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Snapshot · OMB 2025 inventory · processed Oct 11, 2026
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.

Agency
Stage
High-impact
Topic
AI type1
Sourcing
Vendor
Function
Start year

Only records with a parseable start date match a year filter.

AI type: Generative AIindependent_review: affirmative

Practice-by-practice evidence

Denominator: 4 records · use cases designated high-impact
Reported in placeReported in progressNot applicableOther or ambiguous answer
PracticeIn scopeIn placeIn progressNot in placeN/APrecluded or waivedOtherNo answerAnsweredIn place of applicable
Pre-deployment testing42200000100%50% of 4
AI impact assessment44000000100%100% of 4
Independent review44000000100%100% of 4
Ongoing monitoring41300000100%25% of 4
Operator training44000000100%100% of 4
Fail-safe44000000100%100% of 4
Appeal process40004000100%n/a of 0
User and public consultation42000020100%50% of 4

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 placeAnswered
Agency by governance practice
TestingImpact assess.Indep. reviewMonitoringTrainingFail-safeAppealConsultationn
SSA100%100%100%50%100%100%0%100%2
DOE0%100%100%0%100%100%0%0%2

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

3 records with at least one practice unanswered or in progressOpen in explorer
Use caseStageTestAIAReviewMonitorTrainFail-safeAppealConsult
Copilot Studio
DOE · DOE-444
DeployedReported in progressReported in placeReported in placeReported in progressReported in placeReported in placeNot applicableOther or ambiguous answer
Copilot for Microsoft 365
DOE · DOE-452
DeployedReported in progressReported in placeReported in placeReported in progressReported in placeReported in placeNot applicableOther or ambiguous answer
Policy Assistance Tool (PAT)
SSA · R3116
PilotReported in placeReported in placeReported in placeReported in progressReported in placeReported in placeNot applicableReported in place

Unanswered analytical questions

Generated from the data; for follow-up with agencies
  1. 4 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
  2. 2 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
  3. 14 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.