September 15, 2021

Unity appreciates the opportunity to share our perspectives on managing risks associated with 

artificial intelligence (“AI”) with the National Institute of Standards and Technology (“NIST”) in 

response to NIST’s Request for Information (“RFI”) concerning the development of an Artificial 

Intelligence Risk Management Framework (“AI RMF”). Unity welcomes NIST’s commitment to 

develop the AI RMF consistent with a consensus-driven, open, and collaborative process, 

including public workshops and other opportunities for stakeholders to provide input. As an 

organization that utilizes the NIST Cybersecurity and Privacy Frameworks in our internal 

governance, Unity views the AI RMF initiative as an important step towards strengthening 

enterprise risk management practices surrounding the design, development, and deployment of 

AI systems. We look forward to further dialogue with NIST and its stakeholders throughout the 

AI RMF development process.

About Unity

Unity is the world’s leading platform for creating and operating interactive, real-time 3D (“RT3D”) 

content. We believe the world is a better place with more creators in it, and this belief is at the 

core of our efforts to democratize innovation for all. Our products unlock opportunities for 

creators to entertain and educate people, and deliver groundbreaking RT3D experiences that 

add value across industries.

Unity is a comprehensive RT3D platform. Developers can enter the Unity ecosystem at any 

stage in their process and utilize our platform to advance their unique business goals. Our 

platform has two central pillars -- our Create and Operate solutions -- with the Unity Runtime 

Engine being the connective tissue between these pillars. 

Our Create Solutions are used to create, edit, run, and deploy real-time 2D, as well as high 

definition, RT3D content. Create Solutions includes custom scripting tools and a high-definition 

render pipeline for developers; graphics, animation and audio tools for artists; and navigation, 

networking and user interface tools for designers. In addition, businesses can leverage our 

complete, end-to-end Operate Solutions to realize the value of their creations. We provide a 

complete, full stack solution for development, engagement, and ongoing management that is 

heavily utilized in mobile gaming applications and an increasing number of industries. 

AI plays a critical role in Unity’s current offerings and our future growth, as well as the success 

of developers who utilize our platform. For example, Unity Simulation is a suite of products that 

harnesses the power of cloud computing to run millions of simulations to test, train and validate 

AI algorithms at scale. Available on Google Cloud Platform and Amazon Web Services, Unity 

Simulation lowers the barrier for anyone to train, test, or validate new products and services in a 

high-fidelity 3D environment, so creators can bring their ideas to the world faster. Initial use 

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cases for Unity Simulation have focused on computer vision-oriented applications for the 

automotive, gaming, and robotics industries, however, the product can be used for any project, 

prototype, or concept created in Unity.

Foundational Principles for the AI RMF

Unity is committed to the democratization of AI by making AI systems widely available to 

developers and organizations of all sizes. Unity also recognizes broad adoption of AI will 

depend on the trustworthiness of AI systems, including the underlying principles that guide AI 

designers and developers. Accordingly, Unity supports NIST’s focus on transparency, fairness, 

and accountability as the foundational principles underlying the AI RMF. These concepts align 

well with Unity’s six guiding AI principles, as described below. 

• Be Unbiased. Design AI tools to complement the human experience in a positive 

way. Consider all types of human experiences in this pursuit. Diversity of perspective 

will lead to AI complementing experiences for everybody, as opposed to a select few.

• Be Accountable. Consider the potential negative consequences of the AI tools we build. 

Anticipate what might cause potential direct or indirect harm and engineer to avoid and 

minimize these problems.

• Be Fair. Do not knowingly develop AI tools and experiences that interfere with normal, 

functioning democratic systems of government. This means saying no to product 

development aimed at the suppression of human rights, as defined by the Universal 

Declaration of Human Rights, such as the right to free expression.

• Be Responsible. Develop products responsibly and do not take advantage of your 

products’ users by manipulating them through AI’s vastly more predictive capabilities 

derived from user data.

• Be Honest. Trust the users of the technology to understand the product’s purpose so 

they can make informed decisions about whether to use the product. Be clear and be 

transparent.

• Be Trustworthy. Guard the AI derived data as if it were handed to you by your customer 

directly in trust to only be used as directed under the other principles found in this guide.

The first version of the AI RMF should focus on practical approaches to implementing NIST’s 

proposed foundational principles -- transparency, fairness, and accountability -- as a baseline 

for organizations to develop and iterate further on principles that address their needs. Unity 

recognizes the scope and implementation methodologies for AI principles will differ for 

organizations based on their role in the AI ecosystem, compliance obligations and governance 

structure, societal commitments and concerns, among other factors. With the AI RMF 

envisioned as a living document, later versions could provide greater breadth and depth on the 

development and implementation of AI principles.

We support NIST’s intention to consider risks from unintentional, unanticipated, or harmful 

outcomes that arise from intended uses, secondary uses, and misuses of the AI. Indeed, AI 

systems designed and developed for one purpose can be adapted to serve different purposes. 

Organizations benefit from considering not only whether they can create an AI system for a 
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given purpose, but whether they should develop the system when taking into account different 

use cases and potential abuse. 

Structure of the AI RMF

Unity utilizes both the Privacy and Cybersecurity Frameworks in our operations, and we have 

found both frameworks to be especially useful as we work to mature and continually improve 

our risk governance operations. We would encourage NIST to harmonize the AI RMF with 

NIST’s existing frameworks as much as possible, including the inclusion of a maturity model. 

For example, the AI RMF should emulate the existing frameworks’ focus on the maturity of 

organizational programs through critical analysis documentation, repeatability of processes and 

feedback loops, and other relevant indicators of maturity,

Attributes of the AI RMF

Unity supports NIST’s proposed attributes of the AI RMF, and we encourage NIST to consider 

its application of these proposed attributes throughout the initial AI RMF development process 

as well as its ongoing renewal as a living document. Rather than a sequential response, our 

comments are organized to address NIST’s proposed attributes where those attributes reflect 

complementary goals.

Development of the AI RMF

AI risk management will require multi stakeholder and multilateral engagement over many years 

to come. We appreciate NIST’s commitment to developing the AI RMF through an open and 

consensus-driven process, similar to the processes utilized in the Cybersecurity and Privacy 

Frameworks. We encourage NIST to leverage its relationships with national and international 

standards organizations around the world to raise their awareness about the AI RMF, and to 

participate in NIST’s process where appropriate. This dialogue will be critical as the European 

Union and other jurisdictions address AI risk management through their own policy development 

processes.

Characteristics of the AI RMF and its integration with risk management programs

Given that many AI use cases will fall outside of regulated sectors and activities, it is critical that 

the AI RMF provide guidance that is accessible to organizations that may not have well 

developed governance practices. We support NIST’s goal of creating a risk-based, outcomefocused, voluntary, and non-prescriptive approach in the AI RMF, which will be critical for 

organizations that do have sector-specific regulators. Likewise, we support NIST’s intention that 

the AI RMF should be usable as part of an organization's broader risk management strategy 

and processes. Indeed, the AI RMF may serve as the only AI-specific risk management 

framework for many organizations in the AI ecosystem.

Use of plain language and adaptability across multiple organizations

Broad adoption of the AI RMF will depend on its ability to communicate complex topics using 

plain language. We support NIST’s focus on ensuring that the AI RMF is comprehensible for 

non-technical stakeholders, and we encourage NIST to build the AI RMF with an eye towards 

modular use of its components. For example, the AI RMF could distinguish between higher 

versus lower risk use cases for AI, while at the same time identifying practices that are so 

fundamental that any organization deploying AI should take them into account.
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Common definitions and consistency with other approaches to managing AI risk

Developing common definitions for the AI RMF is critical and those definitions should mesh with 

definitions under consideration in related workstreams, especially definitions that are emerging 

outside of the United States. We encourage NIST to drive for alignment between definitions 

provided in the AI RMF with definitions proposed in the European Commission’s proposed AI 

Act as well as definitions under development at the International Standards Organization.

Maintenance of the AI RMF as a living document

The sophistication of AI systems, and associated risk mitigations, are both advancing 

rapidly. We support NIST’s intention to maintain the AI RMF as a living document, and we 

encourage NIST to articulate its update schedule. In contrast with the Privacy and Cybersecurity 

Frameworks, the AI RMF would be NIST’s first framework focused on a technology (AI) that is 

still relatively new and evolving at the speed of innovation. Stakeholders would benefit from the 

ability to anticipate and prepare for updates to the AI RMF.

Encouraging Workforce Development Through the AI RMF

Unity would support a strong emphasis on workforce development in the AI RMF, including 

measures that encourage AI providers to offer training and learning opportunities to the current 

and future workforce. This is driven by our belief that learning should be accessible to everyone. 

We know there is workforce demand for technical programming skills which is why we 

contribute our products, technology, and expertise to enable over 300,000 students and 

educators every year to learn how to use Unity’s products and services.

The AI RMF should encourage organizations to share their AI expertise as a means of 

advancing AI skills in the current and future workforce. At Unity, we make two AI courses 

available to the public online; Artificial Intelligence for Beginners, which has had over 15,000 

viewers in 2021 alone, and Machine Learning (ML) Agents: Hummingbirds, which has had 

nearly 6,000 viewers in 2021. This level of engagement demonstrates there is strong interest in 

learning about AI and its practical applications, and expanding the breadth and depth of similar 

offerings across the AI ecosystem can only benefit the workforce.

Conclusion

Unity commends NIST for its initiative to develop a risk management framework that is broadly 

relevant to organizations throughout the AI ecosystem. We are grateful for the opportunity to 

share our perspectives, and we welcome dialogue about our input. We look forward to further 

collaboration with NIST and its stakeholders to develop the AI RMF.