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: 18 records · all use cases in the current filterReported in placeReported in progressReported not in placeNot applicablePrecluded by law or guidanceOther or ambiguous answerNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 14 (77.8%)Pre-deployment testing
Reported in progress: 4 (22.2%)
18Reported in place: 14 (77.8%)Pre-deployment testing
Reported in progress: 4 (22.2%)
AI impact assessment
AI impact assessment
Reported in place: 7 (38.9%)AI impact assessment
Reported in progress: 6 (33.3%)AI impact assessment
Reported not in place: 1 (5.6%)AI impact assessment
No answer reported: 4 (22.2%)
18Reported in place: 7 (38.9%)AI impact assessment
Reported in progress: 6 (33.3%)AI impact assessment
Reported not in place: 1 (5.6%)AI impact assessment
No answer reported: 4 (22.2%)
Independent review
Independent review
Reported in place: 8 (44.4%)Independent review
Reported in progress: 6 (33.3%)Independent review
No answer reported: 4 (22.2%)
18Reported in place: 8 (44.4%)Independent review
Reported in progress: 6 (33.3%)Independent review
No answer reported: 4 (22.2%)
Ongoing monitoring
Ongoing monitoring
Reported in place: 11 (61.1%)Ongoing monitoring
Reported in progress: 5 (27.8%)Ongoing monitoring
Other or ambiguous answer: 1 (5.6%)Ongoing monitoring
No answer reported: 1 (5.6%)
18Reported in place: 11 (61.1%)Ongoing monitoring
Reported in progress: 5 (27.8%)Ongoing monitoring
Other or ambiguous answer: 1 (5.6%)Ongoing monitoring
No answer reported: 1 (5.6%)
Operator training18
Fail-safe
Fail-safe
Reported in place: 12 (66.7%)Fail-safe
Reported in progress: 1 (5.6%)Fail-safe
Not applicable: 5 (27.8%)
18Reported in place: 12 (66.7%)Fail-safe
Reported in progress: 1 (5.6%)Fail-safe
Not applicable: 5 (27.8%)
| 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 | 18 | 14 | 4 | 0 | 0 | 0 | 0 | 0 | 100% | 78% of 18 |
| AI impact assessment | 18 | 7 | 6 | 1 | 0 | 0 | 0 | 4 | 78% | 39% of 18 |
| Independent review | 18 | 8 | 6 | 0 | 0 | 0 | 0 | 4 | 78% | 44% of 18 |
| Ongoing monitoring | 18 | 11 | 5 | 0 | 0 | 0 | 1 | 1 | 94% | 61% of 18 |
| Operator training | 18 | 12 | 6 | 0 | 0 | 0 | 0 | 0 | 100% | 67% of 18 |
| Fail-safe | 18 | 12 | 1 | 0 | 5 | 0 | 0 | 0 | 100% | 92% of 13 |
| Appeal process | 18 | 3 | 1 | 0 | 10 | 1 | 0 | 3 | 83% | 43% of 7 |
| User and public consultation | 18 | 18 | 0 | 0 | 0 | 0 | 0 | 0 | 100% | 100% of 18 |
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 | |
|---|---|---|---|---|---|---|---|---|---|
| DOE | 63% | 0% | 13% | 38% | 50% | 100% | 0% | 100% | 8 |
| DHS | 100% | 100% | 100% | 100% | 100% | 100% | 100% | 100% | 5 |
| SBA | 100% | 100% | 100% | 100% | 100% | 0% | 0% | 100% | 2 |
| EPA | 100% | 0% | – | 0% | 0% | 100% | – | 100% | 1 |
| TREAS | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 100% | 1 |
| STATE | 100% | 0% | 0% | 100% | 100% | 100% | 100% | 100% | 1 |
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
11 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| OPQ-AI DOE · DOE-477 | Deployed | Reported in place | No answer reported | No answer reported | Reported in place | Reported in place | Reported in place | No answer reported | Reported in place |
| Invoice Scanning System DOE · DOE-632 | Deployed | Reported in place | No answer reported | Reported in place | Reported in place | Reported in place | Not applicable | Not applicable | Reported in place |
| Georeference Figures DOE · DOE-645 | Deployed | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in place | Not applicable | Reported in place |
| pComply-AI-High Risk DOE · DOE-658 | Deployed | Reported in place | No answer reported | No answer reported | Reported in place | Reported in place | Reported in place | No answer reported | Reported in place |
| Groundwater Modeling DOE · DOE-659 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in place | Not applicable | Reported in place |
| Agency Records Management System EPA · 73 | Deployed | Reported in place | Reported not in place | No answer reported | Other or ambiguous answer | Reported in progress | Reported in place | No answer reported | Reported in place |
| AI-Augmented Declassification Review STATE · R3213 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in place | Reported in place | Reported in place | Reported in place | Reported in place |
| Drone Imagery Analysis DOE · DOE-539 | Pilot | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in place | Not applicable | Reported in place |
| Soil Moisture Modeling DOE · DOE-545 | Pilot | Reported in place | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in place | Not applicable | Reported in place |
| Crickets DOE · DOE-723 | Pre-deployment | Reported in progress | No answer reported | No answer reported | No answer reported | Reported in place | Not applicable | Not applicable | Reported in place |
| GenAI Procurement Tool TREAS · TREASURY-OCIO-003 | Pre-deployment | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in place |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- 1 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?
- 3 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.