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: 55 records · all use cases in the current filterReported in placeReported in progressNot applicableWaived by CAIONo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 2 (3.6%)Pre-deployment testing
Reported in progress: 1 (1.8%)Pre-deployment testing
No answer reported: 52 (94.5%)
55Reported in place: 2 (3.6%)Pre-deployment testing
Reported in progress: 1 (1.8%)Pre-deployment testing
No answer reported: 52 (94.5%)
AI impact assessment
AI impact assessment
Reported in place: 1 (1.8%)AI impact assessment
Reported in progress: 1 (1.8%)AI impact assessment
No answer reported: 53 (96.4%)
55Reported in place: 1 (1.8%)AI impact assessment
Reported in progress: 1 (1.8%)AI impact assessment
No answer reported: 53 (96.4%)
Independent review
Independent review
Reported in place: 1 (1.8%)Independent review
Waived by CAIO: 1 (1.8%)Independent review
No answer reported: 53 (96.4%)
55Reported in place: 1 (1.8%)Independent review
Waived by CAIO: 1 (1.8%)Independent review
No answer reported: 53 (96.4%)
Ongoing monitoring
Ongoing monitoring
Reported in place: 2 (3.6%)Ongoing monitoring
Reported in progress: 1 (1.8%)Ongoing monitoring
No answer reported: 52 (94.5%)
55Reported in place: 2 (3.6%)Ongoing monitoring
Reported in progress: 1 (1.8%)Ongoing monitoring
No answer reported: 52 (94.5%)
Operator training
Operator training
Reported in place: 2 (3.6%)Operator training
Reported in progress: 1 (1.8%)Operator training
No answer reported: 52 (94.5%)
55Reported in place: 2 (3.6%)Operator training
Reported in progress: 1 (1.8%)Operator training
No answer reported: 52 (94.5%)
| 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 | 55 | 2 | 1 | 0 | 0 | 0 | 0 | 52 | 5% | 4% of 55 |
| AI impact assessment | 55 | 1 | 1 | 0 | 0 | 0 | 0 | 53 | 4% | 2% of 55 |
| Independent review | 55 | 1 | 0 | 0 | 0 | 1 | 0 | 53 | 4% | 2% of 54 |
| Ongoing monitoring | 55 | 2 | 1 | 0 | 0 | 0 | 0 | 52 | 5% | 4% of 55 |
| Operator training | 55 | 2 | 1 | 0 | 0 | 0 | 0 | 52 | 5% | 4% of 55 |
| Fail-safe | 55 | 2 | 0 | 0 | 1 | 0 | 0 | 52 | 5% | 4% of 54 |
| Appeal process | 55 | 0 | 0 | 0 | 2 | 0 | 0 | 53 | 4% | 0% of 53 |
| User and public consultation | 55 | 2 | 1 | 0 | 0 | 0 | 0 | 52 | 5% | 4% of 55 |
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 | |
|---|---|---|---|---|---|---|---|---|---|
| FRB | – | – | – | – | – | – | – | – | 20 |
| NARA | – | – | – | – | – | – | – | – | 7 |
| DOI | – | – | – | – | – | – | – | – | 6 |
| FDIC | – | – | – | – | – | – | – | – | 5 |
| VA | – | – | – | – | – | – | – | – | 4 |
| DOE | 50% | 25% | 33% | 50% | 50% | 67% | 0% | 50% | 4 |
| STB | – | – | – | – | – | – | – | – | 2 |
| STATE | – | – | – | – | – | – | – | – | 2 |
| SEC | – | – | – | – | – | – | – | – | 1 |
| NTSB | – | – | – | – | – | – | – | – | 1 |
| HUD | – | – | – | – | – | – | – | – | 1 |
| HHS | – | – | – | – | – | – | – | – | 1 |
| GSA | – | – | – | – | – | – | – | – | 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
54 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| AI for Operations Center DOE · DOE-10 | Deployed | Reported in place | No answer reported | No answer reported | Reported in place | Reported in place | Reported in place | No answer reported | Reported in place |
| WCD-AI DOE · DOE-474 | 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 |
| FOIA Request Lexical Similarity Tool in the Document Review Platform (Term Frequency – Inverse Document Frequency (TF-IDF) - Cosine) DOI · DOI-0020 | 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 |
| Enabling FOIA Request Clustering Capability in the Document Review Platform (Density Based Algorithm alongside Term Frequency – Inverse Document Frequency (TF-IDF)) DOI · DOI-0019 | 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 |
| FOIA Request Clustering Tool (Embedding based clustering alongside Term Frequency – Inverse Document Frequency (TF-IDF)) DOI · DOI-0018 | 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 |
| FOIA Request Conceptual Similarity Tool (Semantic Similarity Score Generation) DOI · DOI-0017 | 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 |
| Blockchain and Cryptocurrency Transaction Identification and Visualization FDIC · FDIC-65 | 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 |
| Location and Evaluation of Individuals and Assets for Collectability of Civil Claim FDIC · FDIC-66 | 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 |
| Social Listening FDIC · FDIC-68 | 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 |
| Proposals and Public Comments FRB · FRB-0013 | 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 |
| Manufacturer Sentiment Analysis FRB · FRB-0016 | 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 |
| Supply Chain Estimations FRB · FRB-0017 | 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 |
| Market Fund Portfolio FRB · FRB-0022 | 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 |
| Sentiment Analysis of Earnings Transcripts FRB · FRB-0024 | 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 |
| Anomaly Detection FRB · FRB-0025 | 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 |
| Consumer Complaints Explorer FRB · FRB-0026 | 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 |
| Document Summarization Statistics FRB · FRB-0034 | 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 |
| Comment Review System FRB · FRB-0036 | 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 |
| Bank Examiner Search Engine FRB · FRB-0052 | 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 |
| Category Taxonomy Refinement Using NLP GSA · R1162 | 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 |
| Qualitative Analysis HHS · R0610 | 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 |
| Automated Draft Narrative Reports
Previously "Automating Draft Counterparty Credit Narrative Reports"; have since expanded to general enterprise use. HUD · HUD-2024-003 | 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 |
| NARA@WORK Kendra Search NARA · NARA - 0003 | 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 |
| Amelia Earhart AI Search NARA · NARA - 0004 | 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 |
| Using Natural Language Processing Techniques to Search and Analyze Certain Filings SEC · SEC-23 | 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 (Pilot) DOE · DOE-603 | Pilot | Reported in progress | Reported in progress | Reported in place | Reported in progress | Reported in progress | Reported in place | Not applicable | Reported in progress |
| FOIA Record Pre-Review Tool DOI · DOI-0025 | 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 |
| Automate Project Execution of FI&R (Facilities Improvement and Repair) Projects DOI · DOI-0004 | 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 |
| Trust Document Entity Extraction FDIC · FDIC – 52 | 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 |
| Trust Document Entity Extraction - LLM FDIC · FDIC – 53 | 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 |
| Stock Market Analysis FRB · FRB-0005 | 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 |
| Financial News Processing FRB · FRB-0032 | 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 |
| Bank Exam Quality Control – Model 1 FRB · FRB-0033 | 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 |
| Writing Quality Analysis Model FRB · FRB-0035 | 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 |
| Trading Desk Grouping FRB · FRB-0037 | 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 |
| Earnings Call Topic Model FRB · FRB-0044 | 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 |
| Bank Exam Quality Control – Model 2 FRB · FRB-0047 | 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 |
| Oasis Semantic Search FRB · FRB-0053 | 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 |
| Data Quality Prioritization Dashboard FRB · FRB-0055 | 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 |
| Monitoring Earnings Conference Calls FRB · FRB-0056 | 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 based Semantic Search for National Archives Catalog (aka ArchiAI) NARA · NARA - 0006 | 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 |
| Create an AI based knowledge articles user interface for working with CRG documents NARA · NARA - 0009 | 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 |
| EOP 42 Search PoC using AI Based Semantic Search NARA · NARA - 0010 | 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 |
| Freedom of Information Act (FOIA) Discovery AI Pilot NARA · NARA - 0011 | 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 |
| Archives.gov AI search NARA · NARA - 0012 | 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 |
| Voice to text transcription NTSB · NTSB-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 |
| Automatic Detection of Authentic Material STATE · R3242 | 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 |
| Live Consular AI Language Augmentation (LCALA) - Visa Interview Pilot STATE · R3267 | 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 for Appian STB · TBD | 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 |
| RelativityOne STB · TBD | 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 |
| ASKA: Automated Support and Knowledge Assistance VA · VA-25-3670 | 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 |
| Clinician-Administered PTSD Scale for DSM-5 (CAPS-5) Clinician Training Simulator VA · VA-24-3783 | 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 |
| Research and Development Computer Center (RDCC) System Transformation AI Supported Reporting VA · VA-25-3723 | 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 |
| Program Evaluation for Commission on Collegiate Nursing Education (CCNE) VA · VA-25-3152 | 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 |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- 1 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.