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 applicableNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in progress: 2 (4.2%)Pre-deployment testing
No answer reported: 46 (95.8%)
48Reported in progress: 2 (4.2%)Pre-deployment testing
No answer reported: 46 (95.8%)
AI impact assessment
AI impact assessment
Reported in progress: 2 (4.2%)AI impact assessment
No answer reported: 46 (95.8%)
48Reported in progress: 2 (4.2%)AI impact assessment
No answer reported: 46 (95.8%)
Independent review48
Ongoing monitoring48
Operator training48
Fail-safe
Fail-safe
Reported in place: 1 (2.1%)Fail-safe
Reported in progress: 1 (2.1%)Fail-safe
No answer reported: 46 (95.8%)
48Reported in place: 1 (2.1%)Fail-safe
Reported in progress: 1 (2.1%)Fail-safe
No answer reported: 46 (95.8%)
Appeal process
Appeal process
Reported in progress: 1 (2.1%)Appeal process
Not applicable: 1 (2.1%)Appeal process
No answer reported: 46 (95.8%)
48Reported in progress: 1 (2.1%)Appeal process
Not applicable: 1 (2.1%)Appeal process
No answer reported: 46 (95.8%)
User and public consultation
User and public consultation
Reported in progress: 2 (4.2%)User and public consultation
No answer reported: 46 (95.8%)
48Reported in progress: 2 (4.2%)User and public consultation
No answer reported: 46 (95.8%)
| 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 | 0 | 2 | 0 | 0 | 0 | 0 | 46 | 4% | 0% of 48 |
| AI impact assessment | 48 | 0 | 2 | 0 | 0 | 0 | 0 | 46 | 4% | 0% of 48 |
| Independent review | 48 | 0 | 2 | 0 | 0 | 0 | 0 | 46 | 4% | 0% of 48 |
| Ongoing monitoring | 48 | 0 | 2 | 0 | 0 | 0 | 0 | 46 | 4% | 0% of 48 |
| Operator training | 48 | 0 | 2 | 0 | 0 | 0 | 0 | 46 | 4% | 0% of 48 |
| Fail-safe | 48 | 1 | 1 | 0 | 0 | 0 | 0 | 46 | 4% | 2% of 48 |
| Appeal process | 48 | 0 | 1 | 0 | 1 | 0 | 0 | 46 | 4% | 0% of 47 |
| User and public consultation | 48 | 0 | 2 | 0 | 0 | 0 | 0 | 46 | 4% | 0% 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 | – | – | – | – | – | – | – | – | 11 |
| DOJ | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 9 |
| DOE | – | – | – | – | – | – | – | – | 7 |
| VA | – | – | – | – | – | – | – | – | 4 |
| FHFA | – | – | – | – | – | – | – | – | 3 |
| GSA | – | – | – | – | – | – | – | – | 3 |
| TVA | – | – | – | – | – | – | – | – | 2 |
| SEC | – | – | – | – | – | – | – | – | 1 |
| NRC | – | – | – | – | – | – | – | – | 1 |
| NEA | – | – | – | – | – | – | – | – | 1 |
| HHS | – | – | – | – | – | – | – | – | 1 |
| USDA | – | – | – | – | – | – | – | – | 1 |
| TREAS | – | – | – | – | – | – | – | – | 1 |
| DOC | – | – | – | – | – | – | – | – | 1 |
| PBGC | – | – | – | – | – | – | – | – | 1 |
| SBA | 0% | 0% | 0% | 0% | 0% | 100% | 0% | 0% | 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
48 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| Critical Infrastructure Network Anomaly Detection DHS · DHS-106 | 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 Detection of Personally Identifiable Information (PII) in Cybersecurity Data DHS · DHS-4 | 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 |
| Cybersecurity Threat Management, Detection, and Response DHS · DHS-2426 | 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 |
| 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 |
| Machine Learning components within CrowdStrike DOE · DOE-458 | 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 |
| Cyber Threat Enrichment DOE · DOE-467 | 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 |
| Deep Learning Malware Analysis for reusable cyber defenses. DOE · DOE-76 | 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 |
| Cybersecurity Defense Tools DOJ · DOJ-0101 | 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 |
| UAS Threat Detector DOJ · DOJ-0169 | 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 |
| Exiger Supply Chain Risk Management - DDIQ Research Engine DOJ · DOJ-0174 | 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 |
| Exiger Supply Chain Risk Management - DDIQ Due Diligence Analytics DOJ · DOJ-0175 | 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 |
| Smartphone and tablet operating systems and features DOJ · DOJ-0258 | 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 |
| Phishing Email Identification FHFA · FHFA-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 |
| Security and network monitoring using Cisco Identify Services engine FHFA · FHFA-10 | 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 |
| Virtual Desktop using Citrix FHFA · FHFA-11 | 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 |
| Elastic Machine Learning Threat Detection (Phase 1) GSA · R1179 | 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 |
| Elastic Machine Learning Threat Detection (Phase 2) GSA · R1180 | 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 |
| Support routine administrative tasks and enhancing communications NRC · NRC-0002 | 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 |
| Cyber Threat Detection DHS · DHS-2446 | 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 |
| Malware Reverse Engineering DHS · DHS-107 | 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 |
| ICE Enterprise AI Assistant DHS · DHS-2594 | 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 |
| One Health Threat Detection and Risk Assessment Platform (OH-TREADS) / Planner DHS · DHS-2421 | 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 |
| Risk Management Framework (RMF) Automation DHS · DHS-2740 | 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 |
| Security Operation Center (SOC) Network Anomaly Detection DHS · DHS-2403 | Retired | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Confidence Scoring for Cybersecurity Threat Indicators DHS · DHS-5 | Retired | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| USAi.gov DOC · DOC-208 | Not reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| CyberSearch DOE · DOE-647 | 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 |
| COREII DOE · DOE-693 | 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 |
| Agentic AI for cybersecurity change request reviews DOE · DOE-701 | 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 |
| Narrative Analysis for Fusion Desktop DOJ · DOJ-0190 | 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 |
| Narrative Analysis for DOJ MIS DOJ · DOJ-0191 | 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 |
| Creating and Maintaining IT Security Packages for Authorizations DOJ · DOJ-0357 | 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 |
| Creating and Maintaining IT Security Packages for Authorizations DOJ · DOJ-0357 | 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 |
| Cybersecurity Chatbot GSA · R1178 | 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 |
| C3PO: CMS Comprehensive Cybersecurity and Privacy Optimization HHS · R0807 | 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 |
| Managing Cybersecurity Controls NEA · NEA-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 |
| IT Security and Privacy Control Assessment PBGC · PBGC - 11 | 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-Powered Search and Recovery SBA · SBA-41 | Pre-deployment | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in place | Not applicable | Reported in progress |
| Evaluating Cybersecurity Alerts SEC · SEC-11 | 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 |
| Establish localized Large Language Model (LLM) TREAS · REQ-2025-02310 | 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 |
| Advanced Network Anomaly Detection TVA · R1116 | Not reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Network Anomaly Detection TVA · R1121 | Not reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Automating ATO/POAM documentation USDA · USDA-115 | 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 |
| Cyber Authorization Memo Generation VA · VA-25-6956 | 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 |
| CSOC AI Analyst Accelerator (Andesite AI) VA · VA-25-3685 | 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 |
| Policy Knowledge Base VA · VA-25-6903 | 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 |
| Secure Access Service Edge (SASE) VA · VA-25-6479 | 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- VA designated 3 use cases high-impact but answered none of the minimum-practice questions for any of them. Were the practices assessed, and where is that recorded?
- 1 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?
- 1 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.