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: 8 records · use cases designated high-impactReported in placeReported in progressNot applicableOther or ambiguous answerNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 3 (37.5%)Pre-deployment testing
Reported in progress: 1 (12.5%)Pre-deployment testing
No answer reported: 4 (50.0%)
8Reported in place: 3 (37.5%)Pre-deployment testing
Reported in progress: 1 (12.5%)Pre-deployment testing
No answer reported: 4 (50.0%)
AI impact assessment
AI impact assessment
Reported in place: 1 (12.5%)AI impact assessment
Reported in progress: 3 (37.5%)AI impact assessment
No answer reported: 4 (50.0%)
8Reported in place: 1 (12.5%)AI impact assessment
Reported in progress: 3 (37.5%)AI impact assessment
No answer reported: 4 (50.0%)
Independent review
Independent review
Reported in place: 1 (12.5%)Independent review
Reported in progress: 3 (37.5%)Independent review
No answer reported: 4 (50.0%)
8Reported in place: 1 (12.5%)Independent review
Reported in progress: 3 (37.5%)Independent review
No answer reported: 4 (50.0%)
Ongoing monitoring
Ongoing monitoring
Reported in place: 1 (12.5%)Ongoing monitoring
Reported in progress: 3 (37.5%)Ongoing monitoring
No answer reported: 4 (50.0%)
8Reported in place: 1 (12.5%)Ongoing monitoring
Reported in progress: 3 (37.5%)Ongoing monitoring
No answer reported: 4 (50.0%)
Operator training
Operator training
Reported in place: 2 (25.0%)Operator training
Reported in progress: 2 (25.0%)Operator training
No answer reported: 4 (50.0%)
8Reported in place: 2 (25.0%)Operator training
Reported in progress: 2 (25.0%)Operator training
No answer reported: 4 (50.0%)
Fail-safe
Fail-safe
Reported in place: 1 (12.5%)Fail-safe
Reported in progress: 1 (12.5%)Fail-safe
Not applicable: 2 (25.0%)Fail-safe
No answer reported: 4 (50.0%)
8Reported in place: 1 (12.5%)Fail-safe
Reported in progress: 1 (12.5%)Fail-safe
Not applicable: 2 (25.0%)Fail-safe
No answer reported: 4 (50.0%)
| 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 | 8 | 3 | 1 | 0 | 0 | 0 | 0 | 4 | 50% | 38% of 8 |
| AI impact assessment | 8 | 1 | 3 | 0 | 0 | 0 | 0 | 4 | 50% | 13% of 8 |
| Independent review | 8 | 1 | 3 | 0 | 0 | 0 | 0 | 4 | 50% | 13% of 8 |
| Ongoing monitoring | 8 | 1 | 3 | 0 | 0 | 0 | 0 | 4 | 50% | 13% of 8 |
| Operator training | 8 | 2 | 2 | 0 | 0 | 0 | 0 | 4 | 50% | 25% of 8 |
| Fail-safe | 8 | 1 | 1 | 0 | 2 | 0 | 0 | 4 | 50% | 17% of 6 |
| Appeal process | 8 | 2 | 0 | 0 | 2 | 0 | 0 | 4 | 50% | 33% of 6 |
| User and public consultation | 8 | 2 | 1 | 0 | 0 | 0 | 1 | 4 | 50% | 25% of 8 |
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 | 38% | 13% | 13% | 13% | 25% | 17% | 33% | 25% | 8 |
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
7 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| Babel DHS · DHS-185 | 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 |
| CBP Translate DHS · DHS-2388 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in progress | Reported in place | Not applicable | Not applicable | Reported in place |
| Open Source and Social Media Analysis DHS · DHS-2538 | Deployed | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Not applicable | Reported in place | Reported in progress |
| Smartphone Information Forensics Triage DHS · DHS-2705 | Pre-deployment | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| AI Resume & ATS App DHS · DHS-2721 | Pre-deployment | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Real-Time Language Translation Services DHS · DHS-2749 | Pre-deployment | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| USCIS Speech Translation Service DHS · DHS-2514 | Pre-deployment | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- 3 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?
- 2 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
These are questions the inventory raises but cannot answer. They are not findings of non-compliance.