How frontier AI companies could implement an internal audit function

Fuente: arXiv
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Main Authors: Gomez, Francesca, Buick, Adam, Ferentinos, Leah, Kim, Haelee, Lee, Elley
Format: Preprint
Published: 2025
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author Gomez, Francesca
Buick, Adam
Ferentinos, Leah
Kim, Haelee
Lee, Elley
author_facet Gomez, Francesca
Buick, Adam
Ferentinos, Leah
Kim, Haelee
Lee, Elley
contents Frontier AI developers operate at the intersection of rapid technical progress, extreme risk exposure, and growing regulatory scrutiny. While a range of external evaluations and safety frameworks have emerged, comparatively little attention has been paid to how internal organizational assurance should be structured to provide sustained, evidence-based oversight of catastrophic and systemic risks. This paper examines how an internal audit function could be designed to provide meaningful assurance for frontier AI developers, and the practical trade-offs that shape its effectiveness. Drawing on professional internal auditing standards, risk-based assurance theory, and emerging frontier-AI governance literature, we analyze four core design dimensions: (i) audit scope across model-level, system-level, and governance-level controls; (ii) sourcing arrangements (in-house, co-sourced, and outsourced); (iii) audit frequency and cadence; and (iv) access to sensitive information required for credible assurance. For each dimension, we define the relevant option space, assess benefits and limitations, and identify key organizational and security trade-offs. Our findings suggest that internal audit, if deliberately designed for the frontier AI context, can play a central role in strengthening safety governance, complementing external evaluations, and providing boards and regulators with higher-confidence, system-wide assurance over catastrophic risk controls.
format Preprint
id arxiv_https___arxiv_org_abs_2512_14902
institution arXiv
publishDate 2025
record_format arxiv
spellingShingle How frontier AI companies could implement an internal audit function
Gomez, Francesca
Buick, Adam
Ferentinos, Leah
Kim, Haelee
Lee, Elley
Computers and Society
Software Engineering
Frontier AI developers operate at the intersection of rapid technical progress, extreme risk exposure, and growing regulatory scrutiny. While a range of external evaluations and safety frameworks have emerged, comparatively little attention has been paid to how internal organizational assurance should be structured to provide sustained, evidence-based oversight of catastrophic and systemic risks. This paper examines how an internal audit function could be designed to provide meaningful assurance for frontier AI developers, and the practical trade-offs that shape its effectiveness. Drawing on professional internal auditing standards, risk-based assurance theory, and emerging frontier-AI governance literature, we analyze four core design dimensions: (i) audit scope across model-level, system-level, and governance-level controls; (ii) sourcing arrangements (in-house, co-sourced, and outsourced); (iii) audit frequency and cadence; and (iv) access to sensitive information required for credible assurance. For each dimension, we define the relevant option space, assess benefits and limitations, and identify key organizational and security trade-offs. Our findings suggest that internal audit, if deliberately designed for the frontier AI context, can play a central role in strengthening safety governance, complementing external evaluations, and providing boards and regulators with higher-confidence, system-wide assurance over catastrophic risk controls.
title How frontier AI companies could implement an internal audit function
topic Computers and Society
Software Engineering
url https://arxiv.org/abs/2512.14902