How good is PAC-Bayes at explaining generalisation?

Abstract: We discuss necessary conditions for a PAC-Bayes bound to provide a meaningful generalisation guarantee. Our analysis reveals that the optimal generalisation guarantee depends solely on the distribution of the risk induced by the prior distribution. In particular, achieving a target generalisation level is only achievable if the prior places sufficient mass on high-performing predictors. We relate these requirements to the prevalent practice of using data-dependent priors in deep learning PAC-Bayes applications, and discuss the implications for the claim that PAC-Bayes ``explains'' generalisation.