Governance and accountability
Governance evidence
What agencies reported about the OMB M-25-21 minimum practices for high-impact AI. This is a disclosure analysis, not an audit, a compliance finding or an official assessment. An unanswered question is missing evidence, not evidence that a safeguard is absent.
Practice-by-practice evidence
Denominator: 21 records · deployed high-impact use casesReported in placeReported in progressNot applicableOther or ambiguous answer
Pre-deployment testing
Pre-deployment testing
Reported in place: 18 (85.7%)Pre-deployment testing
Reported in progress: 3 (14.3%)
21Reported in place: 18 (85.7%)Pre-deployment testing
Reported in progress: 3 (14.3%)
AI impact assessment
AI impact assessment
Reported in place: 15 (71.4%)AI impact assessment
Reported in progress: 6 (28.6%)
21Reported in place: 15 (71.4%)AI impact assessment
Reported in progress: 6 (28.6%)
Independent review21
Ongoing monitoring21
Operator training
Operator training
Reported in place: 16 (76.2%)Operator training
Reported in progress: 3 (14.3%)Operator training
Other or ambiguous answer: 2 (9.5%)
21Reported in place: 16 (76.2%)Operator training
Reported in progress: 3 (14.3%)Operator training
Other or ambiguous answer: 2 (9.5%)
Fail-safe
Fail-safe
Reported in place: 12 (57.1%)Fail-safe
Reported in progress: 5 (23.8%)Fail-safe
Not applicable: 4 (19.0%)
21Reported in place: 12 (57.1%)Fail-safe
Reported in progress: 5 (23.8%)Fail-safe
Not applicable: 4 (19.0%)
| Practice | In scope | In place | In progress | Not in place | N/A | Precluded or waived | Other | No answer | Answered | In place of applicable |
|---|---|---|---|---|---|---|---|---|---|---|
| Pre-deployment testing | 21 | 18 | 3 | 0 | 0 | 0 | 0 | 0 | 100% | 86% of 21 |
| AI impact assessment | 21 | 15 | 6 | 0 | 0 | 0 | 0 | 0 | 100% | 71% of 21 |
| Independent review | 21 | 15 | 6 | 0 | 0 | 0 | 0 | 0 | 100% | 71% of 21 |
| Ongoing monitoring | 21 | 16 | 5 | 0 | 0 | 0 | 0 | 0 | 100% | 76% of 21 |
| Operator training | 21 | 16 | 3 | 0 | 0 | 0 | 2 | 0 | 100% | 76% of 21 |
| Fail-safe | 21 | 12 | 5 | 0 | 4 | 0 | 0 | 0 | 100% | 71% of 17 |
| Appeal process | 21 | 5 | 3 | 0 | 13 | 0 | 0 | 0 | 100% | 63% of 8 |
| User and public consultation | 21 | 11 | 3 | 0 | 0 | 0 | 7 | 0 | 100% | 52% of 21 |
Answered = records with any answer ÷ records in scope. In place of applicable = reported in place ÷ (in scope minus not applicable, precluded and waived). Unanswered records stay in that denominator, so the rate is a lower bound on reported evidence, not an estimate of real practice.
| Testing | Impact assess. | Indep. review | Monitoring | Training | Fail-safe | Appeal | Consultation | n | |
|---|---|---|---|---|---|---|---|---|---|
| DHS | 86% | 71% | 71% | 76% | 76% | 71% | 63% | 52% | 21 |
Hatched cells: the agency answered nothing for that practice, so there is no evidence either way. Compare agencies with care: each agency is one reporting unit, and portfolios differ in size and type.
Records requiring further investigation
6 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| Passive Body Scanner DHS · DHS-2380 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Not applicable | Other or ambiguous answer |
| Traffic Jam DHS · DHS-2570 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in place | Other or ambiguous answer |
| Mobile Fortify DHS · DHS-2731 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in place | Reported in place | Reported in place | Not applicable | Reported in place |
| Consular Consolidated Database (CCD) Facial Recognition (FR) On Demand Report (VISA Only) DHS · DHS-365 | Deployed | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress |
| Mobile Fortify DHS · DHS-2577 | Deployed | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Other or ambiguous answer | Reported in progress | Reported in progress | Reported in progress |
| License Plate Capture and Analysis DHS · DHS-2666 | Deployed | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Other or ambiguous answer | Reported in progress | Reported in progress | Reported in progress |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- 6 high-impact use cases are reported as deployed while their AI impact assessment is reported in progress. Was deployment authorised before the assessment was complete?
- 14 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
- 5 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
- 2 governance answers are ambiguous (for example, an answer option from a different question). What did the agency intend?
These are questions the inventory raises but cannot answer. They are not findings of non-compliance.