Auditing large language models: a three-layered approach

The emergence of large language models (LLMs) represents a major advance in artificial intelligence (AI) research. However, the widespread use of LLMs is also coupled with significant ethical and social challenges. Previous research has pointed towards auditing as a promising governance mechanism to help ensure that AI systems are designed and deployed in ways that are ethical, legal, and technically robust. However, existing auditing procedures fail to address the governance challenges posed by LLMs, which are adaptable to a wide range of downstream tasks. To help bridge that gap, we offer three contributions in this article. First, we establish the need to develop new auditing procedures that capture the risks posed by LLMs by analysing the affordances and constraints of existing auditing procedures. Second, we outline a blueprint to audit LLMs in feasible and effective ways by drawing on best practices from IT governance and system engineering. Specifically, we propose a three-layered approach, whereby governance audits, model audits, and application audits complement and inform each other. Finally, we discuss the limitations not only of our three-layered approach but also of the prospect of auditing LLMs at all. Ultimately, this article seeks to expand the methodological toolkit available to technology providers and policymakers who wish to analyse and evaluate LLMs from technical, ethical, and legal perspectives.