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: 23 records · all use cases in the current filterReported in placeReported in progressReported not in placeNot applicableOther or ambiguous answerNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 4 (17.4%)Pre-deployment testing
Reported in progress: 6 (26.1%)Pre-deployment testing
Reported not in place: 1 (4.3%)Pre-deployment testing
No answer reported: 12 (52.2%)
23Reported in place: 4 (17.4%)Pre-deployment testing
Reported in progress: 6 (26.1%)Pre-deployment testing
Reported not in place: 1 (4.3%)Pre-deployment testing
No answer reported: 12 (52.2%)
AI impact assessment
AI impact assessment
Reported in place: 5 (21.7%)AI impact assessment
Reported in progress: 5 (21.7%)AI impact assessment
No answer reported: 13 (56.5%)
23Reported in place: 5 (21.7%)AI impact assessment
Reported in progress: 5 (21.7%)AI impact assessment
No answer reported: 13 (56.5%)
Independent review
Independent review
Reported in place: 6 (26.1%)Independent review
Reported in progress: 2 (8.7%)Independent review
Reported not in place: 1 (4.3%)Independent review
No answer reported: 14 (60.9%)
23Reported in place: 6 (26.1%)Independent review
Reported in progress: 2 (8.7%)Independent review
Reported not in place: 1 (4.3%)Independent review
No answer reported: 14 (60.9%)
Ongoing monitoring
Ongoing monitoring
Reported in place: 4 (17.4%)Ongoing monitoring
Reported in progress: 5 (21.7%)Ongoing monitoring
No answer reported: 14 (60.9%)
23Reported in place: 4 (17.4%)Ongoing monitoring
Reported in progress: 5 (21.7%)Ongoing monitoring
No answer reported: 14 (60.9%)
Operator training
Operator training
Reported in place: 5 (21.7%)Operator training
Reported in progress: 4 (17.4%)Operator training
No answer reported: 14 (60.9%)
23Reported in place: 5 (21.7%)Operator training
Reported in progress: 4 (17.4%)Operator training
No answer reported: 14 (60.9%)
Fail-safe
Fail-safe
Reported in place: 6 (26.1%)Fail-safe
Not applicable: 4 (17.4%)Fail-safe
No answer reported: 13 (56.5%)
23Reported in place: 6 (26.1%)Fail-safe
Not applicable: 4 (17.4%)Fail-safe
No answer reported: 13 (56.5%)
Appeal process23
| 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 | 23 | 4 | 6 | 1 | 0 | 0 | 0 | 12 | 48% | 17% of 23 |
| AI impact assessment | 23 | 5 | 5 | 0 | 0 | 0 | 0 | 13 | 43% | 22% of 23 |
| Independent review | 23 | 6 | 2 | 1 | 0 | 0 | 0 | 14 | 39% | 26% of 23 |
| Ongoing monitoring | 23 | 4 | 5 | 0 | 0 | 0 | 0 | 14 | 39% | 17% of 23 |
| Operator training | 23 | 5 | 4 | 0 | 0 | 0 | 0 | 14 | 39% | 22% of 23 |
| Fail-safe | 23 | 6 | 0 | 0 | 4 | 0 | 0 | 13 | 43% | 32% of 19 |
| Appeal process | 23 | 0 | 0 | 0 | 10 | 0 | 0 | 13 | 43% | 0% of 13 |
| User and public consultation | 23 | 4 | 1 | 0 | 0 | 0 | 5 | 13 | 43% | 17% of 23 |
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 | 15% | 23% | 31% | 15% | 23% | 50% | 0% | 15% | 13 |
| SBA | 100% | 100% | 100% | 100% | 100% | 100% | 0% | 50% | 2 |
| NIGC | – | – | – | – | – | – | – | – | 1 |
| HUD | – | – | – | – | – | – | – | – | 1 |
| USDA | – | – | – | – | – | – | – | – | 1 |
| DOJ | – | – | – | – | – | – | – | – | 1 |
| EAC | 0% | – | 0% | – | – | – | – | 100% | 1 |
| DOI | – | – | – | – | – | – | – | – | 1 |
| OSC | – | – | – | – | – | – | – | – | 1 |
| FTC | – | – | – | – | – | – | – | – | 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
21 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 |
| 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 |
| 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 |
| 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 |
| GitHub Copilot DOE · DOE-584 | 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 |
| 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 |
| Integration of AI, specifically CoPilot for GitHub, for BTFA Software Development Life Cycle Process for DME and O&M applications. DOI · DOI-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 |
| 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 |
| Microsoft 365 Copilot FTC · FTC-0010 | 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 |
| Microsoft Copilot HUD · HUD-2025-001 | 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 Studio OSC · OSC-0001 | 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 |
| Axon+ Copilot Studio Chatbot USDA · USDA-098 | 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- 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?
- 4 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.