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: 51 records · all use cases in the current filterReported in placeReported in progressReported not in placeNot applicableOther or ambiguous answerNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 8 (15.7%)Pre-deployment testing
Reported in progress: 4 (7.8%)Pre-deployment testing
Reported not in place: 1 (2.0%)Pre-deployment testing
No answer reported: 38 (74.5%)
51Reported in place: 8 (15.7%)Pre-deployment testing
Reported in progress: 4 (7.8%)Pre-deployment testing
Reported not in place: 1 (2.0%)Pre-deployment testing
No answer reported: 38 (74.5%)
AI impact assessment
AI impact assessment
Reported in place: 8 (15.7%)AI impact assessment
Reported in progress: 4 (7.8%)AI impact assessment
No answer reported: 39 (76.5%)
51Reported in place: 8 (15.7%)AI impact assessment
Reported in progress: 4 (7.8%)AI impact assessment
No answer reported: 39 (76.5%)
Independent review
Independent review
Reported in place: 9 (17.6%)Independent review
Reported in progress: 2 (3.9%)Independent review
Reported not in place: 1 (2.0%)Independent review
No answer reported: 39 (76.5%)
51Reported in place: 9 (17.6%)Independent review
Reported in progress: 2 (3.9%)Independent review
Reported not in place: 1 (2.0%)Independent review
No answer reported: 39 (76.5%)
Ongoing monitoring
Ongoing monitoring
Reported in place: 8 (15.7%)Ongoing monitoring
Reported in progress: 3 (5.9%)Ongoing monitoring
No answer reported: 40 (78.4%)
51Reported in place: 8 (15.7%)Ongoing monitoring
Reported in progress: 3 (5.9%)Ongoing monitoring
No answer reported: 40 (78.4%)
Operator training
Operator training
Reported in place: 10 (19.6%)Operator training
Reported in progress: 1 (2.0%)Operator training
No answer reported: 40 (78.4%)
51Reported in place: 10 (19.6%)Operator training
Reported in progress: 1 (2.0%)Operator training
No answer reported: 40 (78.4%)
Fail-safe
Fail-safe
Reported in place: 6 (11.8%)Fail-safe
Not applicable: 6 (11.8%)Fail-safe
No answer reported: 39 (76.5%)
51Reported in place: 6 (11.8%)Fail-safe
Not applicable: 6 (11.8%)Fail-safe
No answer reported: 39 (76.5%)
| 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 | 51 | 8 | 4 | 1 | 0 | 0 | 0 | 38 | 25% | 16% of 51 |
| AI impact assessment | 51 | 8 | 4 | 0 | 0 | 0 | 0 | 39 | 24% | 16% of 51 |
| Independent review | 51 | 9 | 2 | 1 | 0 | 0 | 0 | 39 | 24% | 18% of 51 |
| Ongoing monitoring | 51 | 8 | 3 | 0 | 0 | 0 | 0 | 40 | 22% | 16% of 51 |
| Operator training | 51 | 10 | 1 | 0 | 0 | 0 | 0 | 40 | 22% | 20% of 51 |
| Fail-safe | 51 | 6 | 0 | 0 | 6 | 0 | 0 | 39 | 24% | 13% of 45 |
| Appeal process | 51 | 1 | 0 | 0 | 11 | 0 | 0 | 39 | 24% | 3% of 40 |
| User and public consultation | 51 | 7 | 0 | 0 | 0 | 0 | 6 | 38 | 25% | 14% of 51 |
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 | 12% | 12% | 18% | 12% | 24% | 21% | 0% | 12% | 17 |
| HHS | – | – | – | – | – | – | – | – | 6 |
| SBA | 100% | 100% | 100% | 100% | 100% | 100% | 100% | 67% | 6 |
| TREAS | – | – | – | – | – | – | – | – | 4 |
| DOJ | – | – | – | – | – | – | – | – | 3 |
| DHS | – | – | – | – | – | – | – | – | 3 |
| NASA | – | – | – | – | – | – | – | – | 2 |
| VA | – | – | – | – | – | – | – | – | 2 |
| HUD | – | – | – | – | – | – | – | – | 1 |
| DOT | – | – | – | – | – | – | – | – | 1 |
| USDA | – | – | – | – | – | – | – | – | 1 |
| EAC | 0% | – | 0% | – | – | – | – | 100% | 1 |
| DOI | – | – | – | – | – | – | – | – | 1 |
| SSA | – | – | – | – | – | – | – | – | 1 |
| OSC | – | – | – | – | – | – | – | – | 1 |
| FTC | – | – | – | – | – | – | – | – | 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
45 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| Microsoft 365 Copilot (Productivity Suite) DOE · DOE-433 | 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 |
| Microsoft Copilot for Security DOE · DOE-441 | 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 |
| Copilot Studio DOE · DOE-444 | Deployed | Reported in progress | Reported in place | Reported in place | Reported in progress | Reported in place | Reported in place | Not applicable | Other or ambiguous answer |
| Copilot for Microsoft 365 DOE · DOE-452 | Deployed | Reported in progress | Reported in place | Reported in place | Reported in progress | Reported in place | Reported in place | Not applicable | Other or ambiguous answer |
| LANL AI Portal DOE · DOE-495 | Deployed | Reported in place | Reported in progress | Reported in place | Reported in place | Reported in place | Not applicable | Not applicable | Reported in place |
| Microsoft Copilot DOE · DOE-577 | Deployed | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Not applicable | Not applicable | Reported in place |
| Microsoft CoPilot DOE · DOE-593 | 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 |
| Microsoft Copilot Studio DOE · DOE-739 | 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 |
| Code Development DOJ · DOJ-0312 | 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 |
| Power Platform Use DOT · DOT-1000051 | 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 |
| ChatOFR AI Chatbot TREAS · TREASURY-OFR-001 | 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 |
| Source Code Development Tool DHS · DHS-2452 | 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 |
| Private Artificial Intelligence (AI) Tech Hub (PAiTH) DHS · DHS-2599 | 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 |
| LIGER Generative AI Toolkit DHS · DHS-2454 | 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 |
| Tabnine AI Pair Programmer DOE · DOE-567 | 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 |
| M365 Copilot DOE · DOE-574 | Pilot | Reported in place | Reported in progress | Reported in progress | Reported in place | Reported in place | Reported in place | Not applicable | Other or ambiguous answer |
| GitHub Copilot DOE · DOE-584 | 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 |
| AI Enabled Code Review DOE · DOE-606 | 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 |
| Claude Anthropic Enterprise DOE · DOE-618 | 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 |
| O365 Copilot DOE · DOE-648 | 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 |
| Microsoft Copilot Pilot DOE · DOE-676 | Pilot | Reported in progress | Reported in progress | No answer reported | No answer reported | No answer reported | Not applicable | Not applicable | Other or ambiguous answer |
| Copilot Studio DOE · DOE-690 | 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 |
| Microsoft 365 Copilot DOE · DOE-708 | 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 |
| Integration of AI, specifically CoPilot for GitHub, for BTFA Software Development Life Cycle Process for DME and O&M applications. DOI · DOI-0001 | 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 |
| CoPilot DOJ · DOJ-0177 | 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-assisted Legacy Code Modernization DOJ · DOJ-0341 | 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 |
| Internal Generative AI Tools for Staff Productivity EAC · EAC-2 | Pilot | Reported not in place | No answer reported | Reported not in place | No answer reported | No answer reported | No answer reported | No answer reported | Reported in place |
| Microsoft 365 Copilot FTC · FTC-0010 | 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 |
| AI DevOps - Improving Development and CI/CD Operations HHS · R0628 | 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 |
| Leveraging AI for the Creation of Synthetic Datasets HHS · R0705 | 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 |
| AI Code Assistance – WETG GitHub CoPilot Proof-of-Concept HHS · R0777 | 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 |
| AI-Generated Data Processing and Visualization Code Development HHS · R0872 | 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 |
| Code Conversion for PowerBI Migration HHS · R0894 | 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 |
| CoPilot Outlook HHS · R1038 | 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 |
| Microsoft Copilot HUD · HUD-2025-001 | 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 |
| Intelligent Chatbot for Science using Microsoft Copilot NASA · NASA-723 | 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 |
| Using MML code generation to create new high-energy astrophysics science software NASA · NASA-877 | 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 |
| Copilot Studio OSC · OSC-0001 | 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 |
| Mainframe code modernization assistant SSA · R3119 | 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 |
| Software Code Generation TREAS · 21 | 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 for Data Platform Operations TREAS · DO/TCSC/EDM-1 | 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 |
| Local GenAI Pilot TREAS · TREAS-117 | 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 |
| Axon+ Copilot Studio Chatbot USDA · USDA-098 | 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 |
| VetsEZ Middleware Development VA · VA-25-5472 | 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 |
| Internal QMS Processes Revamp VA · VA-25-2578 | 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- 2 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
- 2 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
- 8 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.