Content reviewed and verified by Graham Chee, with FCPA-led practice at Local Knowledge, Mascot NSW. Continuous CPA Australia member since 1986. Prior career at Goldman Sachs, BNP Investment Management and Merrill Lynch.. Last reviewed July 2026. Next review scheduled for October 2026.
Navigate the complexities of valuing and auditing AI-driven intellectual property under AASB 13 for robust financial reporting.
The rapid evolution of Artificial Intelligence (AI) is not merely optimising existing business processes; it is fundamentally reshaping the creation of intellectual property (IP). From AI-generated code and design to sophisticated algorithms that drive proprietary models, businesses are increasingly developing valuable assets that originate from AI systems. This paradigm shift presents a significant challenge for financial reporting, particularly in how these non-traditional assets are recognised, measured, and audited. This analysis, written by Graham Chee, FCPA, GRCP — Fellow of CPA Australia since November 2005, continuous CPA member since 1986, and principal of Local Knowledge — delves into the technical regulatory intersection of AASB 13 Fair Value Measurement and the unique characteristics of AI-generated IP assets. While much of the industry dialogue focuses on the operational efficiencies of AI, this paper moves beyond 'using' AI to address the critical financial reporting and fair value measurement implications for proprietary AI models on the balance sheet. CPAs face a new imperative to understand how to apply established accounting standards to these novel assets. This article will guide readers through the recognition challenges, fair value methodologies, and the crucial role of audit assurance in this emerging landscape, ensuring compliance and robust financial integrity.
The emergence of AI as a creator of intellectual property presents a novel challenge for traditional accounting frameworks. Historically, intangible assets like patents, copyrights, and trademarks have been clearly linked to human ingenuity and legal registration. However, AI-generated IP, such as algorithms, datasets, or even creative works produced autonomously by AI systems, blurs these lines. For an AI-generated asset to be recognised on the balance sheet, it must meet the criteria for an intangible asset under AASB 138 Intangible Assets, which requires identifiability, control, and the expectation of future economic benefits [AASB 138.8]. The 'identifiability' criterion is particularly pertinent here; can an AI-generated output be separated or divided from the entity and sold, transferred, licensed, rented, or exchanged? Furthermore, the 'control' aspect demands that the entity has the power to obtain the future economic benefits flowing from the asset and restrict others' access to those benefits. This often involves legal protection, which can be complex for AI-generated outputs. For instance, while software developed by AI might be copyrightable if it meets originality thresholds, the status of an AI-generated artwork or invention can be ambiguous under current Australian IP law [IP Australia: AI and IP]. The crucial step for CPAs is to assess whether these AI-derived creations can genuinely be classified as intangible assets, distinct from the AI system itself, and whether they provide future economic benefits reliably measurable. This assessment forms the bedrock for any subsequent fair value measurement under AASB 13.
AASB 13 Fair Value Measurement establishes a single source of guidance for measuring fair value when it is required or permitted by other AASBs. Its application to AI-generated IP assets, however, is fraught with unique challenges. Fair value is defined as the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date [AASB 13.9]. For AI-generated IP, active and observable markets are typically non-existent. This pushes the valuation towards Level 3 inputs within the AASB 13 fair value hierarchy, relying on unobservable inputs and the entity’s own data. The inherent complexity lies in determining what a 'market participant' would consider when valuing a proprietary AI model or its outputs. Factors such as the uniqueness of the AI's algorithm, the proprietary datasets it was trained on, its current and potential applications, and the cost to replicate its output are all critical. Furthermore, the rapid pace of technological change and the potential for obsolescence in AI models add another layer of difficulty to establishing a stable fair value. CPAs must exercise significant professional judgement, ensuring that the valuation techniques used are appropriate in the circumstances and that sufficient data is available to measure fair value, maximising the use of relevant observable inputs and minimising the use of unobservable inputs [AASB 13.67].
The audit of AI-generated intellectual property assets under AASB 13 demands a sophisticated understanding from CPAs, extending beyond traditional financial statement audits. The CPA's role evolves into an assurance provider for the governance, valuation methodologies, and underlying data integrity of these complex assets. This requires not only financial acumen but also a foundational understanding of AI technologies and their operational implications. Auditors must critically assess the internal controls surrounding the development, ownership, and protection of AI-generated IP. This includes verifying the legal basis for ownership, the robustness of data used for AI training, and the processes for identifying and securing economic benefits from the AI outputs. Furthermore, CPAs must challenge the assumptions and models used in fair value measurements, particularly when Level 3 inputs are predominant. This involves evaluating the competence of internal or external valuation specialists, scrutinising the sensitivity analyses performed, and ensuring that disclosures adequately reflect the inherent uncertainties. The APES 110 Code of Ethics for Professional Accountants (including Independence Standards) [APESB: APES 110] mandates professional competence and due care, objectivity, and integrity, which are paramount when auditing such novel and complex assets. Audit procedures must be adapted to verify the existence, ownership, and valuation of AI IP, potentially involving specialists in technology and intellectual property law.
The regulatory landscape for AI-generated IP is still evolving, creating significant complexities for financial reporting and audit. In Australia, the existing IP framework, primarily governed by the Copyright Act 1968 and Patents Act 1990, does not explicitly address AI as an inventor or author. This legal ambiguity directly impacts the recognition and fair value measurement of AI-generated assets. For example, if an AI is deemed not to be an 'author' for copyright purposes, the legal ownership of its creative outputs becomes uncertain, affecting the 'control' criterion under AASB 138. CPAs must, therefore, stay abreast of developments from bodies like IP Australia and potential legislative changes. Furthermore, the ethical considerations surrounding AI, such as data privacy and algorithmic bias, while not directly accounting standards, can indirectly impact an AI asset's fair value by influencing its market acceptance, regulatory risks, and potential for future economic benefits. Auditors need to consider these broader implications. From a tax perspective, the ATO's guidance on intangible assets and R&D tax incentives will also need to be carefully applied to AI development and its resulting IP [ATO: R&D tax incentive]. The interplay between accounting standards, intellectual property law, and emerging AI regulations necessitates a multi-disciplinary approach to ensure compliance and accurate financial representation of AI-derived value.
The primary challenge stems from the lack of active and observable markets for unique AI-generated intellectual property. AASB 13 defines fair value based on market participant assumptions in an orderly transaction, but for novel AI assets, such markets rarely exist. This often forces valuers to rely heavily on Level 3 inputs, which are unobservable and require significant professional judgment and entity-specific data. Projecting future economic benefits from rapidly evolving AI technology also introduces substantial uncertainty, making the income approach, while often most relevant, inherently complex to apply reliably [AASB 13.9].
AASB 138 requires an asset to be identifiable, controlled by the entity, and expected to generate future economic benefits to be recognised as an intangible asset. For AI-generated content, 'identifiability' means it can be separated or licensed. 'Control' is particularly challenging due to the current ambiguities in Australian IP law regarding AI as an author or inventor; legal ownership is crucial for control. The 'future economic benefits' must be reliably measurable. Without clear legal ownership or the ability to restrict others' access, AI-generated content may struggle to meet the recognition criteria as a stand-alone intangible asset [AASB 138.8].
Yes, AI-developed software can potentially be recognised as an intangible asset if it meets the criteria of AASB 138. This includes being identifiable (e.g., distinct code), controlled by the entity (which typically implies legal ownership or exclusive rights), and expected to generate future economic benefits (e.g., through sales, licensing, or cost savings). The costs associated with developing the software, including direct development costs and potentially the costs of training the AI that created it, would be considered. However, the legal nuances of AI's inventorship or authorship under Australian law must be carefully considered to establish clear control and ownership [AASB 138.57].
CPAs play a critical role in ensuring the integrity of AI asset valuations by applying professional scepticism and expertise. This involves scrutinising the valuation methodologies chosen, challenging the assumptions underlying future cash flow projections, and evaluating the reliability and relevance of the data used, especially for Level 3 inputs under AASB 13. Auditors must also assess the competence of valuation specialists and verify that internal controls around AI asset development and protection are robust. Their adherence to the APES 110 Code of Ethics, particularly regarding professional competence and objectivity, is paramount in providing credible assurance on these complex assets [APESB: APES 110].
Currently, there are no specific Australian accounting standards solely dedicated to AI intellectual property. Entities must apply existing frameworks like AASB 138 Intangible Assets for recognition and AASB 13 Fair Value Measurement for valuation. The Australian IP landscape, managed by IP Australia, is also evolving to address AI's role in creation, but explicit regulations for AI inventorship or authorship are still under development. Therefore, CPAs must interpret and apply existing standards to these novel assets, often requiring significant professional judgment and careful consideration of the legal and technical specifics of each AI asset. Tax implications are guided by general ATO principles for intangible assets and R&D incentives [ATO: R&D tax incentive].
In principal-led practice, we are seeing a clear shift in the demands placed on CPAs. The rise of AI-generated intellectual property is not just an academic discussion; it's a tangible challenge appearing on client balance sheets. My experience, from institutional finance to supporting founder-led businesses, underscores the importance of robust frameworks. The traditional audit approach, while foundational, must now be augmented with a deeper understanding of technology, IP law, and complex valuation methodologies. Providing assurance on AI assets requires us to be more than just accountants; we must be strategic advisors, capable of translating technological innovation into verifiable financial reporting. This necessitates continuous learning and a proactive engagement with emerging regulatory and technological landscapes. Our commitment to the CPA Code of Ethics means every file, every valuation, and every piece of advice must be grounded in the highest standards of professional competence and integrity, especially when navigating these uncharted waters.
The advent of AI-generated intellectual property presents both unprecedented opportunities and significant accounting and auditing challenges. Navigating the complexities of AASB 13 Fair Value Measurement for these non-traditional assets demands a sophisticated understanding of both financial reporting standards and the underlying technology. For CPAs, this means adapting existing methodologies, exercising heightened professional judgment, and staying abreast of the evolving legal and regulatory landscape. By rigorously applying AASB 13 and AASB 138, and by fostering a deep understanding of AI's implications, auditors can provide the necessary assurance to maintain confidence in financial statements. The integrity of financial reporting in the AI era hinges on the CPA profession's ability to evolve and embrace this new frontier. Speak with our principal to discuss how these principles apply to your business.

Principal and Founder, Local Knowledge
Graham Chee is the principal and founder of Local Knowledge, an FCPA-led Australian practice that brings institutional-grade compliance, investment-structure and intellectual-property experience directly to owner-managed businesses. Graham is a Fellow of CPA Australia (FCPA since November 2005, continuous CPA member since 1986) and holds the OCEG Governance, Risk & Compliance Professional (GRCP) and Governance, Risk & Compliance Auditor (GRCA) designations. His prior career includes senior roles at Goldman Sachs, BNP Investment Management and Merrill Lynch. Graham was previously portfolio manager of the Asian Masters Fund (IPO December 2007 – 31 December 2009), which returned +29% in AUD terms versus the MSCI Asia Pacific (ex Japan) benchmark. He signs off on 100% of client files personally.
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Graham Chee FCPA, CPA, GRCP, GRCA · Principal, Local Knowledge · Mascot NSW · CPA-signed files