The Association of Chartered Certified Accountants (ACCA) alongside Ernst and Young (EY) have published a response to the recent UK White Paper: “A pro-innovation approach to AI regulation” (see our article on White Paper and flowchart for navigating the White Paper).

In summary, ACCA/EY:

  • welcome the white paper’s flexible, common-sense approach to the regulation of AI.
  • supports regulating outcomes rather than the technology itself.  This aligns with the principles-based approach toregulation for the accountancy profession in the UK.
  • agree with the white paper’s desire to build on the UK’s thriving AI ecosystem and welcome the UK government’s commitment to international cooperation – something they are keen to support where possible.
  • are highly supportive of the role that the white paper describes for effective oversight tools, and that of audit and assurance, for supporting the long-term sustainable development of the AI ecosystem; the accountancy profession has a key role to play in driving trust in, and the ethical deployment of, AI.
  • recognise the existing role of the UK Corporate Governance Code and UK Companies Act, and of technical standards such as ISO/IEC 23894:2023.

However, ACCA/EY raise concerns and risks:

  • with the cross-sectoral principles on a non-statutory footing, with potential legislation in future, there will be a waiting delay in knowing whether or not these principles will be mandatory or voluntary.  Businesses, especially small to medium enterprises, will be less likely to commit cost or effort without regulatory certainty.
  • with no designated entity responsible for AI oversight, stakeholders would benefit frrom additional support to help them navigate the different bodies relevant to their AI compliance obligations. Consideration is also needed for foundation models which do not neatly fall into the remit of any one existing regulator.
  • UK organisations which operate in other jurisdictions with prescriptive regimes may make them 'rule-takers' of those other regimes.
  • explanation would be welcomed for how the UK's proposed approach will support sectors which are less mature with AI.

If you would like to discuss how current or future regulations impact what you do with AI, please contact Tom Whittaker, Brian Wong, Martin Cook, or any other member in our Technology team. With thanks to Connor Maunder for research.