122THREE HATS, ONE HEAD
The Three Lines Model: Independence Is a Role, Not a Headcount
The Three Lines Model distinguishes management's action and challenge from internal audit's independent assurance to the governing body. Rechecking your own decision cannot create that independence.
THREE ROLES, ONE SYSTEM
Internal audit has a direct route to the governing body
- First line: owns risks and operates processes and controls
- Second line: supplies risk expertise, monitoring, support, and challenge within management
- Third line: internal audit provides independent assurance and advice without taking management decisions
The IIA's July 2026 statement describes responsibilities, not a required number of departments. First- and second-line roles can be combined. Internal audit reports functionally to the governing body and examines the system, including both management lines. Coordination matters; independence does not require isolation.
Access and authority make a second opinion usable
The reviewer needs relevant records and people, control over the scope of the review, and freedom to report an unwelcome finding. The IIA's independence criteria also cover resources, protection from interference, and safeguards for conflicts. A reviewer who helped make the decision may need to step aside from assuring that same work.
THE MODEL CHANGED
The name changed in 2020; the model continues to evolve
The IIA published its Three Lines of Defense paper in January 2013. Its July 2020 revision renamed the framework the Three Lines Model and emphasized governance, relationships, and creating as well as protecting value. Coordination was already present in the earlier paper. A new statement published July 8, 2026 now replaces the 2020 paper and expands guidance on assurance, advice, and overlapping roles.
Two signatures can share the same blind spot
An approval chain can catch errors while leaving the decision frame untouched. Reviewers may share the target, incentives, or filtered evidence. Management checks and specialist assurance have value; the question is whether anyone can examine their limits and report beyond the owner of the work.
LOCK THE DECISION EARLY
Accept the study plan before seeing the result
- Standard reports: 146 of 152 first hypotheses supported, 96.05%
- Registered Reports: 31 of 71 supported, 43.66%
- Authors reported full or partial support; this is not the share of all statistical tests with significant results
Registered Reports receive peer review and in-principle acceptance before results, with publication conditional on adherence and quality requirements. Scheel, Schijen and Lakens (2021) compared a sample of standard psychology reports from 2013–2018 with eligible Registered Reports listed by November 19, 2018. Publication formats were not randomly assigned: hypotheses, authors, journals, and replication frequency differed. The gap is consistent with less publication bias, but does not isolate the format's causal effect.
THE SEALED NOTE
Seal the criterion before the result arrives
- Before the pilot: date the criterion, exclusions, and analysis plan
- After the result: retain that record and explain deviations
Consider a pilot whose continuation depends on a reproducible improvement. Write down what counts as improvement, which observations can be excluded, and how the comparison will be made. Preserve that version when results arrive. This makes changes inspectable; it does not establish whether the criterion itself is a good way to select the correct answer. The same owner still controls the experiment.
BORROW THE LOGIC
An outside reviewer needs more than distance
- Use the sealed record and a separate challenge pass for management checks
- Agree on evidence access, conflicts, review scope, and who receives findings
- If the owner controls every report, record that limit on independence
For consequential work, arrange a competent reviewer who did not make the decision, can inspect the underlying record, and can report concerns without the operator's permission. This is a practical adaptation, not a claim to have built an internal audit function. The 2026 IIA statement classifies outsourced work by the function that directs it; hiring an outsider does not change accountability or create a third line by itself.
THE INTERVENTION LOG
Record what changed and why
- Decision A: revise because an exclusion was missing
- Decision B: escalate because the reviewer had an ownership conflict
- Decision C: proceed because a separate check reproduced the result
These three invented entries show the information a decision log can preserve. Record the proposal, review outcome, reason, and decision type. Repeated unchanged approvals can prompt inspection of reviewer behavior, including loss of practiced judgment; they cannot diagnose it. Better proposals and easier work can also reduce interventions. Compare like decisions before treating a change in the log as a change in scrutiny.
INDEPENDENCE, NOT HEADCOUNT
Trace the route from evidence to the governing body
A review is constrained when the work's owner can filter its evidence or suppress its findings. In the formal model, internal audit has access, authority, and a direct reporting relationship with the governing body. In a smaller arrangement, name the recipient and disclose the limits. Building the check includes deciding who can question the decision-maker.