AI Audit Checklist: Prepare for Your 2026 Examination

What Examiners Are Looking For in 2026

Regulatory examiners are now asking specific questions about AI governance — and many organizations are not prepared to answer them. FFIEC examiners are including AI governance in examination scope. EU AI Act supervisory authorities are beginning conformity assessments. The institutions that fare best are the ones that have done the internal work before the examiner arrives: documented their AI inventory, completed their risk assessments, and built a paper trail that demonstrates active governance.

Your AI Audit Readiness Checklist

• AI governance policy: documented, board-approved, and current
• AI model inventory: complete, including third-party SaaS tools, with risk tiers assigned
• Risk assessments: completed for each AI use case with documented methodology
• Acceptable use policy: communicated to all employees with acknowledgment records
• Vendor due diligence: questionnaires completed for all third-party AI providers
• Data handling guidelines: specifying what data may and may not enter AI systems
• Incident response procedure: documented and tested with defined escalation paths
• Monitoring program: evidence of ongoing model performance review
• Training records: documentation that employees have been trained on AI policies
• Board reporting: evidence that senior management receives AI risk reporting
• EU AI Act classification: AI systems assessed and classified by risk tier

How Audit Preparation Goes Wrong

• Preparing documentation reactively — assembling evidence after an examiner requests it
• Inventories that cover models but not SaaS AI tools adopted by business units
• Risk assessments completed at deployment but never updated as models evolve
• No evidence of board or senior management oversight of AI risk
• Policies that exist on paper but are not operationally implemented or enforced