Comment by TechNet

TechNet believes it is premature to mandate independent third-party auditing of AI systems. Mandating an independent audit before appropriate technical standards and conformity assessment requirements are established could open AI systems to national security threats, trade secrets theft, and inaccurate audit reports. We believe AI auditing standards, ethics, or oversight rules must consider the use-case-specific auditing needs, calibrated to the risk of the specific use case, set to measurable benchmarks, and ensure safe and ethical practices to promote continued innovation while also protecting intellectual property, trade secrets, and security. Any transparency, explainability, or audit requirements imposed on AI systems must account for protecting personal information, and carefully balance the proprietary and trade secret protections regarding the AI system and the technical feasibility of implementing such requirements. It must also not jeopardize the safety systems of AI-driven services.