Who Audits Whom, on What Substrate, with What Evidence? An Independence-Graded Audit Protocol for Agentic AI

Abstract

Agentic AI systems plan, invoke tools and act with limited supervision; they are now both the subject of audits and, increasingly, the auditor. Independence, the foundation of assurance,is still applied to them as a binary. We argue that it must be graded along three orthogonal axes: principal independence (who controls the auditor), substrate independence (an auditor sharing the auditee's foundation-model family, toolchain or guardrails fails with it) and evidence independence (whether evidence is attestable rather than self-reported). Each axis has precedent; the contribution is to grade all three on a single audit, aggregate them by the weakest link, and apply the same rubric when the auditor is itself an agent. We give the model a formal basis by transplanting the beta-factor model of common-cause failure from reliability engineering, a seven-step protocol whose outputs a third party can verify, a structural detectability analysis of a procurement-controls agent audited at three grades, and a Monte Carlo study of the model in which a conventional internal audit of an agent-a real audit team, a second agent, provider logsp-surfaces 5.9% of the faults it could in principle see and none at all in half the fault classes. We map the triple to the EU AI Act as amended, ISO/IEC 42006, UK public-sector risk-management guidance and audit-regulator practice.