IIA Makes Recommendations on Development of Artificial Intelligence Action Plan

Auditing | March 18, 2025

IIA Makes Recommendations on Development of Artificial Intelligence Action Plan

The IIA emphasized the importance of establishing clear and measured safeguards governing AI applications, noting the significant impact the technology will have on Americans.

Isaac M. O'Bannon

The Institute of Internal Auditors has submitted a comment letter in response to a request for information from the U.S. Office of Science and Technology Policy (OSTP) entitled “Development of an Artificial Intelligence Action Plan.”

In the letter, The IIA emphasized the importance of establishing clear and measured safeguards governing AI applications, noting the significant impact the technology will have on Americans.

Specifically, The IIA advocated that “a comprehensive AI Action Plan must also highlight the importance of governance, internal controls, and risk management” to support organizations who utilize AI.

Further, the letter noted that “a critical component of any robust risk management analysis – and one The IIA recommends should be recognized in the AI Action Plan – is the complementary role of an organization’s internal audit function. An internal audit function – operating in conformity with the Global Internal Audit Standards – is the entity responsible for providing an organization’s governing body with objective assurance over AI related risk management and internal control processes.”

The IIA recommends that the AI Action Plan empower the private sector to execute assurance responsibilities through internal audit, rather than “establish a traditional regulatory regime directing a specific government agency to audit AI operations.”

As OSTP explores policy solutions to promote American leadership in AI, the internal audit profession is uniquely positioned to facilitate private sector-based transparency and accountability.

For this reason, The IIA asked OSTP to address the following topics in the AI Action Plan:

1) Recognize the Significance of AI Risk Management and Governance: The IIA supports a greater policy emphasis concerning the need for appropriate risk management and governance processes related to implementing and using AI in business operations.

 2) Strengthen Internal AI Oversight: Utilize internal audit-led assurance processes for evaluating an organization’s AI-related internal controls, risk management and governance structures.  The presence of a qualified internal audit function will strengthen independent oversight efforts and increase consumer confidence.”

The IIA appreciates OSTP’s consideration of our recommendation on behalf of the internal audit profession and looks forward to continuing a productive dialogue on this critically important topic to the lives of all Americans.

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