WorksEconomics, Econometrics and Finance
Regret-based Characterization, Information Limits, and the Sample Complexity of Auditing Adaptive Policies
Abstract
A policy can earn its performance by where it locates on average or by reacting to information. For any Markov policy in a finite-horizon MDP, let be its open-loop marginal, which plays 's average action distribution at each step. We show that equals under endogenous dynamics. Audits based on immediate costs alone can have the wrong sign. Writing the covariance as a joint-versus-product gap gives the bound , with a sharp constant. Hence, an MDP's adaptivity gap is bounded by the information that its optimal policy uses. Estimating from 's own bandit-feedback logs takes rounds, where is an average -divergence. At the same time, deterministic non-constant policies cannot be audited at all. We also provide an importance-sampling auditor for episodic MDPs.
Introduction
Learned policies set portfolio weights, prices, bids, inventory orders, and treatment assignments. A principal or regulator who evaluates such a policy usually sees only its inputs and outputs, but wants to know whether the policy creates value by using information or merely by how it behaves on average. The second kind of value can be replicated by a fixed rule; the first cannot. This paper studies the problem of separating the two, which we call auditing adaptivity, from three angles: an exact characterization, an information-theoretic limit, and the sample complexity of estimation.
The benchmark. Fix a Markov policy in a finite-horizon MDP and let be its state distribution at step . Its open-loop marginal is the policy that, at step , ignores the state and draws from
Thus uses each action exactly as often as does on average at each step, but uses no information. The quantity , where denotes expected total cost, is the value that adds (if negative) or destroys (if positive) by conditioning on the state. In finance, this is the classical split of active returns into a ”timing” (covariance) component and a ”static allocation” (means) component [9, 19]; in stochastic optimization, is the additive adaptivity gap [10, 13]. Recent work by Aldridge [2, 3] observed that, for stochastic linear programs and portfolio policies, expected regret equals the covariance between costs and decisions when the policy is mean-unbiased. We show that this phenomenon is exact in far greater generality and develop its quantitative theory.
Results
1. Exact characterization (§ 3). In every finite-horizon MDP and for every Markov policy ,
where is the joint law of under and is the product of its marginals (Theorem 3.4). The identity holds under fully endogenous dynamics; the feedback from actions to states is absorbed by evaluating the covariance under ’s state distribution and pairing actions with the -function of . Pathwise and with no probability model at all, the regret of any online linear optimization algorithm against the best fixed action in hindsight equals a sample covariance plus a non-negative static gap (Theorem 3.1). Regret to the optimal policy splits as adaptivity plus static allocation plus the problem’s adaptivity gap, and the adaptivity gap is at most the covariance magnitude of any optimal policy (Theorem 3.7). The in (1) cannot be replaced by immediate costs: the resulting “myopic audit” can report value destruction for a policy that creates value, with unbounded error (Theorem 3.8).
2. Information limits (§ 4). The right-hand form of (1) compares a joint law to the product of its marginals. The KL divergence between them is the mutual information , so Pinsker’s inequality yields:
Informal statement (Theorems 4.2 and 4.3). , where is the largest per-state range of across actions. The constant cannot be improved.
Two consequences follow. The additive adaptivity gap of an MDP is at most evaluated at any optimal policy, so problems whose optimal policies need few bits have small adaptivity gaps (Theorem 4.4). And with costs in , a policy whose actions carry at most units of mutual information between state and action per step (a.k.a. ”nats”) cannot beat the best open-loop policy by more than (Theorem 4.5). This is a rate–value tradeoff in the spirit of rational inattention [24, 25].
3. Sample complexity of auditing (§ 5). An auditor observes ’s own logs and must estimate . Under full information, the problem is easy. Under bandit feedback, it reduces to off-policy evaluation of the open-loop marginal , and the right complexity parameter is
the average -divergence from the marginal to the conditional action distributions.
Informal statement (Theorems 5.2 to 5.4). A median-of-means IPW auditor estimates within with probability from logged rounds, for every policy and instance. Conversely, for every value there is a policy with and two instances on which every auditor needs rounds. If never plays some action that plays, on a set of contexts of positive measure, then is not identifiable. In particular, a deterministic non-constant policy cannot be audited from its own logs.
For episodic MDPs, an importance-sampling auditor over whole trajectories needs a number of episodes
(Theorem 5.6).
Techniques
The characterization rests on two observations. First, the open-loop marginal is the unique state-independent policy whose value function satisfies with the same as ’s marginal. Plugging this into the performance-difference lemma [16] turns each advantage term into a centered inner product, which is a covariance. Second, a covariance between a function of the state and a function of the action is , so any divergence bound between a joint law and its product applies. The identity is invariant to adding any function of the state to , and choosing the per-state midpoint replaces the global oscillation of by the much smaller per-state action range. For auditing, the key observation is that under is directly observable, so all statistical difficulty lies in evaluating off-policy. The variance of the natural estimator is exactly bounded by . The lower bound plants a cost perturbation on the context–action pair that plays with probability but plays with probability , and applies the Bretagnolle–Huber inequality.
Related work
Online learning and regret. Regret against the best fixed action is the standard benchmark of online learning [7, 14]. Theorem 3.1 is an elementary identity, but it provides a structural reading of regret: negative regret (beating the best fixed action) is possible only with negative sample covariance, and every no-regret algorithm has sample covariance of at most its regret. Applied to stochastic bandit algorithms such as Thompson sampling, whose regret is near-optimal [1], the decomposition separates an algorithm’s static exposure to suboptimal arms (the static gap) from the timing of its exploration (the covariance).
Adaptivity gaps. The benefit of adaptivity is studied as a multiplicative ratio for stochastic knapsack [10], stochastic probing [13] and submodular maximization [4]. Our bounds are additive and problem-agnostic: Theorem 4.4 bounds the gap by the information used by an optimal policy, and Theorem 3.7 identifies the policy-level quantity, a covariance, whose extremum the gap is.
Information-theoretic bounds. Bounding the covariance between a selection and a quantity by mutual information through a change of measure underlies information-theoretic analyzes of adaptive data analysis [23], generalization [29], and Thompson sampling [22]. Theorem 4.2 applies this technique to the value of adaptivity in MDPs. Evaluating the bound on continuous-state data requires estimating mutual information, for which efficient -nearest-neighbour entropy estimators are available [5]. Two ingredients specific to this setting are the reduction to through Theorem 3.4 and the state-baseline invariance that yields the per-state span. Information-constrained decision-making is studied as rational inattention [24] and in information-theoretic RL [25].
Off-policy evaluation. Our auditing results are an instance of off-policy evaluation (OPE), with the twist that the target policy is defined by the behavior policy itself. Importance sampling and doubly robust estimators [11, 15, 21] and minimax analyses for contextual bandits [17, 27] are the closest antecedents. The lower bound of Theorem 5.4 is in the spirit of [17], specialized for targets of the form . Marginalized importance sampling [18, 28, 31] suggests routes to polynomial-in-horizon auditing.
Auditing LLM agents. Agentic systems built on large language models raise the same question at the level of tool calls and workflow steps. Systems working on agent evaluation ask when and how to inspect an agent’s execution mid-trajectory [30]. Our results supply a complementary statistical criterion. Logging the agent’s action propensities and states is enough to estimate its adaptive value against its own open-loop marginal (Theorem 5.6). Without exploration, however, a deterministic agent cannot be audited from its own logs (Theorem 5.2).
Finance and predict-then-optimize. The decomposition is classical in performance attribution [9, 19] and related to decision-focused learning [12]. Aldridge [2, 3] uses it as a regret characterization for stochastic linear programs and AI investment strategies under a mean-unbiasedness condition. The present paper removes that condition, extends the identity to endogenous dynamics, and supplies information and sample-complexity theory.
Model
MDPs and policies. A finite-horizon MDP is a tuple with finite state and action sets, transition kernels , bounded costs , and initial distribution . A (randomized, time-dependent) Markov policy is with . Running generates , , . Write for the law of , for expected total cost, and
for the action-value and value functions of a Markov policy . Costs, rather than rewards, maintain the sign convention of regret.
Definition 2.1 (Open-loop marginal). For a Markov policy , let . The open-loop marginal of is the policy with for all . A policy is open-loop if does not depend on for every .
We write and when is clear, and call the adaptivity cost of ; is its adaptive value. Let be an optimal policy and an optimal open-loop policy (both exist by finiteness and compactness). The (additive) adaptivity gap of is .
Covariances. For random vectors with finite second moments, . Throughout, and with , so that .
Information quantities. Under , let be the joint law of , with marginals and . The mutual information is , in units of information, nats. For distributions on , , with the convention if .
Exact characterization
Pathwise: online linear optimization
Theorem 3.1 (Pathwise decomposition). Let be convex and compact, let be arbitrary, and let be arbitrary. Let , , and . Then
Proof. , because the cross terms and vanish. Also . The last term is non-negative because by convexity.
Corollary 3.2. For every online algorithm and every adversary, , with equality if and only if is a best fixed action in hindsight. In particular, implies , and every algorithm with has .
Theorem 3.1 requires no stochastic assumptions; it is the accounting identity the auditor computes on a realized path. The rest of the paper concerns the expected, endogenous-dynamics analogue.
The MDP covariance identity
Lemma 3.3 (Performance difference [16]). For Markov policies ,
Proof. Since , by telescoping. Take expectations under : the right side is . On the left, , and averaging over gives the claim.
Theorem 3.4 (Covariance characterization). For every finite-horizon MDP and every Markov policy , with ,
Moreover, each summand is unchanged if is replaced by for any .
Proof. Because for every , . By Theorem 3.3 with ,
Since , , so each summand equals , which proves (3). For (4), and . Finally, and have the same -marginal, so .
Remark 3.5 (What is new relative to the static identity). The identity is exact under endogenous dynamics: actions affect future states, and this feedback is fully captured by (i) averaging over ’s own state distribution and (ii) pairing actions with the action-values of , not of and not the immediate costs. The baseline invariance means may be replaced by the advantage .
Corollary 3.6 (Exogenous costs). Suppose actions do not affect transitions, that is, . Write . Then . In particular, for a contextual problem (, ), .
Proof. With action-independent transitions, with . Apply the invariance in Theorem 3.4.
Decomposing regret to the optimum
Corollary 3.7 (Three-part decomposition). For every Markov policy ,
Consequently for every optimal , with equality if and only if the open-loop marginal of is an optimal open-loop policy.
Proof. Add and subtract and , and apply Theorem 3.4. The middle term is non-negative because is open-loop. Setting gives the second statement.
Myopic audits fail
A tempting shortcut is to audit with immediate costs, , which by Theorem 3.6 is correct when dynamics are exogenous. Under endogenous dynamics it can be arbitrarily wrong.
Proposition 3.8 (Sign reversal). For every there is a two-step MDP with two states and two actions, and a deterministic policy , such that
Proof. Let and (“wait”, “invest”). Set and . The step-2 state records , and is action-independent with and . Let (invest exactly when ); is arbitrary. Then .
Myopic term. At , , since the coordinate is constant. At , the cost vector is constant across actions, so its covariance with vanishes because .
True value. and . By Theorem 3.4, ; the step-2 term vanishes for the same reason as before.
The ratio between the two quantities, , is unbounded as . Swapping the roles of the costs gives the reverse failure: a myopic audit that certifies value for a policy that destroys it.
Information limits of adaptivity
Definition 4.1 (Action span). For a Markov policy with marginal , let
The span measures how much the choice of action can matter in a single state; it ignores the variation of across states, which by Theorem 3.4 is irrelevant to adaptivity.
Theorem 4.2 (Information bound). For every finite-horizon MDP and every Markov policy ,
where is the mutual information, in nats, between state and action at step under .
Proof. Fix and write and . If and then , so both and are supported on . For let be the midpoint of , and set . Then takes values in on . By Theorem 3.4, the -th summand equals . For any with values in an interval of length , . By Pinsker’s inequality [8],
Sum over and use the triangle inequality.
Proposition 4.3 (Sharpness). The constant in Theorem 4.2 is optimal: there is a family of one-step instances with , , and
Proof. Let , , , , and for . Then , , and . Moreover, and , so . The mutual information is that of a binary symmetric channel with uniform input:
Hence , and the ratio tends to 1 as .
Corollary 4.4 (Adaptivity gap is bounded by the information an optimal policy uses). For every optimal Markov policy ,
In particular, if some optimal policy satisfies for all , then .
Proof. Combine Theorem 3.7 () with Theorem 4.2.
Corollary 4.5 (Rate–value tradeoff). Suppose . If a Markov policy satisfies for every , then
In particular, with a constant budget ,
Proof. , so . By Theorem 4.2, , and .
Remark 4.6 (Sub-Gaussian refinement). The proof of Theorem 4.2 only uses a change of measure between and . If is -sub-Gaussian under , the Donsker–Varadhan argument of [23, 29] gives . This can be much tighter than the span bound when has rare extreme action values.
Remark 4.7 (Estimating the bound from data). With finitely many states, is a plug-in quantity. When states are continuous, as with prices, inventories or market signals, the auditor can write in terms of differential entropies of the state. Each entropy can be estimated from logged states using the weighted -nearest-neighbor estimator of [5], which is efficient in low dimensions. Because the action is discrete and its propensities are logged, only the entropies of the state distribution need to be estimated.
The sample complexity of auditing
Contextual bandits
Setting. Contexts are i.i.d. on a measurable space ; given , a cost vector is drawn from a conditional law with mean ; the policy draws , independently of given . The auditor observes the log (bandit feedback with logged propensities) and knows . The target is the per-round adaptivity cost
the case of Theorem 3.6. An auditor is -accurate on an instance if its output satisfies . Let .
Remark 5.1 (Knowing ). depends only on and , not on costs, so it can be estimated to any accuracy from unlabelled contexts, which are cheap in most applications. We treat it as known to isolate the cost of missing counterfactual costs.
Proposition 5.2 (Non-identifiability). Suppose there are an action with and a measurable set with such that for all . Then there are two instances whose logs have the same distribution for every but whose values of differ. In particular, if is deterministic and its action is not almost surely constant, then is not identifiable from ’s logs.
Proof. Take any instance with , and modify it by adding to the mean of for . The log never contains for , so its law is unchanged. The first term of is unchanged because on ; the second changes by . For a deterministic policy with a non-constant action, pick with and , which has measure .
Theorem 5.3 (Upper bound). Let and . Split rounds into blocks of rounds each, and output the median of the block means. If , this auditor is -accurate on every instance once
Proof. Unbiasedness. Conditioning on and using independence of and given ,
Here ensures whenever , for -almost every . Taking expectations gives .
Variance. Since , . Now and , so .
Concentration. By Chebyshev’s inequality, each block mean deviates from by at least with probability at most . The median fails only if at least of the independent blocks fail. By Hoeffding’s inequality this has probability at most [20].
Theorem 5.4 (Lower bound). For every , and , there is a context distribution and a policy with , together with two cost models, such that every auditor that is -accurate on both instances requires
Proof. Instance. Let with uniform, , and for let and . Then and
This is continuous and decreasing on , takes the value at , and diverges as . So for each there is with , and .
For and , let instance have for both contexts, when , and when . Only action 2 has a context-dependent mean, so
and .
Divergence. The laws of coincide under both instances, and the law of differs only on the event , which has probability . On that event, using ,
By the chain rule and independence across rounds,
Testing. Given a -accurate auditor, let if and otherwise. Since , and . The Bretagnolle–Huber inequality [6, 26] gives , so
Using ,
Theorems 5.3 and 5.4 together show that is the right complexity parameter: the uniform upper bound is matched, up to constants, at every value of . Theorem 5.2 is the endpoint. A practical reading for audit design is that a policy can be audited from its own logs only if it explores, and the cost of auditing grows inversely with its exploration probability on the actions it marginally uses.
Episodic MDPs
Now the auditor observes i.i.d. episodes generated by , with logged propensities, and knows . Assume costs lie in and the following overlap condition.
Assumption 5.5 (Overlap). For every , , and : .
Theorem 5.6 (MDP auditing). Under Theorem 5.5, let , , and . Then and , where denotes the trajectory law under . Moreover
Consequently, the median-of-means auditor of Theorem 5.3 applied to is -accurate after episodes.
Proof. Support. Every trajectory with positive probability under has positive probability under . By induction on : under both; if the prefix up to is -possible, then , and any with has by Theorem 5.5, so and any in the support of are -possible. The transition factors cancel in , which therefore equals . Hence , , and .
Variance. , so , using .
Factorization. Let and let be generated by the history up to . Then , where is the maximum in the statement. By the tower property, . Induct.
Concentration. This is identical to Theorem 5.3, with variance bound in place of .
The product bound is exponential in unless the per-step divergences are . General OPE lower bounds for tree-structured MDPs are also exponential in [15]. Because the target is a very special policy. However, those lower bounds do not apply directly.
Numerical illustration
We illustrate the theorems on three small examples; the code is seeded and runs in seconds. (i) For the sharpness family of Theorem 4.3, the ratio in Theorem 4.2 is 0.978, 0.997, 0.9992 and 0.99999 at , 0.2, 0.1, 0.01. (ii) On the lower-bound family of Theorem 5.4 with and (), the root-mean-squared error of the IPW mean, over 2,000 replications at , equals – in every configuration, matching the rate of Theorem 5.3. (iii) Table 1 reports a 20-step lost-sales inventory MDP (capacity 12, orders 0–6, Poisson(3) demand, order cost 1, holding cost 0.5, lost-sale penalty 6), computed exactly by dynamic programming. The covariance identity holds to . The myopic audit understates adaptive value by 22–78%, and the information bound holds with slack, as expected of a worst-case bound when is large.
| Policy | Myopic | Info. bound on | ||||
| Optimal (DP) | 92.66 | 130.14 | 32.5 | 285.9 | ||
| Base-stock 6 | 94.63 | 131.41 | 35.0 | 292.1 | ||
| Noisy base-stock 6 | 98.99 | 136.10 | 11.2 | 172.8 | ||
| Base-stock 9 | 121.63 | 134.68 | 35.1 | 286.8 | ||
| Random closed-loop | 137.87 | 140.51 | 5.5 | 112.7 |
Table 1. Inventory MDP, exact computation. Adaptivity cost ; myopic ; bound (Theorem 4.2); in nats.
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