KPMG’s submission paper for introducing mandatory guardrails for AI in high-risk settings.
 
As a leading professional services firm, KPMG Australia (KPMG) is committed to meeting the requirements of all our stakeholders – not only the organisations we audit and advise, but also employees, governments, regulators – and the wider community. We strive to contribute in a positive way to the debate that is shaping the Australian economy and we welcome the opportunity to provide a submission in response to the Introducing mandatory guardrails for AI in high-risk settings proposals paper.

This submission builds on KPMG’s previous engagement in the safe and responsible development of AI in Australia and globally. KPMG has provided a number of submissions to various forums on this topic, including Safe and Responsible AI in Australia in August 2023, Automated Decision Making and AI Regulation in July 2022, An AI Action Plan for all Australians in December 2020, the Australian Data Strategy in July 2022, and Human Rights and Technology in 2020 and Beyond in March 2020. KPMG published a report with the AIIA in March 2023, Navigating AI: analysis and guidance on use and adoption, which examines the global and domestic regulatory landscape in the Artificial Intelligence space.

KPMG is an early and active user of AI, having partnered with Microsoft to streamline the deployment of AI in our back-office functions and consider its use across tax, audit and advisory work.1 Through our Trusted AI Framework, KPMG is also committed to a human-centred approach to responsible AI that we apply to the design and deployment of AI within the firm.

KPMG is considered both a developer and deployer of AI applications in Australia and has been on a journey over the last few years, evolving a robust AI governance structure and putting in place appropriate policies and processes that underpin our approach to responsible AI. KPMG is also working towards a certification against the ISO42001:2023 AI Management System Standard.

The submission outlines 14 recommendations at section one and directly addresses the consultation questions at section two. If you would like to discuss the contents of this submission further, please do not hesitate to reach out. KPMG looks forward to continuing engagement with the Australian Government as it develops a safe and responsible framework for AI in Australia.

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