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: 5 records · use cases designated high-impactReported in place: 2 (40.0%)Pre-deployment testing
Reported in progress: 2 (40.0%)Pre-deployment testing
No answer reported: 1 (20.0%)
Reported in progress: 4 (80.0%)AI impact assessment
No answer reported: 1 (20.0%)
Reported in place: 2 (40.0%)Ongoing monitoring
Reported in progress: 2 (40.0%)Ongoing monitoring
No answer reported: 1 (20.0%)
Reported in place: 1 (20.0%)Operator training
Reported in progress: 3 (60.0%)Operator training
No answer reported: 1 (20.0%)
Reported in place: 2 (40.0%)Fail-safe
Reported in progress: 2 (40.0%)Fail-safe
No answer reported: 1 (20.0%)
| 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 | 5 | 2 | 2 | 0 | 0 | 0 | 0 | 1 | 80% | 40% of 5 |
| AI impact assessment | 5 | 0 | 4 | 0 | 0 | 0 | 0 | 1 | 80% | 0% of 5 |
| Independent review | 5 | 0 | 4 | 0 | 0 | 0 | 0 | 1 | 80% | 0% of 5 |
| Ongoing monitoring | 5 | 2 | 2 | 0 | 0 | 0 | 0 | 1 | 80% | 40% of 5 |
| Operator training | 5 | 1 | 3 | 0 | 0 | 0 | 0 | 1 | 80% | 20% of 5 |
| Fail-safe | 5 | 2 | 2 | 0 | 0 | 0 | 0 | 1 | 80% | 40% of 5 |
| Appeal process | 5 | 2 | 2 | 0 | 0 | 0 | 0 | 1 | 80% | 40% of 5 |
| User and public consultation | 5 | 1 | 3 | 0 | 0 | 0 | 0 | 1 | 80% | 20% of 5 |
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 | |
|---|---|---|---|---|---|---|---|---|---|
| DOJ | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 2 |
| DHS | 100% | 0% | 0% | 100% | 0% | 100% | 100% | 0% | 1 |
| VA | – | – | – | – | – | – | – | – | 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
5 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| Verification Match Model DHS · DHS-2384 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in place | Reported in progress | Reported in place | Reported in place | Reported in progress |
| Building Automation Systems DOJ · DOJ-0147 | 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 |
| Background Searches DOJ · DOJ-0324 | 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 |
| 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 |
| Concept Clustering VA · VA-25-3275 | 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 |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- 4 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?
- 1 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
These are questions the inventory raises but cannot answer. They are not findings of non-compliance.