Context. Deep networks fit noisy labels exactly and still predict well. Bartlett, Long, Lugosi and Tsigler (BLLT, 2020) take the simplest version of the puzzle and ask when, in linear regression with a general covariance Σ, the minimum-norm interpolant of noisy data has excess risk near zero. They give nearly matching upper and lower bounds for arbitrary Σ, n and dimension in terms of two effective ranks of the tail of the spectrum. Tsigler and Bartlett (TB, 2023) extend the answer to ridge at every penalty above a critical negative value, bound the bias sharply too, need only sub-Gaussian rows plus the condition number of one random matrix, and explain when the best penalty is negative. The argument splits the spectrum at an index k. The top k directions are learned, up to constants, as ridge regression on n samples with penalty λ+∑i>kλi, because the tail's Gram matrix is close to a multiple of In and its energy acts as an implicit ridge; the tail itself is not learned and absorbs the label noise. The interpolated noise is harmless when there are few head directions and the tail has many more than n roughly equal small eigenvalues, and the signal is learned when it sits in head directions with λi well above (λ+∑i>kλi)/n.
Setting. Rows of X∈Rn×p are i.i.d. and mean zero with covariance Σ=diag(λ1≥λ2≥⋯), p possibly infinite, and y=Xθ∗+ε with noise level σ2. BLLT assume x=Σ1/2z with independent unit-variance σx2-sub-Gaussian coordinates of z, and noise with E[ε2∣x]≥σ2 that is conditionally σy2-sub-Gaussian; TB assume only sub-Gaussian whitened rows (norm σx) and noise of variance σ2 (their vε2) independent of X. The estimator is
θ^=X⊤(λIn+XX⊤)−1y,λ>−μn(XX⊤),
ridge for λ>0 and the minimum-norm interpolant at λ=0. Everything is read off two effective ranks of the tail,
rk=λk+1λ+∑i>kλi,Rk=∑i>kλi2(∑i>kλi)2:rk is the tail mass in units of its largest eigenvalue and Rk measures how evenly that mass is spread. Write ρk=rk/n (ρk(0) at λ=0), λˉ=(λ+∑i>kλi)/n for the effective penalty per sample, and k∗=min{k:rk≥bn} for a constant b depending only on the sub-Gaussian norm.
Min-norm interpolant (BLLT, Theorem 4). At λ=0, there are constants b,c depending only on σx such that, for log(1/δ)<n/c: if k∗≥n/c then ER(θ^)≥σ2/c; otherwise, with probability 1−δ,
R(θ^)≤c∥θ∗∥2∥Σ∥max{nr0,nr0,nlog(1/δ)}+clog(1/δ)σy2(nk∗+Rk∗n),
and ER(θ^)≥(σ2/c)(k∗/n+n/Rk∗). The first term is the bias and the second the variance, tight up to constants and the log(1/δ) and σy2/σ2 factors: k∗/n is the variance from the head directions, which are fit like least squares with n samples, and n/Rk∗ the variance from absorbing the noise in the tail. The bias bound is a worst case over ∥θ∗∥, and it is nearly necessary: for Gaussian x and every t there is a θ∗ with ∥θ∗∥=t and noise variance t2∥Σ∥ such that, with probability 1/4, R(θ^)≥t2∥Σ∥/c whenever r0/(nlog(1+r0))≥c′. A sequence Σn with ∥Σn∥=1 is benign when r0/n, k∗/n and n/Rk∗ all tend to zero; this is sufficient for R(θ^)→0, and necessary with r0/n replaced by r0/(nlog(1+r0)).
Ridge at any noncritical penalty (TB, Theorems 1, 2 and 10). Write the noise-averaged risk as bias plus variance, B+σ2V. Suppose λ>−γ∑i>kλi with γ<1 (NoncritReg) and that the tail Gram matrix Ak=λIn+Xk:∞Xk:∞⊤ is positive definite with condition number at most L with probability 1−δ (CondNum), for some k<n/c. Then (Theorem 1) at min(k,k∗), which we again call k, with probability 1−δ−ce−n/c,
cB≤∥θk:∞∗∥Σk:∞2+∥θ0:k∗∥Σ0:k−12λˉ2,cV≤nk+(λ+∑i>kλi)2n∑i>kλi2.
At λ=0 the variance part is the BLLT rate without independent coordinates, and the bias part, which sees how θ∗ aligns with the spectrum, is new. Matching lower bounds (Theorem 2) hold for k≤k∗ with ρk bounded below: for V under independent coordinates, and for B averaged over random signs of θ∗ under exchangeable coordinates and CondNum. Wherever both theorems apply, up to constants,
B≍i∑λiθi∗2(λˉ+λi)2λˉ2,V≍n1i∑(λˉ+λi)2λi2,
the bias and variance of population ridge with penalty nλˉ, a form that needs no tracking of k∗.
Step 1 (both papers)
The risk is a bias form plus a noise form. With A=λIn+XX⊤, substituting y=Xθ∗+ε gives θ^−θ∗=(X⊤A−1X−I)θ∗+X⊤A−1ε, so the risk is at most 2B+2ε⊤Cε with bias B=∥(X⊤A−1X−I)θ∗∥Σ2 (at λ=0, B=θ∗⊤PΣPθ∗ with P the projection onto kerX) and C=A−1XΣX⊤A−1. In expectation over ε the cross term vanishes and the noise part averages to σ2V with V=tr(C) (at least σ2V under BLLT's E[ε2∣x]≥σ2, which gives the lower bounds), and a Hanson-Wright bound for sub-Gaussian noise keeps the realized value within a constant times log(1/δ)σy2V.
Step 2 (BLLT)
The variance is a sum of one term per eigendirection, and Sherman-Morrison makes each term explicit. Whiten each eigendirection, zi=Xvi/λi, and write V=∑iλi2zi⊤A−2zi with A=λIn+∑iλizizi⊤. Pull direction i out of A with Sherman-Morrison:
λi2zi⊤A−2zi=(1+λizi⊤A−i−1zi)2λi2zi⊤A−i−2zi.
Under BLLT's independent coordinates the zi are independent, so zi is independent of A−i and both pieces are quadratic forms of a fresh subgaussian vector against a fixed matrix, and they concentrate. For a strong direction the denominator is large and the term matches the least-squares variance; for a weak one it is near 1, and that direction is shrunk as in ridge. The rest of the proof controls A−i.
Step 3 (BLLT)
The tail Gram matrix is a nearly isotropic ridge exactly when rk≥bn. For a fixed unit v, v⊤Xk:∞Xk:∞⊤v=∑i>kλi(v⊤zi)2 is a weighted sum of subexponential variables, so Bernstein and a net over the sphere put every eigenvalue of the tail Gram matrix in
c1i>k∑λi−cλk+1n≤μn≤μ1≤c(i>k∑λi+λk+1n).
Since ∑i>kλi=λk+1rk at λ=0, the additive λk+1n is negligible exactly when rk≥bn. Interlacing past the rank-k head gives μk+1(A−i)≤μ1(Ak) for all i and μn(A−i)≥μn(Ak) for i≤k. The top k directions are rank-one spikes added to a near multiple of the identity of size ∑i>kλi.
Step 4 (BLLT)
Upper bound; head directions contribute 1/n each and tail directions are ridge-shrunk. Fix k≤n/c with rk≥bn. For a head term, drop the 1 in the denominator and bound the numerator by ∥zi∥2/μn(A−i)2; the denominator cannot use μ1(A−i), which contains the other head spikes, so restrict zi to the bottom n−k eigenvectors of A−i, a subspace independent of zi that keeps all but k≤n/c of its dimensions; each head term is O(1/n), the least-squares rate. For tail terms use only μn(A)≳∑j>kλj and Bernstein for ∑i>lλi2∥zi∥2≤cn∑i>lλi2. Together, for every cutoff l≤k,
V≤c(nl+n(∑i>kλi)2∑i>lλi2),
so each tail direction is shrunk by the factor λi/∑j>kλj, and its share of the noise is weighted by λi at prediction time.
Step 5 (BLLT; reused by TB)
The lower bound holds term by term and is summed without a union bound. Reverse Step 4 using only the upper eigenvalue bound, which holds for any Σ: the bottom n−k eigenvalues of A−i are at most of order nλk+1(1+ρk), so restricting zi to their eigenvectors as in Step 4 gives zi⊤A−i−1zi≳1/(λk+1(1+ρk)). Cauchy-Schwarz, (zi⊤A−i−1zi)2≤∥zi∥2zi⊤A−i−2zi, bounds the Sherman-Morrison ratio below by 1/(∥zi∥2(1+(λizi⊤A−i−1zi)−1)2), so with probability 1−ce−n/cλi2zi⊤A−2zi≥cn1min{1,λk+12(1+ρk)2λi2}.
There may be infinitely many directions, so a union bound is useless; a first-moment argument (BLLT's Lemma 15, TB's Lemma 26) shows that if each ηi≥0 exceeds ti with probability 1−δ, then ∑iηi≥21∑iti with probability 1−2δ, with no independence needed, which matters because all the terms share A. If rk<bn for every k≤n/c, the first n/c terms contribute order 1/n each and ER≥σ2/c. TB run the same argument for any λ, with ∣A−i∣ in place of A−i when λ<0.
Step 6 (BLLT)
The optimal cutoff is l=k∗, which gives k∗/n+n/Rk∗. When rk≥bn, since λi is nonincreasing and the second entry of the minimum is at most 1 for i>k, the summed lower bound is, up to constants, a minimum over cutoffs l≤k of the Step 4 upper bound. Any qualifying k gives ∑i>kλi within constants of μn(A), so take k=k∗. The objective puts index i in the head iff λi≥λˉ/b, and minimality of k∗ with the recursion rk=λk+1λk(rk−1−1) places that threshold exactly between λk∗ and λk∗+1, so l=k∗ and the value is k∗/n+n/Rk∗. Going past k∗ cannot help, because an identity for 1/Rk+1 shows that k/(b2n)+n/Rk increases once rk>bn; with Step 1 this proves the variance parts of Theorem 4.
Step 7 (BLLT)
The bias is bounded by a covariance-estimation error, and its lower bound puts θ∗ on the top eigenvector. The projection P onto kerX annihilates the empirical covariance, so
θ∗⊤PΣPθ∗≤Σ−n1X⊤X∥θ∗∥2,
which the Koltchinskii-Lounici bound controls through r0, whatever the alignment of θ∗. For the lower bound take θ∗=tv1: when r0≥Cn, Step 3 with k=1 shows the interpolant keeps only a fraction of order n/r0 of θ∗, so the bias is at least t2∥Σ∥/4, and since ε is symmetric, R(θ^) is at least the bias with conditional probability 1/2. The paper argues instead by reduction to learning from labels rounded to a fine grid (a dither undoes the rounding up to total variation nα over the sample) and counting: grouping coordinates into d=Ω(nlogn) blocks of eigenvalue mass in [1,2) gives a packing, at scale 3τ in the Σ-norm, of size (1/τ)Ω(d), and for packing points g in the unit ball ∣xt⊤g∣≤∥xt∥ allows only exp(O(nlog(nd))) distinct quantized label vectors, too few to recover them all.
Step 8 (BLLT, Theorem 6)
Which spectra are benign, by parametrizing spectra through their effective ranks. The sequence rk determines λ up to scale through λk+1rk=λkrk−1(1−rk−1−1), so the conditions can be checked in r: for increasing rk, k∗/n→0 iff rn/n→∞, and Stolz-Cesaro gives n/Rk∗→0 whenever rk−2=o(rk−1−rk+1−1). For fixed Σ with λk=k−αln−β(k+1), overfitting is benign iff α=1,β>1: there r0 is finite, rn=Θ(nlogn) and rk+1−rk→∞, so all three conditions hold; for α>1, rn=O(n) and k∗/n→0; for α<1 or β≤1 the spectrum is not summable. In finite dimension pn, Rk≤pn−k forces pn=ω(n), and even an exponentially decaying γk=Θ(e−k/τ) is benign once an isotropic floor ϵn is added, iff pn=ω(n) and ne−o(n)=ϵnpn=o(n); the floor must not be exponentially small because k∗=τln(n/(ϵnpn))+O(1), and then Rk∗=Θ(min{n2,pn}).
Step 9 (TB)
The head solves a k-dimensional ridge problem, and every upper bound follows from it. Write A=Ak+X0:kX0:k⊤ in θ^0:k=X0:k⊤A−1y and multiply out:
θ^0:k+X0:k⊤Ak−1X0:kθ^0:k=X0:k⊤Ak−1y,
the normal equation of generalized least squares on the head with weight Ak−1 and unit ridge; if Ak≈(λ+∑i>kλi)In, it is ordinary ridge at penalty λ+∑i>kλi. Testing the identity against θ^0:k and dropping ∥θ^0:k∥2≥0 bounds the head variance by the OLS rate k/n times the squared condition number of Ak; the same move on the error bounds the head bias by ridge shrinkage ∥θ0:k∗∥Σ−12λˉ2 plus the tail signal acting as noise. The tail needs no structure: A⪰Ak bounds its variance by n∑i>kλi2/μn(Ak)2, and its bias is the unlearned signal ∥θk:∞∗∥Σ2 plus two leakage terms carrying λk+1 and a factor 1+λ−/μn(Ak), λ−=max(0,−λ), the only place where a negative ridge enlarges the bound. All of these bounds are deterministic on {Ak≻0}, in terms of μ1(Ak), μn(Ak) and the head sample covariance, which Step 10 pins down.
Step 10 (TB)
Concentration pins the eigenvalues of Ak, and CondNum reduces to a small-ball condition. The only uniform convergence used is in the k-dimensional head (its sample covariance is close to nIk). The trace of Ak concentrates at n(λ+∑i>kλi) (Lemma 25), fixing the average eigenvalue; NoncritReg, ∑i>kλi≤(λ+∑i>kλi)/(1−γ), keeps the trace's fluctuation, of order nt∑i>kλi at deviation level t, a fraction t/n/(1−γ) of the mean even for λ<0, and the condition number fixes the rest, so every factor of the general bound becomes a constant (Corollary 6, valid at any such k); a well-conditioned tail in turn forces ρk≥1/c, since μ1(Ak)≥λ+nλk+1/2. Decoupling over random splits of the rows makes the off-diagonal part of Ak small once ρk is large, so the diagonal determines the conditioning (Lemma 3): if ρk≥L2 and minj(λ+∥xj,k:∞∥2) stays a constant fraction of its mean, CondNum holds; conversely CondNum forces ρk≥1/(cL) and, if it holds with probability 1−ce−n/c, the same small-ball bound, since μn(Ak)≤minjAk[j,j]. Sub-Gaussianity alone does not give it: x replaced by 2x or 0 with probability 1/2 each keeps the covariance and ψ2 norm but makes the Gram matrix singular.
Step 11 (TB)
CondNum at an oracle k≥k∗ implies CondNum at k∗, which gives Theorem 1. Lowering k only adds PSD terms to Ak, so its smallest eigenvalue can only grow, while sub-Gaussianity caps the largest at λ+c(nλk∗+1+∑i>k∗λi). The two scales match because the removed mass is small: nλk∗+1=(λ+∑i>k∗λi)/ρk∗<(λ+∑i>k∗λi)/b, and in Theorem 1 k<n/c, so ∑k∗<i≤kλi≤(n/c)λk∗+1<(λ+∑i>k∗λi)/(bc), and c>2/b suffices. So CondNum holds at k∗ (Lemma 11), and Corollary 6 there is Theorem 1.
Step 12 (TB)
The bias lower bound, and why the two forms agree. Averaging over random signs of θ∗ removes the cross terms of B=θ∗⊤Mθ∗, M=(X⊤A−1X−I)Σ(X⊤A−1X−I), and Sherman-Morrison makes each diagonal entry explicit, Mii≥λi/(1+λizi⊤A−i−1zi)2. This needs μn(A−i) bounded below for every i, which follows from CondNum and exchangeable coordinates (A−i⪰Ak for i≤k, and for i>k swapping z1 in for zi makes A−i dominate a copy of Ak); with ∥zi∥2≤2n each term is at least λiθˉi2/(1+2Lλi/λˉ)2, and Lemma 15 sums the terms. Coordinate by coordinate, upper and lower bounds agree iff λi≳λˉ in the head and λi≲λˉ in the tail, that is, when k sits where the spectrum crosses λˉ (Theorem 10). The tail condition is ρk>a; at k=k∗ the head condition follows from ρk−1≤b, which gives λk≥λˉ/b. This is also why the bounds are loose for k≫k∗: coordinates in (k∗,k] have λi≪λˉ and are barely learned, yet a split at k counts 1/n of variance for each of them.
Step 13 (TB, Theorem 19)
A negative ridge can go below a bias lower bound that holds for every λ≥0. For λ≥0 the bias lower bound is monotone in λ, and at λ=0 under independent coordinates the sharper tail eigenvalue bound from BLLT's proof (TB's Lemma 16), ∑i>kλi±c(nλk+1+n∑i>kλi2), applied for i>k to the tail matrix with λiz1 swapped into slot i (same assumptions, though not in general the same law), gives μn(A−i)≥21∑i>kλi once ρk(0)>b, so the head shrinkage is at least of order ∑i>kλi/n (Lemma 17). Negative ridge cancels most of it while keeping Ak well conditioned: set λ=−∑i>kλi+⋄, where ⋄ can go down to the fluctuation nλk+1+n∑i>kλi2 of the tail Gram eigenvalues. With small noise, ⋄≈nλk+1∑i>kλi balances head shrinkage against leakage, and the head bias drops from (∑i>kλi)2/n2 to λk+1∑i>kλi/n, a factor of ρk(0); with larger noise ⋄ instead balances head bias against tail variance, and it stays below ∑i>kλi when vε2≲∥θˉ0:k∥Σ−12(∑i>kλi)4/(n3∑i>kλi2). The theorem: under random signs and independent coordinates, with k=min{κ:ρκ(0)>b}<n/c, the minimizer over λ of Eθ∗B+vε2V is negative with probability 1−ce−n/c provided vε2≤c∥θˉ0:k∥Σ0:k−12min(nk(∑i>kλi)2,n3∑i>kλi2(∑i>kλi)4),ρk(0)>c,∥θˉk:∞∥Σk:∞2≤c1∥θˉ0:k∥Σ0:k−12n2(∑i>kλi)2. In words, the best λ is negative with high probability given small noise, a jump in effective rank (ρk−1(0)≤b but ρk(0)>c, forcing λk/λk+1>c/b) and little tail signal, and the gain is at least of order ρk(0); no matching lower bound is proved in this regime.
Consequences and limits. Benign overfitting needs small total scale (r0=o(n), up to a log, for the bias), few strong directions (k∗=o(n)), a tail that is both heavy and flat (Rk∗≫n), so that the unimportant directions greatly outnumber n, and, by TB's bias bounds (under the assumptions of both their theorems, with k∗<n/c), signal that sits in the head: ∥θk∗:∞∗∥Σ→0 and ∥θ0:k∗∗∥Σ−1λˉ→0. The risk depends on λ only through λ+∑i>kλi, so every λ∈(−γ∑i>kλi,O(∑i>kλi)) is within a constant of the min-norm interpolant: positive λ helps when the implicit regularization is too small (tail variance dominates), negative λ when it is too large. Limits: constants are unspecified; BLLT's covariates must be a linear image of independent coordinates (which excludes RKHS features of low-dimensional inputs and the NTK); TB's upper bound assumes CondNum as an oracle, their lower bounds need independent or exchangeable coordinates and random signs, and the noise must be independent of X (Shamir 2022 has a misspecified counterexample).
Terms
θ^=X⊤(XX⊤)−1y
minimum-norm interpolant; the pseudoinverse solution of the normal equations
rk=(λ+∑i>kλi)/λk+1
tail mass in units of the top tail eigenvalue; rk≥bn makes the tail Gram matrix near isotropic
Rk(Σ)=(∑i>kλi)2/∑i>kλi2
how evenly the tail mass is spread; n/Rk∗ is the tail variance term
k∗=min{k:rk≥bn}
split point between head (fit like ridge or OLS) and tail (implicit ridge); bounds are tight for k≤k∗
λˉ=(λ+∑i>kλi)/n
Effective regularization of the head: explicit ridge plus the tail energy.
Head identity
θ^0:k+X0:k⊤Ak−1X0:kθ^0:k=X0:k⊤Ak−1y: ridge on the head with weight Ak−1.
Alternative form
B~=∑λiθi∗2λˉ2/(λˉ+λi)2, V~=n1∑λi2/(λˉ+λi)2: population ridge at penalty nλˉ.
With probability 1−δ, Ak≻0 and μ1(Ak)/μn(Ak)≤L; for sub-Gaussian data it holds, up to a gap in constants, iff ρk is large and the tail norm satisfies a small-ball condition.
Benign sequence
r0(Σn)/n→0, kn∗/n→0, n/Rkn∗(Σn)→0
Quiz
A tail direction i>k∗ contributes about nλi2/(∑j>k∗λj)2 to tr(C). What is the mechanism?
For i>k∗, λizi⊤A−i−1zi≲1/b, so the denominator is near 1 and the term is governed by the smallest eigenvalue of A, close to ∑j>k∗λj. With ∥zi∥2≈n, summing gives n/Rk∗.
For λk=k−αln−β(k+1) with fixed Σ, why is overfitting benign only at α=1,β>1?
The bias needs summability, so r0(Σ)<∞, while k∗=o(n) needs rn/n→∞, which fails for α>1 where rn=O(n). Only the boundary α=1,β>1 gives both, with rn=Θ(nlogn).
Corollary 6 holds at any k where CondNum holds, yet tightness needs k≤k∗. What goes wrong for k≫k∗?
A coordinate with λi≪λˉ contributes about λi2/(nλˉ2)≪1/n to the variance, so counting it in the head overstates its variance. In the isotropic case the bound becomes k/n+n/(p−k), much larger than n/p.
Under NoncritReg(k,γ), why can no negative λ improve the risk by more than a constant factor over λ=0?
The matching bounds depend on λ only through the effective penalty, which for λ∈[−γ∑i>kλi,0] stays within [1−γ,1]⋅∑i>kλi. Larger gains need λ near −∑i>kλi, where the matching lower bounds fail.
Sources
Peter L. Bartlett, Philip M. Long, Gábor Lugosi, and Alexander Tsigler. Benign Overfitting in Linear Regression. Proceedings of the National Academy of Sciences, 2020.