Chapter 13
Third-party engagements — when to commission, how to oversee
Last reviewed 2026-05-01
External testers are not a substitute for an internal program; they augment it. Use them when one of three conditions holds:
- Capacity: too much testable scope for the internal team in the cycle.
- Capability: a specific domain (multimodal, agentic, specialized model) where internal expertise is shallow.
- Independence: a regulator or audit requirement explicitly demands an external test.
Selecting
Five criteria, weighted in this order:
- Methodology fit: Their published methodology should be compatible with this framework’s structure (charter, ROE, three-tier reporting). Ask for sample (sanitized) deliverables.
- Practitioner-level personnel: Who actually runs the engagement, not who pitched it. Resumes of named personnel, not the firm.
- Domain match: Recent comparable engagements at peer organizations.
- References that you call: Not the references the firm provided — adjacent contacts.
- Commercial terms: IP indemnity, deliverable ownership, scope-change discipline, NDAs.
Contracting essentials
- Engagement scope ties to the ROE (your ROE, not theirs).
- Deliverables in your formats.
- Right to publish (yours), right to anonymized reference use (theirs, capped).
- Personnel substitution requires approval.
- Tools used disclosed in advance (some clients prohibit certain commercial scanners).
- Confidentiality and breach handling tied to your standard.
Oversight
You remain accountable. Concretely:
- A designated internal owner attends standups.
- Internal review of evidence before findings are accepted.
- Re-perform a sample of findings (chapter 8 quality bar applies).
- Drive the compliance-traceability section yourself, even if the external tester drafts it.
Common failures
- Accepting reports without internal review, then being unable to defend them at audit.
- External tester’s report uses commercial tool output verbatim. Re-frame in your methodology.
- Engagement runs longer than scope; budget slips. Set hard checkpoints.