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.

Governance report

Practice-by-practice evidence

Denominator: 30 records · all use cases in the current filter

Reported in placeReported in progressNot applicableNo answer reported

Pre-deployment testing

Pre-deployment testing
Reported in place: 2 (6.7%)Pre-deployment testing
Reported in progress: 1 (3.3%)Pre-deployment testing
No answer reported: 27 (90.0%)

AI impact assessment

AI impact assessment
Reported in progress: 1 (3.3%)AI impact assessment
No answer reported: 29 (96.7%)

Independent review

Independent review
Reported in place: 1 (3.3%)Independent review
Reported in progress: 1 (3.3%)Independent review
No answer reported: 28 (93.3%)

Ongoing monitoring

Ongoing monitoring
Reported in place: 2 (6.7%)Ongoing monitoring
Reported in progress: 1 (3.3%)Ongoing monitoring
No answer reported: 27 (90.0%)

Operator training

Operator training
Reported in place: 2 (6.7%)Operator training
Reported in progress: 1 (3.3%)Operator training
No answer reported: 27 (90.0%)

Fail-safe

Fail-safe
Reported in place: 1 (3.3%)Fail-safe
Reported in progress: 1 (3.3%)Fail-safe
Not applicable: 1 (3.3%)Fail-safe
No answer reported: 27 (90.0%)

Appeal process

Appeal process
Reported in progress: 1 (3.3%)Appeal process
Not applicable: 1 (3.3%)Appeal process
No answer reported: 28 (93.3%)

User and public consultation

User and public consultation
Reported in place: 3 (10.0%)User and public consultation
No answer reported: 27 (90.0%)

Practice	In scope	In place	In progress	N/A	No answer	Answered	In place of applicable
Pre-deployment testing	30	2	1	0	27	10%	7% of 30
AI impact assessment	30	0	1	0	29	3%	0% of 30
Independent review	30	1	1	0	28	7%	3% of 30
Ongoing monitoring	30	2	1	0	27	10%	7% of 30
Operator training	30	2	1	0	27	10%	7% of 30
Fail-safe	30	1	1	1	27	10%	3% of 29
Appeal process	30	0	1	1	28	7%	0% of 29
User and public consultation	30	3	0	0	27	10%	10% of 30

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.

Agency-by-safeguard heatmap

Cell: share reported in place, among applicable recordsIn place Answered

Agency by governance practice
	Testing	Impact assess.	Indep. review	Monitoring	Training	Fail-safe	Appeal	Consultation	n
TREAS	0%	0%	0%	0%	0%	0%	0%	14%	7
NCUA	–	–	–	–	–	–	–	–	6
FDIC	–	–	–	–	–	–	–	–	4
DOJ	–	–	–	–	–	–	–	–	4
DOE	67%	–	33%	67%	67%	50%	0%	67%	3
VA	–	–	–	–	–	–	–	–	2
NASA	–	–	–	–	–	–	–	–	1
HUD	–	–	–	–	–	–	–	–	1
GSA	–	–	–	–	–	–	–	–	1
USDA	–	–	–	–	–	–	–	–	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

30 records with at least one practice unanswered or in progressOpen in explorer

Use case	Stage	Test	AIA	Review	Monitor	Train	Fail-safe	Appeal	Consult
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
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
Dun & Bradstreet Business Establishments Data DOJ · DOJ-0014	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
National Insurance Crime Bureau ISO ClaimSearch DOJ · DOJ-0022	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Southwest Border Transaction Record Analysis Center (SWBTRAC) DOJ · DOJ-0029	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Subledger Data Quality Machine Learning HUD · HUD-2024-002	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Machine Learning Data Validation NCUA · NCUA_E&I-01	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Supervisory Stress Testing NCUA · NCUA_ONES-02	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Risk Indicator Model NCUA · NCUA_ONES-03	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Moody’s Stress Test Modeling NCUA · NCUA-12-2025	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
ADCo MBS/CMO Modeling NCUA · NCUA-13-2025	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
CoStar CRE Modeling NCUA · NCUA-14-2025	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Sub-Asset Maintenance Model TREAS · BEP-25	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Inventory Replenishment Forecast TREAS · BEP-42	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
IDV Model TREAS · BEP-67	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Payment Redirect Fraud (PRF) Model VA · VA-24-3291	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Analytics, Data, and Decision Support Unified Platform (ADDSUP) VA · VA-24-1815	Deployed	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 for Financial Analysis DOE · DOE-742	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
Optical Character Recognition Tool 3 DOJ · DOJ-0273	Pilot	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
FDIC Predictive Budget Analysis FDIC · FDIC – 34	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
CFOO Transactional Data Analysis FDIC · FDIC – 39	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
FDIC Financial Audit Report FDIC · FDIC – 41	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
FDIC Investment Portfolio Management FDIC · FDIC – 44	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-Powered Visibility for Supply and Vendor Risk Resilience GSA · R1164	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
OCFO Credit Risk and Defaul Estimation Tool NASA · NASA-494	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
Ink and Paper Consumption Forecast (IPCF) TREAS · BEP-41	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
Vendor Risk Analytics TREAS · TREAS-IRS-9	Pilot	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
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
Procurement Intelligence TREAS · TREASURY-OFR-008	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
Yearly Incident Procurement Classification Report USDA · USDA-135	Pilot	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

NCUA designated 5 use cases high-impact but answered none of the minimum-practice questions for any of them. Were the practices assessed, and where is that recorded?

These are questions the inventory raises but cannot answer. They are not findings of non-compliance.