Escaping Parameter Space: Tight Generalization Bounds via Representation Quality

We derive a tight generalization bound for deterministic neural networks based on their last hidden layer representations. By evaluating representation quality with a parameter-free $k$-nearest-neighbor ($k$-NN) classifier, our certificate avoids traditional parameter-space complexity measures, KL divergences to a posterior, weight norms, and compression. The bound is tight: trained from scratch, it reaches an 8.0 percentage point gap to test error on CIFAR-10 (ResNet-18) and yields the first non-vacuous certificates we are aware of on CIFAR-100; with frozen DINOv2 representations, it certifies at 1.4% on CIFAR-10 and 23.1% on 1,000-class ImageNet. It decomposes additively into three empirical, independently measurable quantities: local class geometry ($k$-NN decoder error), decoder-network agreement, and training stability. This allows the bound to act as a diagnostic tool: we demonstrate that actively destroying local class geometry eliminates generalization while leaving dataset memorization intact, identifying class geometry as a causally relevant mechanism for generalization. Finally, we show that learned representations are significantly less sensitive to weight noise than linear readouts, suggesting why parameter-space certificates often struggle to remain tight.