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SSRN: Serval says frontier-model auditors should be statutory and based outside developers' home jurisdictions
In an October 13, 2026 SSRN preprint, Thomas Serval argues that neither AI evaluation nonprofits nor large U.S. consulting networks meet the independence standards auditors have applied since Sarbanes-Oxley, so neither should serve as the independent external auditor required by the September 29, 2026 White House Accord on Super Intelligence. He proposes six eligibility criteria and a transnational college of auditors.
Key points
- The accord committed the six largest American AI developers to engage an independent external auditor without defining who qualifies.SSRN
- Serval says existing frameworks already cover non-financial assurance, including ISAE 3000, the IESBA independence code and public audit oversight.SSRN
- What is missing, he argues, is a statutory auditor free of advisory ties to the developer and subject to public oversight.SSRN
- His central claim is that the auditor should be established outside the audited developer's own jurisdiction.SSRN
- He applies six eligibility criteria symmetrically, so a U.S. auditor could review European developers and vice versa.SSRN