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: 12 records · use cases designated high-impactReported in placeReported in progressNot applicablePrecluded by law or guidanceOther or ambiguous answerNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 7 (58.3%)Pre-deployment testing
Reported in progress: 4 (33.3%)Pre-deployment testing
No answer reported: 1 (8.3%)
12Reported in place: 7 (58.3%)Pre-deployment testing
Reported in progress: 4 (33.3%)Pre-deployment testing
No answer reported: 1 (8.3%)
AI impact assessment12
Independent review
Independent review
Reported in place: 6 (50.0%)Independent review
Reported in progress: 5 (41.7%)Independent review
No answer reported: 1 (8.3%)
12Reported in place: 6 (50.0%)Independent review
Reported in progress: 5 (41.7%)Independent review
No answer reported: 1 (8.3%)
Ongoing monitoring
Ongoing monitoring
Reported in place: 7 (58.3%)Ongoing monitoring
Reported in progress: 4 (33.3%)Ongoing monitoring
No answer reported: 1 (8.3%)
12Reported in place: 7 (58.3%)Ongoing monitoring
Reported in progress: 4 (33.3%)Ongoing monitoring
No answer reported: 1 (8.3%)
Operator training
Operator training
Reported in place: 7 (58.3%)Operator training
Reported in progress: 4 (33.3%)Operator training
No answer reported: 1 (8.3%)
12Reported in place: 7 (58.3%)Operator training
Reported in progress: 4 (33.3%)Operator training
No answer reported: 1 (8.3%)
Fail-safe
Fail-safe
Reported in place: 4 (33.3%)Fail-safe
Reported in progress: 4 (33.3%)Fail-safe
Not applicable: 4 (33.3%)
12Reported in place: 4 (33.3%)Fail-safe
Reported in progress: 4 (33.3%)Fail-safe
Not applicable: 4 (33.3%)
| 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 | 12 | 7 | 4 | 0 | 0 | 0 | 0 | 1 | 92% | 58% of 12 |
| AI impact assessment | 12 | 6 | 6 | 0 | 0 | 0 | 0 | 0 | 100% | 50% of 12 |
| Independent review | 12 | 6 | 5 | 0 | 0 | 0 | 0 | 1 | 92% | 50% of 12 |
| Ongoing monitoring | 12 | 7 | 4 | 0 | 0 | 0 | 0 | 1 | 92% | 58% of 12 |
| Operator training | 12 | 7 | 4 | 0 | 0 | 0 | 0 | 1 | 92% | 58% of 12 |
| Fail-safe | 12 | 4 | 4 | 0 | 4 | 0 | 0 | 0 | 100% | 50% of 8 |
| Appeal process | 12 | 1 | 4 | 0 | 6 | 1 | 0 | 0 | 100% | 20% of 5 |
| User and public consultation | 12 | 3 | 4 | 0 | 0 | 0 | 5 | 0 | 100% | 25% of 12 |
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 | 88% | 75% | 75% | 88% | 88% | 75% | 50% | 25% | 8 |
| DOJ | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 3 |
| SSA | – | 0% | – | – | – | 100% | 0% | 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
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 |
|---|---|---|---|---|---|---|---|---|---|
| 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 |
| Facial Recognition Technology and Data Mapping Tools DOJ · DOJ-0126 | 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 |
| Facial Recognition Technology and Data Mapping Tools - 2 DOJ · DOJ-0137 | 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 |
| Facial Recognition Technology DOJ · DOJ-0226 | 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 |
| Digital Identity Verification Services SSA · R3122 | Deployed | No answer reported | Reported in progress | No answer reported | No answer reported | No answer reported | Reported in place | Precluded by law or guidance | Reported in place |
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?
- 6 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?
These are questions the inventory raises but cannot answer. They are not findings of non-compliance.