Statistical Learning Theory for Direct Preference Optimization

Direct Preference Optimization (DPO) learns from pairwise preferences through a logistic objective whose score-difference parameterization follows the Bradley--Terry model. We study how failure of this modeling assumption limits DPO, distinguishing structural misspecification from limited model capacity and finite-sample estimation. Our main contribution is a characterization of structural approximation error through the triangle-curl of the preference log-odds, which vanishes exactly when preferences admit a Bradley--Terry representation. We upper bound the achievable excess logistic risk by a score-class approximation term and a triangle-curl term, and establish a lower bound proportional to triangle-curl under additional boundedness assumptions. For ReLU score models, including clipped models, we derive explicit approximation rates showing that increasing capacity can eliminate the score-approximation term while leaving the structural obstruction unchanged. We further establish finite-sample bounds for clipped empirical risk minimizers that separate network approximation, structural misspecification, and estimation error. We place these results within a surrogate-risk framework by identifying contextual preference accuracy (CPA) as a natural measure of agreement between preference judgments and changes in pairwise probability ratios relative to the reference policy. Standard logistic consistency and calibration results connect DPO's objective to this policy property and transfer our excess-risk upper bounds to CPA, without treating CPA as a complete measure of generated-response quality.