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: 15 records · all use cases in the current filterReported in placeReported in progressNot applicableOther or ambiguous answerNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 2 (13.3%)Pre-deployment testing
Reported in progress: 3 (20.0%)Pre-deployment testing
No answer reported: 10 (66.7%)
15Reported in place: 2 (13.3%)Pre-deployment testing
Reported in progress: 3 (20.0%)Pre-deployment testing
No answer reported: 10 (66.7%)
AI impact assessment
AI impact assessment
Reported in place: 3 (20.0%)AI impact assessment
Reported in progress: 2 (13.3%)AI impact assessment
No answer reported: 10 (66.7%)
15Reported in place: 3 (20.0%)AI impact assessment
Reported in progress: 2 (13.3%)AI impact assessment
No answer reported: 10 (66.7%)
Independent review
Independent review
Reported in place: 4 (26.7%)Independent review
Reported in progress: 1 (6.7%)Independent review
No answer reported: 10 (66.7%)
15Reported in place: 4 (26.7%)Independent review
Reported in progress: 1 (6.7%)Independent review
No answer reported: 10 (66.7%)
Ongoing monitoring
Ongoing monitoring
Reported in place: 2 (13.3%)Ongoing monitoring
Reported in progress: 3 (20.0%)Ongoing monitoring
No answer reported: 10 (66.7%)
15Reported in place: 2 (13.3%)Ongoing monitoring
Reported in progress: 3 (20.0%)Ongoing monitoring
No answer reported: 10 (66.7%)
Operator training
Operator training
Reported in place: 3 (20.0%)Operator training
Reported in progress: 2 (13.3%)Operator training
No answer reported: 10 (66.7%)
15Reported in place: 3 (20.0%)Operator training
Reported in progress: 2 (13.3%)Operator training
No answer reported: 10 (66.7%)
| 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 | 15 | 2 | 3 | 0 | 0 | 0 | 0 | 10 | 33% | 13% of 15 |
| AI impact assessment | 15 | 3 | 2 | 0 | 0 | 0 | 0 | 10 | 33% | 20% of 15 |
| Independent review | 15 | 4 | 1 | 0 | 0 | 0 | 0 | 10 | 33% | 27% of 15 |
| Ongoing monitoring | 15 | 2 | 3 | 0 | 0 | 0 | 0 | 10 | 33% | 13% of 15 |
| Operator training | 15 | 3 | 2 | 0 | 0 | 0 | 0 | 10 | 33% | 20% of 15 |
| Fail-safe | 15 | 3 | 0 | 0 | 2 | 0 | 0 | 10 | 33% | 23% of 13 |
| Appeal process | 15 | 0 | 0 | 0 | 5 | 0 | 0 | 10 | 33% | 0% of 10 |
| User and public consultation | 15 | 3 | 0 | 0 | 0 | 0 | 2 | 10 | 33% | 20% of 15 |
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 | |
|---|---|---|---|---|---|---|---|---|---|
| DOE | 20% | 30% | 40% | 20% | 30% | 38% | 0% | 30% | 10 |
| NIGC | – | – | – | – | – | – | – | – | 1 |
| DOT | – | – | – | – | – | – | – | – | 1 |
| DOJ | – | – | – | – | – | – | – | – | 1 |
| VA | – | – | – | – | – | – | – | – | 1 |
| TREAS | – | – | – | – | – | – | – | – | 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
15 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| Microsoft 365 Copilot (Productivity Suite) DOE · DOE-433 | 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 for Security DOE · DOE-441 | 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 |
| 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 |
| GitHub Copilot with the OpenAI Codex DOE · DOE-490 | 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 |
| 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 |
| Microsoft CoPilot DOE · DOE-593 | 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 Studio DOE · DOE-739 | 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 |
| Code Development DOJ · DOJ-0312 | 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 |
| Power Platform Use DOT · DOT-1000051 | 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 NIGC · NIGC-3 | 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 |
| ChatOFR AI Chatbot TREAS · TREASURY-OFR-001 | 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 |
| CT CoPilot VA · VA-24-5222 | 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 |
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?
- 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.