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: 48 records · all use cases in the current filterReported in placeReported in progressNot applicablePrecluded by law or guidanceOther or ambiguous answerNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 16 (33.3%)Pre-deployment testing
Reported in progress: 10 (20.8%)Pre-deployment testing
No answer reported: 22 (45.8%)
48Reported in place: 16 (33.3%)Pre-deployment testing
Reported in progress: 10 (20.8%)Pre-deployment testing
No answer reported: 22 (45.8%)
AI impact assessment
AI impact assessment
Reported in place: 14 (29.2%)AI impact assessment
Reported in progress: 13 (27.1%)AI impact assessment
No answer reported: 21 (43.8%)
48Reported in place: 14 (29.2%)AI impact assessment
Reported in progress: 13 (27.1%)AI impact assessment
No answer reported: 21 (43.8%)
Independent review
Independent review
Reported in place: 14 (29.2%)Independent review
Reported in progress: 12 (25.0%)Independent review
No answer reported: 22 (45.8%)
48Reported in place: 14 (29.2%)Independent review
Reported in progress: 12 (25.0%)Independent review
No answer reported: 22 (45.8%)
Ongoing monitoring
Ongoing monitoring
Reported in place: 16 (33.3%)Ongoing monitoring
Reported in progress: 10 (20.8%)Ongoing monitoring
No answer reported: 22 (45.8%)
48Reported in place: 16 (33.3%)Ongoing monitoring
Reported in progress: 10 (20.8%)Ongoing monitoring
No answer reported: 22 (45.8%)
Operator training
Operator training
Reported in place: 16 (33.3%)Operator training
Reported in progress: 9 (18.8%)Operator training
Other or ambiguous answer: 1 (2.1%)Operator training
No answer reported: 22 (45.8%)
48Reported in place: 16 (33.3%)Operator training
Reported in progress: 9 (18.8%)Operator training
Other or ambiguous answer: 1 (2.1%)Operator training
No answer reported: 22 (45.8%)
Fail-safe
Fail-safe
Reported in place: 13 (27.1%)Fail-safe
Reported in progress: 10 (20.8%)Fail-safe
Not applicable: 4 (8.3%)Fail-safe
No answer reported: 21 (43.8%)
48Reported in place: 13 (27.1%)Fail-safe
Reported in progress: 10 (20.8%)Fail-safe
Not applicable: 4 (8.3%)Fail-safe
No answer reported: 21 (43.8%)
| 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 | 48 | 16 | 10 | 0 | 0 | 0 | 0 | 22 | 54% | 33% of 48 |
| AI impact assessment | 48 | 14 | 13 | 0 | 0 | 0 | 0 | 21 | 56% | 29% of 48 |
| Independent review | 48 | 14 | 12 | 0 | 0 | 0 | 0 | 22 | 54% | 29% of 48 |
| Ongoing monitoring | 48 | 16 | 10 | 0 | 0 | 0 | 0 | 22 | 54% | 33% of 48 |
| Operator training | 48 | 16 | 9 | 0 | 0 | 0 | 1 | 22 | 54% | 33% of 48 |
| Fail-safe | 48 | 13 | 10 | 0 | 4 | 0 | 0 | 21 | 56% | 30% of 44 |
| Appeal process | 48 | 5 | 10 | 0 | 11 | 1 | 0 | 21 | 56% | 14% of 36 |
| User and public consultation | 48 | 11 | 10 | 0 | 0 | 0 | 6 | 21 | 56% | 23% of 48 |
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 | 58% | 54% | 54% | 58% | 58% | 50% | 27% | 38% | 26 |
| DOJ | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 15 |
| HHS | – | – | – | – | – | – | – | – | 2 |
| GSA | – | – | – | – | – | – | – | – | 1 |
| USDA | 100% | 0% | 0% | 100% | 100% | 100% | 100% | 0% | 1 |
| TREAS | – | – | – | – | – | – | – | – | 1 |
| SSA | – | 0% | – | – | – | 100% | 0% | 100% | 1 |
| STATE | – | – | – | – | – | – | – | – | 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
34 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 |
| Mobile Fortify DHS · DHS-2577 | Deployed | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Other or ambiguous answer | Reported in progress | Reported in progress | Reported in progress |
| Process Efficiency Traveler Identity for Airline Check-in and Bag Drop DHS · DHS-2417 | 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 |
| Autonomous Surveillance Tower DHS · DHS-35 | 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 |
| Biometric Check-in for ATD-ISAP (SmartLINK) DHS · DHS-407 | 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 |
| Biometrics Enrollment Tool (BET) Fingerprint Quality Check DHS · DHS-14 | 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 |
| Open-Source Intelligence for Investigations DHS · DHS-2759 | 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 |
| AdaptiveMFA DHS · DHS-419 | 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 |
| Lexis Nexis DHS · DHS-2605 | 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 |
| Facial Recognition Technology DOJ · DOJ-0122 | 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 |
| Next Generation Identification DOJ · DOJ-0135 | 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 |
| Automated Medication Dispensing Cabinet DOJ · DOJ-0143 | 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 |
| Trunet Systems DOJ · DOJ-0167 | 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 |
| JPATS Mobile App (Biometrics) DOJ · DOJ-0234 | 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 |
| Aware DOJ · DOJ-0235 | 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 |
| Object Detection Tool 1 DOJ · DOJ-0277 | 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 |
| Fingerprint (Friction Ridge) Optical Character Recognition (OCR) DOJ · DOJ-0296 | 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 |
| Login.gov: artificial intelligence technology used for detecting and mitigating fraud for remote unsupervised identity verification GSA · R1167 | 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 |
| 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 |
| Identity Verification TREAS · TREAS-IRS-59 | 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 |
| Video Surveillance System USDA · USDA-025 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in place | Reported in place | Reported in place | Reported in place | Other or ambiguous answer |
| Program Integrity (RRAD-PI) AI Counter-Fraud Enhancement Measures DHS · DHS-2724 | 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 |
| Facial Recognition for National Security and Transnational Criminal Organizations DHS · DHS-2729 | 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 |
| Friction Ridge Print Comparisons DOJ · DOJ-0065 | 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 |
| Data & Analytics: Transportation OCR DOJ · DOJ-0073 | 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 |
| Conduit AI DOJ · DOJ-0310 | 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 |
| Cocounsel AI DOJ · DOJ-0313 | 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 |
| Unaccompanied Child Sponsor Identity Verification HHS · R0614 | 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 |
| Pathogen strain characterization from mixed strain samples HHS · R0698 | 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 |
| Consular Affairs FaceVACS STATE · R3216 | 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- 13 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?
- 11 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
- 13 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
- 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.