How to audit your AI outputs for IP risk — a step-by-step framework
16 pages · Provenance infrastructure · CIP Audit Working Group · Updated April 2026
The CIP audit methodology applied to a working AI content pipeline: inventory of ingested content, CDR coverage assessment, output sampling for derivative-rights exposure, NILP screening, and the documentation required to meet Platform Certification audit standards.
This paper is intended to be operational — a senior engineering or compliance lead should be able to read it and structure an internal audit programme directly from its contents.
The six audit areas
- Training corpus inventory: Catalogue all ingested content with source attribution, rights status, and TDM opt-out declarations.
- CDR coverage assessment: Measure what percentage of ingested content has a corresponding Core Data Record in the CIP Rights Registry. Target: 95% for Platform Certification Level 2.
- Output sampling: Random and targeted sampling of AI outputs for derivative-rights exposure. Test against known training sources for substantial similarity.
- NILP screening: Automated and manual screening of outputs for unauthorised use of name, image, likeness, or persona. Voice-clone detection, face-match analysis, and style-attribution testing.
- Provenance chain verification: Confirm that Output-Provenance Blocks are being generated and that the provenance chain is complete from input to output.
- Documentation and compliance evidence: Assemble the audit trail required for Platform Certification assessment, including remediation records for identified violations.
Audit methodology
The CIP audit methodology follows a four-phase cycle: Inventory, Assess, Remediate, Certify. Each phase produces documented outputs that feed into the next. The full cycle should be run quarterly for organisations seeking Platform Certification at Level 2 or above.
Phase 1 — Inventory: Build a complete catalogue of training data sources. For each source, record: the content type, the rights holder (where known), the licence basis for ingestion, and whether a TDM opt-out declaration exists. The inventory should be machine-readable and cross-referenced with the CIP Rights Registry.
Phase 2 — Assess: Run the six audit areas against the inventory. Produce a risk score for each area. Identify gaps where rights are unclear, coverage is below threshold, or outputs show potential infringement.
Phase 3 — Remediate: For each identified gap, implement the appropriate remediation: remove content from corpus, obtain retrospective licence, add CDR coverage, implement output filtering, or add provenance documentation.
Phase 4 — Certify: Submit the audit evidence to the CIP Platform Certification assessor. The assessor reviews the documentation against the certification criteria and either issues certification or provides a remediation roadmap.