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

Reported in placeReported in progressReported not in placeNot applicableOther or ambiguous answerNo answer reported

Pre-deployment testing

Pre-deployment testing
Reported in place: 9 (56.3%)Pre-deployment testing
Reported in progress: 6 (37.5%)Pre-deployment testing
Reported not in place: 1 (6.3%)

AI impact assessment

AI impact assessment
Reported in place: 9 (56.3%)AI impact assessment
Reported in progress: 6 (37.5%)AI impact assessment
No answer reported: 1 (6.3%)

Independent review

Independent review
Reported in place: 11 (68.8%)Independent review
Reported in progress: 2 (12.5%)Independent review
Reported not in place: 1 (6.3%)Independent review
No answer reported: 2 (12.5%)

Ongoing monitoring

Ongoing monitoring
Reported in place: 9 (56.3%)Ongoing monitoring
Reported in progress: 5 (31.3%)Ongoing monitoring
No answer reported: 2 (12.5%)

Operator training

Operator training
Reported in place: 10 (62.5%)Operator training
Reported in progress: 4 (25.0%)Operator training
No answer reported: 2 (12.5%)

Fail-safe

Fail-safe
Reported in place: 8 (50.0%)Fail-safe
Not applicable: 7 (43.8%)Fail-safe
No answer reported: 1 (6.3%)

Appeal process

Appeal process
Reported in place: 1 (6.3%)Appeal process
Not applicable: 14 (87.5%)Appeal process
No answer reported: 1 (6.3%)

User and public consultation

User and public consultation
Reported in place: 8 (50.0%)User and public consultation
Reported in progress: 1 (6.3%)User and public consultation
Other or ambiguous answer: 6 (37.5%)User and public consultation
No answer reported: 1 (6.3%)

Practice	In scope	In place	In progress	Not in place	N/A	Other	No answer	Answered	In place of applicable
Pre-deployment testing	16	9	6	1	0	0	0	100%	56% of 16
AI impact assessment	16	9	6	0	0	0	1	94%	56% of 16
Independent review	16	11	2	1	0	0	2	88%	69% of 16
Ongoing monitoring	16	9	5	0	0	0	2	88%	56% of 16
Operator training	16	10	4	0	0	0	2	88%	63% of 16
Fail-safe	16	8	0	0	7	0	1	94%	89% of 9
Appeal process	16	1	0	0	14	0	1	94%	50% of 2
User and public consultation	16	8	1	0	0	6	1	94%	50% of 16

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 with any answerIn place Answered

Agency by governance practice
	Testing	Impact assess.	Indep. review	Monitoring	Training	Fail-safe	Appeal	Consultation	n
DOE	100%	100%	78%	89%	89%	100%	100%	89%	9
SBA	100%	100%	100%	100%	100%	100%	100%	100%	6
EAC	100%		100%					100%	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

10 records with at least one practice unanswered or in progressOpen in explorer

Use case	Stage	Test	AIA	Review	Monitor	Train	Fail-safe	Appeal	Consult
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
GitHub Copilot DOE · DOE-586	Deployed	Reported in place	Reported in place	Reported in place	Reported in place	Reported in progress	Reported in place	Not applicable	Reported in place
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
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
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 DOE · DOE-734	Pilot	Reported in progress	Reported in progress	No answer reported	Reported in progress	Reported in progress	Not applicable	Not applicable	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

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.