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: 11 records · use cases that answered at least one practice questionReported in placeReported in progressNot applicableOther or ambiguous answerNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 2 (18.2%)Pre-deployment testing
Reported in progress: 8 (72.7%)Pre-deployment testing
No answer reported: 1 (9.1%)
11Reported in place: 2 (18.2%)Pre-deployment testing
Reported in progress: 8 (72.7%)Pre-deployment testing
No answer reported: 1 (9.1%)
AI impact assessment
AI impact assessment
Reported in place: 2 (18.2%)AI impact assessment
Reported in progress: 8 (72.7%)AI impact assessment
No answer reported: 1 (9.1%)
11Reported in place: 2 (18.2%)AI impact assessment
Reported in progress: 8 (72.7%)AI impact assessment
No answer reported: 1 (9.1%)
Independent review11
Ongoing monitoring11
Operator training
Operator training
Reported in place: 3 (27.3%)Operator training
Reported in progress: 6 (54.5%)Operator training
Other or ambiguous answer: 2 (18.2%)
11Reported in place: 3 (27.3%)Operator training
Reported in progress: 6 (54.5%)Operator training
Other or ambiguous answer: 2 (18.2%)
Fail-safe
Fail-safe
Reported in place: 1 (9.1%)Fail-safe
Reported in progress: 8 (72.7%)Fail-safe
Not applicable: 2 (18.2%)
11Reported in place: 1 (9.1%)Fail-safe
Reported in progress: 8 (72.7%)Fail-safe
Not applicable: 2 (18.2%)
Appeal process11
| 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 | 11 | 2 | 8 | 0 | 0 | 0 | 0 | 1 | 91% | 18% of 11 |
| AI impact assessment | 11 | 2 | 8 | 0 | 0 | 0 | 0 | 1 | 91% | 18% of 11 |
| Independent review | 11 | 3 | 8 | 0 | 0 | 0 | 0 | 0 | 100% | 27% of 11 |
| Ongoing monitoring | 11 | 3 | 8 | 0 | 0 | 0 | 0 | 0 | 100% | 27% of 11 |
| Operator training | 11 | 3 | 6 | 0 | 0 | 0 | 2 | 0 | 100% | 27% of 11 |
| Fail-safe | 11 | 1 | 8 | 0 | 2 | 0 | 0 | 0 | 100% | 11% of 9 |
| Appeal process | 11 | 0 | 9 | 0 | 2 | 0 | 0 | 0 | 100% | 0% of 9 |
| User and public consultation | 11 | 1 | 8 | 0 | 0 | 0 | 1 | 1 | 91% | 9% of 11 |
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 | |
|---|---|---|---|---|---|---|---|---|---|
| DOJ | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 6 |
| DHS | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 2 |
| SBA | 100% | 100% | 100% | 100% | 100% | 100% | 0% | 50% | 2 |
| DOI | – | – | 100% | 100% | 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
9 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-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 |
| License Plate Capture and Analysis DHS · DHS-2666 | 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 |
| Unmanned Aerial Systems (UAS) DOJ · DOJ-0003 | 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 |
| Thomson Reuters CLEAR - License Plate Recognition DOJ · DOJ-0048 | 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 |
| Language Translation, Optical Character Recognition (OCR), Object Detection, Language Detection, Alert Noise Reduction DOJ · DOJ-0138 | 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 |
| Nlets Nationwide License Plate Reader Pointer Index DOJ · DOJ-0198 | 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 |
| 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 |
| ATLAS DOI · DOI-0077 | Pre-deployment | No answer reported | No answer reported | Reported in place | Reported in place | Reported in place | Not applicable | Reported in progress | No answer reported |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- VA designated 8 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?
- 8 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?
- 9 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.