As MT and GenAI offer seemingly free and instant translation, “shadow translation” is a reality for in-house language services. There is an inevitability in corporate life, that prohibiting people from taking shortcuts, will not stop them from doing so. Similarly, even if there is a path, there will always be a desire path. Well-meaning rules, e.g. banning free MT tools will always be broken, unless sites or tools are blocked.
Such practices are typical examples of shadow translation activities. In organisations with a team of in-house linguists, shadow translation activities often form due to the bottlenecks in translation via language services, i.e. the need for translation outside the official, governed translation process.
Shadow translation serves as an unofficial, parallel or informal translation conduit. They are produced outside of authorised translation workflows. Shadow translations also evade capture in translation management (e.g. job lists, translation memories, or terminology systems). However, they remain in use in the wild by staff members, from trainees through to board members.
What kinds of translations are vulnerable?
But what kind of translations do shadow translation cover? Frequently it may be translations lazily labelled as “for internal use” i.e. for quickly getting into the meaning of a text, for writing something up etc. But, it might be used by staff, if someone doesn’t feel confident enough to draft texts (e.g. e-mails, summaries or speaking notes) by themself. In some situations, staff members may even delegate translation to the non-professional translator bilingual colleagues. This is particularly visible in job descriptions for PAs with an expectation of multilingual written communication.
In the MT/GenAI era, there is the complicit use of MT/LLM-based translation, often without subsequent review (i.e. the translation, due possibly to its deceptive fluency, is passed on “as is”) or not disclosed as being a translation. However, it may include cases of externally translated content that sits outside of internal translation storage systems.
This can also result in siloing in departments and divisions, meaning that there are multiple diverging translations in circulation of the same texts (for example in the case of standard letters, text blocks etc.) This is one reason why I translate each iteration of the standard texts that form administrative decisions for the entire organisation. I ensure that there is a single source of truth, and then only need to focus on the ruling (Spruch) of the individual administrative decision in hand. In process management, where processes contain sample texts about decisions and mails, I also make sure only to include a sample ruling. Other parts of such sample texts refer to the current template to use for the rest.
Is this an issue for translators?
Shadow translation bears numerous risks. From the perspective of a language services unit or a translator in one, the sensitivity is different to that experienced by the users. Users are likely to have a slightly more cavalier approach, and see it as a “victimless crime”.
Unofficial translations, without quality assurance processes, may diverge subtly from the legally binding or authentic wording of a translation. To provide an example, I recently saw a Copilot Agent use case. The purpose of the agent was “legal translation”. The agent saved parallel texts of a piece of EU legislation in two languages as “knowledge” into the agent. The prompt in the agent instructed it to translate a specific provision from one language into another. Without the prompt stating the Spanish text was an authentic translation of the English text, the agent decided to create a back-translation for its English version.
This can quickly create issues (e.g. like distorted messages in a game of Telephone / Stille Post). It leads to parallel translations that are close but not identical. Potential outcomes can be incorrect wording invalidating decisions or misrepresenting obligations. This results in exposing an institution to being challenged about their decisions.
But it’s “only” for internal use, right?
The problem with claiming that something is “for internal use” is a downstream one later down the line. Months or years later an internal text may suddenly become an external one. When this happens, it is like a document crossing an institutional firewall. Translation in language services can frequently be a “black box” for non-translators. Translators on occasion lose themselves in their own processes or their perceived reality. In the worst case, they might actually neglect that they are translating for a specific audience (e.g. the “Clientland” analogy that Chris Durban frequently alludes to). Translators need to also consider how they label translations – and how it will be (continue to be) used after they deliver it to the customer in-house.
Another issue from shadow translation is that it supports terminology drift – with key terms gradually changing their meaning across documents, or where different departments resort to different equivalents for the same source term, or where informal translations take on a reference quality. Variants can slowly leach into accepted use, and are difficult to reverse. In the human-machine translation age, the effects may be more pronounced, as the training of models has shown, as once something is in a model, it can be very difficult to get it back out of a model.
A question of accountability
A further issue for language services can be down to the emergence of accountability gaps. The assumption might be that the error occurred in language services. Within language services, translation memory systems can resolve the team members involved. In turn, it will also identify the customer, reviewer and who signed off on the translator. Shadow translation can’t do that, other than identifying the string of communications. Nevertheless, language services may be caught in the crossfire. It can have the ability to undermine the authority of the official translation function in the blame game. Inconsistencies that they never contributed too nevertheless land at their door! Invisible translation output can also render quality metrics meaningless.
Is shadow translation an accidental or malicious phenomenon?
Ultimately, structural pressures are usually behind the creating of a burgeoning level of shadow translation. These pressures are due to time pressure (everything required now, or better still yesterday!) Available resources in language services might be creating the bottleneck – there are not endless supplies of human translators in all language combinations. AI tools seep out of every pore in corporate life (especially due to the “fear of missing out”!) unwittingly casting translation as being readily available on tap. Another phenomenon has been that of “multilingualism = translator” conflating speaking more than one language to being able to translate. Even children raised as bilingual/multilingual from birth will still gravitate towards one language over another in specific circumstances.
However, sometimes the issue is down having a lack of clear rules, in order to distinguish working, informational, or legally or externally relevant translations. These issues are scaling silently as digital tools develop and potentially even improve.
So this isn’t just about a translators trying to protect their jobs?
When translators try to explain their continuing role in the GenAI-dominated landscape, they are accused of being protectionist. Persona prompts apparently can make everyone an “expert translator specialising in xyz in the language combination A to B”. But the institutional impact is more about governance rather than an out-and-out language one.
Shadow translation circumvents document control, risk management, process transparency and accountability – a point missed by trivialising it as just being a discussion about quality. In this regard – it ties in a lot with the shattering of the triple constraint for translation, that I refer to in my blog posts about the “Expert in the Lead” approach. Particularly, given the fact that human in the loop approaches in translation do not adequately consider risk management and accountability.
The “internal use only” caveat also is a risky approach. Internal documents (e.g. briefing notes) actively shape decisions, which in turn shape actions, which themselves have external and legal consequences. And internal translations can end up becoming de facto reference documents.
Where there is an added dimension due to AI and MT is due to the fact that such tools also play a role in making shadow translation faster, more tempting to use, and harder to detect. Prompting courses invariably mention using prompts to try to “make the text not look like it is AI-written”. This is why institutions need clear policies to avoid uncontrolled MT output, inconsistent style and terminology, as well as false confidence and over-reliance on “good enough” MT output.
We need to talk about cognitive load and cognitive downstreaming
I increasing mention the concern about cognitive downstreaming. Offloading (linguistic) effort to tools or other individuals downstreams review, validation and responsibility involved. If you use a linguist only for the review stage, they have to try to make “informed” decisions without the full information – I’ve started to receive “Copilot translations” (the quotations are intentional!) in English – without being provided a source text. I enquire where the original German text is. After all, if it is a translation, it must be a translation of a German text.
Sometimes it even emerges that the text was in fact prompting output. However, even the detail in the prompt provides me with information that is missing from the English, e.g. about the legal provisions forming the underlying basis (and quickly highlighting that there has been an unnecessary back translation). In the worse cases, the output has read like LLM output, where the German original also doesn’t respect the house authoring and formatting style.
What should institutional practices do to get a grip on shadow translation?
There is a clear near for greater formal distinction in the classification of translations as an approach to shadow translation management. Labelling is an issue that is emerging with the automation of translation of web content. I am fully aware that bad human translations also exist! Take a look at many multilingual tourism websites for private accommodation if you want!
One potential categorisation could be as follows:
- authoritative translations (binding, publishable)
- working translations (informational, internal)
- machine-assisted drafts (explicitly non-authoritative)
Within each category, the permitted uses, visibility requirements and review expectations also need to be specified.
Let there be light! Visibility of unofficial translations
The way that shadow translation has shown that banning a tool only means that someone will look for the next tool to circumvent the ban, is possibly a sign than a more enlightened approach is to not ban shadow translation (as a process or its output).
I’d suggest destigmatisation by recommending to improve their visibility. However, there would be some requirements, namely:
- enforced use of labelling (e.g. also involving the categorisations mentioned above).
- requiring storage in a shared environment, with the source text available in the same location.
- compulsory disclosure about the use of MT/GenAI (this can also help reduce cognitive downstreaming).
Favouring a visibility approach, over prohibiting shadow translation, can also help ensure a steady work for professional translators. For example, quality scoring of shadow translations can form a ranking for permit the prioritising items for translation to ensure greater availability of authoritative translations.
Visibility on the other hand, can also mean improved centralisation and availability of language data (e.g. from translation memories or terminology databases). Two such approaches are what RWS calls “generative translation” or Kaleidoscope calls “TAG (terminology augmented generation). I’m hoping to be able to convince my employer to allow more effective terminology sharing than in the old-fashioned “bilingual glossary”. That product is no longer cutting edge, and is high maintenance. Each update consumes a lot of time for a product in an old-fashioned format.
The role of translators in AI governance
Back in 2022, I joined our Innovation Lab, and chose from the outset to take a “voice of reason” approach, which would question use cases, AI governance issues and the like. I tried to be open to innovation, while also ensuring that the recognition of the continuing importance of human translation . They recognised and understood my valid concerns. I emphasised that I was risk aware and possibly somewhat risk averse. Labelling myself the “Spaßbremse” (spoiler of the fun) prevented anyone else from using it in an accusatory tone.
I contributed towards my institution’s AI governance – by highlighting the need for review, and highlighting issues of accountability, reputational loss, and credibility. More importantly, it guaranteed my seat at the table. Langtech solution providers currently struggle to be heard. BigTechs demonstrate their (lack of) knowledge of translation and seem hell-bent on ignoring incumbent niche players. In this regard, my approach was about being heard rather than just to be an end-user.
I’ve also used it to cultivate my role as a “risk sensor”. Deceptive fluency of MT output frequently fails to identify inconsistencies in source texts, ambiguities in policy, legal uncertainty and procedural gaps. Trying to bring the issue of “shadow translation” onto the table is also a case of highlighting that it bypasses governance, rather than my being protectionist or territorial.
So what about a bite-sized takeaway?
Shadow translation is a hidden reality of any organisation with a multilingual environment. Failure to govern shadow translation will lead it to self-govern. Self-governance is inconsistent, invisible and allows the propagation and permeation of risks.




