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IIA: Society Submits Comment Letter on Draft Update to the Three Lines Model

By Randi Morrison posted 03-26-2026 09:39 PM

  

Further to our March 11 Society Alert, last week, the Society submitted this comment letter to the Institute of Internal Auditors (IIA) on its stakeholder review draft update to the Statement of Position – Three Lines Model, reflecting input from a small group of members.

The Society’s letter supports the continued positioning of the model as a principles-based and adaptable framework, while encouraging the IIA to preserve its conceptual nature and avoid interpretations that could be viewed as prescriptive in practice. The letter focuses on several areas of relevance to our members and boards, including the articulation of the board’s role, coordination and reliance among assurance providers, independence considerations, and scenarios involving overlapping responsibilities across the three lines.

The letter also encourages the IIA to reiterate that the model is intended as a conceptual framework and not a governance standard or benchmarking tool.

Access additional resources on our Internal Audit page.

              This post first appeared in the weekly Society Alert!

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