transparency and even the legitimacy of a bureaucracy.