The Forgetting-Retention Dilemma: Certified Unlearning Theory in Continual Learning

Yiting Hu, Lingjie Duan, Qian Zhang
Proceedings of the 43rd International Conference on Machine Learning, PMLR 306:44936-44975, 2026.

Abstract

Machine unlearning aims to eliminate the influence of specific data from trained models to safeguard privacy. However, this presents a significant challenge in the context of continual learning (CL), where models update sequentially on dynamic datasets. A major limitation is that current certified unlearning algorithms fail to account for the complex, cumulative model evolution inherent to CL framework. In this work, we establish the first theoretical foundation bridging CL and machine unlearning. We formulate the CL’s unlearning objective as the minimization of post-unlearning excess risk, which decomposes into CL excess risk and unlearning loss, characterizing the fundamental trade-off between preserving historical knowledge and targeted forgetting. Under mild assumptions, we first establish an upper bound for the CL excess risk in non-convex models. We then adapt two certified unlearning approaches, gradient-based and Hessian-based, to the CL framework. Our analysis reveals that while the gradient-based approach is less effective than the Hessian-based method in minimizing unlearning loss, it offers the distinct advantage of nearly zero storage overhead for enabling unlearning. This insight motivates a hybrid strategy that reduces storage costs while maintaining post-unlearning performance. Experimental results further validate our theoretical findings.

Cite this Paper


BibTeX
@InProceedings{pmlr-v306-hu26o, title = {The Forgetting-Retention Dilemma: Certified Unlearning Theory in Continual Learning}, author = {Hu, Yiting and Duan, Lingjie and Zhang, Qian}, booktitle = {Proceedings of the 43rd International Conference on Machine Learning}, pages = {44936--44975}, year = {2026}, editor = {Zhang, Tong and Dudik, Miroslav and Jaggi, Martin and Agarwal, Alekh and Li, Sharon and Schuurmans, Dale and Zhu, Jerry and Berkenkamp, Felix and Dong, Hanze and Bietti, Alberto}, volume = {306}, series = {Proceedings of Machine Learning Research}, month = {06--11 Jul}, publisher = {PMLR}, pdf = {https://raw.githubusercontent.com/mlresearch/v306/main/assets/hu26o/hu26o.pdf}, url = {https://proceedings.mlr.press/v306/hu26o.html}, abstract = {Machine unlearning aims to eliminate the influence of specific data from trained models to safeguard privacy. However, this presents a significant challenge in the context of continual learning (CL), where models update sequentially on dynamic datasets. A major limitation is that current certified unlearning algorithms fail to account for the complex, cumulative model evolution inherent to CL framework. In this work, we establish the first theoretical foundation bridging CL and machine unlearning. We formulate the CL’s unlearning objective as the minimization of post-unlearning excess risk, which decomposes into CL excess risk and unlearning loss, characterizing the fundamental trade-off between preserving historical knowledge and targeted forgetting. Under mild assumptions, we first establish an upper bound for the CL excess risk in non-convex models. We then adapt two certified unlearning approaches, gradient-based and Hessian-based, to the CL framework. Our analysis reveals that while the gradient-based approach is less effective than the Hessian-based method in minimizing unlearning loss, it offers the distinct advantage of nearly zero storage overhead for enabling unlearning. This insight motivates a hybrid strategy that reduces storage costs while maintaining post-unlearning performance. Experimental results further validate our theoretical findings.} }
Endnote
%0 Conference Paper %T The Forgetting-Retention Dilemma: Certified Unlearning Theory in Continual Learning %A Yiting Hu %A Lingjie Duan %A Qian Zhang %B Proceedings of the 43rd International Conference on Machine Learning %C Proceedings of Machine Learning Research %D 2026 %E Tong Zhang %E Miroslav Dudik %E Martin Jaggi %E Alekh Agarwal %E Sharon Li %E Dale Schuurmans %E Jerry Zhu %E Felix Berkenkamp %E Hanze Dong %E Alberto Bietti %F pmlr-v306-hu26o %I PMLR %P 44936--44975 %U https://proceedings.mlr.press/v306/hu26o.html %V 306 %X Machine unlearning aims to eliminate the influence of specific data from trained models to safeguard privacy. However, this presents a significant challenge in the context of continual learning (CL), where models update sequentially on dynamic datasets. A major limitation is that current certified unlearning algorithms fail to account for the complex, cumulative model evolution inherent to CL framework. In this work, we establish the first theoretical foundation bridging CL and machine unlearning. We formulate the CL’s unlearning objective as the minimization of post-unlearning excess risk, which decomposes into CL excess risk and unlearning loss, characterizing the fundamental trade-off between preserving historical knowledge and targeted forgetting. Under mild assumptions, we first establish an upper bound for the CL excess risk in non-convex models. We then adapt two certified unlearning approaches, gradient-based and Hessian-based, to the CL framework. Our analysis reveals that while the gradient-based approach is less effective than the Hessian-based method in minimizing unlearning loss, it offers the distinct advantage of nearly zero storage overhead for enabling unlearning. This insight motivates a hybrid strategy that reduces storage costs while maintaining post-unlearning performance. Experimental results further validate our theoretical findings.
APA
Hu, Y., Duan, L. & Zhang, Q.. (2026). The Forgetting-Retention Dilemma: Certified Unlearning Theory in Continual Learning. Proceedings of the 43rd International Conference on Machine Learning, in Proceedings of Machine Learning Research 306:44936-44975 Available from https://proceedings.mlr.press/v306/hu26o.html.

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