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: 50 records · use cases that answered at least one practice question

Reported in placeReported in progressNot applicableOther or ambiguous answerNo answer reported

Pre-deployment testing

Pre-deployment testing
Reported in place: 8 (16.0%)Pre-deployment testing
Reported in progress: 42 (84.0%)

AI impact assessment

AI impact assessment
Reported in place: 7 (14.0%)AI impact assessment
Reported in progress: 39 (78.0%)AI impact assessment
No answer reported: 4 (8.0%)

Independent review

Independent review
Reported in place: 9 (18.0%)Independent review
Reported in progress: 31 (62.0%)Independent review
No answer reported: 10 (20.0%)

Ongoing monitoring

Ongoing monitoring
Reported in place: 6 (12.0%)Ongoing monitoring
Reported in progress: 34 (68.0%)Ongoing monitoring
No answer reported: 10 (20.0%)

Operator training

Operator training
Reported in place: 10 (20.0%)Operator training
Reported in progress: 32 (64.0%)Operator training
No answer reported: 8 (16.0%)

Fail-safe

Fail-safe
Reported in place: 6 (12.0%)Fail-safe
Not applicable: 44 (88.0%)

Appeal process

Appeal process
Reported in place: 1 (2.0%)Appeal process
Not applicable: 49 (98.0%)

User and public consultation

User and public consultation
Reported in place: 36 (72.0%)User and public consultation
Other or ambiguous answer: 14 (28.0%)

Practice	In scope	In place	In progress	N/A	Other	No answer	Answered	In place of applicable
Pre-deployment testing	50	8	42	0	0	0	100%	16% of 50
AI impact assessment	50	7	39	0	0	4	92%	14% of 50
Independent review	50	9	31	0	0	10	80%	18% of 50
Ongoing monitoring	50	6	34	0	0	10	80%	12% of 50
Operator training	50	10	32	0	0	8	84%	20% of 50
Fail-safe	50	6	0	44	0	0	100%	100% of 6
Appeal process	50	1	0	49	0	0	100%	100% of 1
User and public consultation	50	36	0	0	14	0	100%	72% of 50

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
DOE	9%	7%	11%	4%	13%	100%	100%	76%	46
SBA	100%	100%	100%	100%	100%	100%	0%	25%	4

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
ServiceNow Predictive Intelligence DOE · DOE-430	Deployed	Reported in place	Reported in progress	Reported in place	Reported in place	Reported in place	Not applicable	Not applicable	Reported in place
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
Microsoft Bing Service DOE · DOE-510	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Visual Studio Enterprise DOE · DOE-519	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft OneNote DOE · DOE-525	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Azure Authoring Tools DOE · DOE-536	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Apple Intelligence DOE · DOE-549	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft ScreenSketch DOE · DOE-551	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Visual C++ Additional Runtime DOE · DOE-552	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Project DOE · DOE-556	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Google Chrome Generative AI DOE · DOE-561	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
GitHub Co-Pilot DOE · DOE-571	Deployed	Reported in place	No answer reported	Reported in place	Reported in progress	Reported in progress	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 Visual C++ Redistributable DOE · DOE-596	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Teams DOE · DOE-599	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Search in Bing DOE · DOE-602	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Teams Classic DOE · DOE-608	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
LivChat DOE · DOE-613	Deployed	Reported in place	No answer reported	No answer reported	No answer reported	No answer reported	Not applicable	Not applicable	Other or ambiguous answer
Microsoft MSPaint DOE · DOE-623	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Visual Studio Community DOE · DOE-631	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft OneDrive DOE · DOE-634	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft 365 DOE · DOE-651	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Visual C++ Minimum Runtime DOE · DOE-667	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft OneDrive MUI DOE · DOE-669	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft 365 Apps for Enterprise DOE · DOE-685	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Outlook MUI DOE · DOE-691	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Edge DOE · DOE-698	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
SQL Server Management Studio DOE · DOE-710	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Exchange Server DOE · DOE-711	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Skype App DOE · DOE-721	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft OneNote MUI DOE · DOE-735	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft PowerPoint MUI DOE · DOE-744	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Power BI Desktop DOE · DOE-748	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Azure PowerShell DOE · DOE-749	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Ariculate 360 AI Assistant DOE · DOE-511	Pre-deployment	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Bernie-AI: Infrastructure Planning Support POC DOE · DOE-514	Pilot	Reported in progress	Reported in progress	No answer reported	No answer reported	No answer reported	Not applicable	Not applicable	Other or ambiguous answer
OpenAI ChatGPT Pilot DOE · DOE-526	Pilot	Reported in progress	Reported in progress	No answer reported	No answer reported	No answer reported	Not applicable	Not applicable	Other or ambiguous answer
Ask Alan DOE · DOE-569	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
xAI Grok Pilot DOE · DOE-601	Pilot	Reported in progress	Reported in progress	No answer reported	No answer reported	No answer reported	Not applicable	Not applicable	Other or ambiguous answer
Ask IT DOE · DOE-615	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
LISA Chatbot Pilot DOE · DOE-671	Pilot	Reported in progress	Reported in progress	No answer reported	No answer reported	No answer reported	Not applicable	Not applicable	Other or ambiguous answer
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
Amazon Q Chatbot Pilot DOE · DOE-700	Pre-deployment	Reported in progress	Reported in progress	No answer reported	No answer reported	No answer reported	Not applicable	Not applicable	Other or ambiguous answer
Anthropic Claude Pilot DOE · DOE-703	Pilot	Reported in progress	Reported in progress	No answer reported	No answer reported	No answer reported	Not applicable	Not applicable	Other or ambiguous answer

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?
3 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
35 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.