Implementation Kit
AI Three Lines of Defense RACI and Audit Templates
Applying the three-lines model to AI risk without the second line rubber-stamping what it cannot evaluate. A RACI across the lines, a second-line technical literacy assessment, a risk committee reporting template, and a third-line audit program.
Who this is for: The risk or audit leader mapping AI risk onto an existing three-lines structure.
1. Three lines of defense RACI for AI
SpreadsheetEach governance activity assigned across first line (owns and manages), second line (oversees and challenges), and third line (independent assurance).
Template
| Activity | First line (business / product) | Second line (risk / compliance) | Third line (internal audit) |
|---|---|---|---|
| AI system inventory and classification | R/A | C (challenge tiering) | I (test completeness) |
| Model risk assessment | R | A (set method, review) | I |
| Bias and performance testing | R (run) | A (standard, review results) | I (re-perform sample) |
| Human oversight operation | R/A | C | I |
| Vendor AI risk | R | A | I |
| Incident response | R | C | I |
| Regulatory obligation tracking | C | R/A | I |
| Governance reporting to the board | C | R | A (opinion on the program) |
Worked example
The contested calls, with the reasoning.
| Activity | First line | Second line | Third line |
|---|---|---|---|
| Bias testing | runs it in the model pipeline | owns the methodology; reviews every high-risk result pre-ship | re-performs on a sample of models each year |
| Regulatory tracking | consulted on which systems are affected | R/A (compliance owns it) | tests coverage |
| Board reporting | consulted | drafts the report | independent opinion on whether the program is effective, not just present |
Acceptance criteria
- ✓Every activity has one accountable line, and the second line's role is challenge, not execution.
- ✓Third line has an independent assurance role on every activity, including the program itself.
- ✓Role labels match the organization's actual functions.
2. Second-line AI technical literacy assessment
SpreadsheetConfirms the oversight function can actually evaluate what it signs off. Oversight without competence is theatre.
Template
| Capability | Needed to oversee | Current state | Gap action |
|---|---|---|---|
| Read and question a model card and eval report | model risk sign-off | ||
| Interpret a disparate-impact and subgroup analysis | bias oversight | ||
| Assess whether a human oversight design is meaningful | oversight review | ||
| Evaluate a red-team report and residual risk | security sign-off | ||
| Understand agentic autonomy and containment concepts | agent deployments | ||
| Read a monitoring dashboard and judge a drift response | ongoing oversight |
Worked example
| Capability | Current state | Gap action |
|---|---|---|
| Question a model card / eval | 1 of 4 risk staff comfortable | training + a technical advisor embedded |
| Interpret disparate-impact analysis | 2 of 4 | workshop with DS; a checklist aid |
| Judge human oversight design | strong | none |
| Evaluate a red-team report | weak | pair with Security on the next two reviews |
| Agentic concepts | none | bring in external training Q4 |
| Read monitoring dashboards | moderate | shadow the ML on-call review monthly |
Acceptance criteria
- ✓Each capability is rated against a real standard, not self-declared confidence.
- ✓Gaps have a concrete action (training, advisor, pairing), not "upskill".
- ✓The assessment is repeated as the second line takes on new AI risk types.
3. AI risk committee reporting template
DocumentThe second line's standing report to the risk committee: posture, movement, and what needs a decision.
Template
One to two pages, standing agenda item.
- AI risk posture: systems by tier; high-risk systems with an open control gap; overdue reviews
- Movement since last meeting: new systems, retired systems, tier changes, closed and opened gaps
- Incidents and near-misses: count by severity, status, lessons
- Second-line challenges raised: where oversight pushed back on first line, and the outcome
- Regulatory: obligations approaching, readiness
- Third-line findings: open audit findings and remediation status
- Decisions requested
Worked example
- Posture: 47 systems (3 High, 12 Limited, 32 Minimal). 1 High-tier gap (resume-screener oversight design). 4 overdue reviews, down from 7.
- Movement: 2 new (both Limited); support-copilot moved Minimal to Limited; F-1 gap closed.
- Incidents: 0 Sev-1, 2 Sev-2 (both closed with fixes).
- Second-line challenges: blocked a fraud-model deploy pending an updated bias eval; resolved in 5 days.
- Regulatory: CA ADMT product work at risk; escalated.
- Third-line: 2 open findings from the H1 audit, both on track.
- Decisions requested: approve Q1 budget for ADMT tooling.
Acceptance criteria
- ✓The report shows movement, not just a snapshot.
- ✓It records where the second line challenged the first line and what happened.
- ✓Third-line findings and their status appear every cycle.
4. Third-line AI audit program
SpreadsheetWhat internal audit tests to give an independent opinion on the governance program, not just individual systems.
Template
| Audit area | What is tested | Method | Frequency |
|---|---|---|---|
| Inventory completeness | is every AI system actually captured? | independent discovery, compare to the register | annual |
| Classification accuracy | are tiers assigned correctly and consistently? | re-classify a sample | annual |
| Control operation | do documented controls actually run? | test a sample against system behaviour, not just policy | annual |
| Second-line effectiveness | does oversight have competence and independence? | review challenge logs; competence assessment | annual |
| Incident handling | were incidents classified, notified, and remediated per policy? | trace a sample end to end | annual |
| Board reporting accuracy | does the board picture match reality? | reconcile a past report to source data | annual |
Worked example
H1 audit summary.
| Audit area | Result |
|---|---|
| Inventory completeness | independent discovery found 2 systems not in the register (both Minimal); onboarding checkpoint not consistently applied |
| Classification accuracy | re-classified 10; 1 disagreement (borderline Limited/High), resolved to High |
| Control operation | tested 8 controls on 6 systems; 2 "documented not enforced" (monitoring alerting, low-score review) |
| Second-line effectiveness | challenge log healthy; competence gap on red-team evaluation noted |
| Overall opinion | effective, with improvements needed on control enforcement and onboarding discipline |
Acceptance criteria
- ✓Audit uses independent testing (re-discovery, re-classification, behaviour testing), not self-reported status.
- ✓The program tests the second line and the board reporting, not only first-line systems.
- ✓It produces an overall opinion on program effectiveness.
Governance controls this kit produces evidence for
Completing the artifacts above gives you a head start on the evidence requirements for these controls.
The RACI and third-line program are the continuous AI assurance function design.
The third-line opinion and any maturity grid feed the governance maturity assessment.
The three-lines RACI clarifies committee decision rights and escalation.
The risk committee reporting template is board and committee risk reporting.
Audit findings become governance-program milestones.
This kit backs one playbook. Read the full guidance for the reasoning behind each artifact.
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