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 progressReported not in placeNot applicableOther or ambiguous answerNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 2 (4.2%)Pre-deployment testing
Reported in progress: 2 (4.2%)Pre-deployment testing
No answer reported: 44 (91.7%)
48Reported in place: 2 (4.2%)Pre-deployment testing
Reported in progress: 2 (4.2%)Pre-deployment testing
No answer reported: 44 (91.7%)
AI impact assessment
AI impact assessment
Reported in place: 1 (2.1%)AI impact assessment
Reported in progress: 2 (4.2%)AI impact assessment
Reported not in place: 1 (2.1%)AI impact assessment
No answer reported: 44 (91.7%)
48Reported in place: 1 (2.1%)AI impact assessment
Reported in progress: 2 (4.2%)AI impact assessment
Reported not in place: 1 (2.1%)AI impact assessment
No answer reported: 44 (91.7%)
Independent review
Independent review
Reported in place: 1 (2.1%)Independent review
Reported in progress: 2 (4.2%)Independent review
No answer reported: 45 (93.8%)
48Reported in place: 1 (2.1%)Independent review
Reported in progress: 2 (4.2%)Independent review
No answer reported: 45 (93.8%)
Ongoing monitoring
Ongoing monitoring
Reported in place: 1 (2.1%)Ongoing monitoring
Reported in progress: 2 (4.2%)Ongoing monitoring
Other or ambiguous answer: 1 (2.1%)Ongoing monitoring
No answer reported: 44 (91.7%)
48Reported in place: 1 (2.1%)Ongoing monitoring
Reported in progress: 2 (4.2%)Ongoing monitoring
Other or ambiguous answer: 1 (2.1%)Ongoing monitoring
No answer reported: 44 (91.7%)
Operator training
Operator training
Reported in progress: 3 (6.3%)Operator training
Other or ambiguous answer: 1 (2.1%)Operator training
No answer reported: 44 (91.7%)
48Reported in progress: 3 (6.3%)Operator training
Other or ambiguous answer: 1 (2.1%)Operator training
No answer reported: 44 (91.7%)
Fail-safe
Fail-safe
Reported in place: 1 (2.1%)Fail-safe
Reported in progress: 2 (4.2%)Fail-safe
Not applicable: 1 (2.1%)Fail-safe
No answer reported: 44 (91.7%)
48Reported in place: 1 (2.1%)Fail-safe
Reported in progress: 2 (4.2%)Fail-safe
Not applicable: 1 (2.1%)Fail-safe
No answer reported: 44 (91.7%)
| 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 | 48 | 2 | 2 | 0 | 0 | 0 | 0 | 44 | 8% | 4% of 48 |
| AI impact assessment | 48 | 1 | 2 | 1 | 0 | 0 | 0 | 44 | 8% | 2% of 48 |
| Independent review | 48 | 1 | 2 | 0 | 0 | 0 | 0 | 45 | 6% | 2% of 48 |
| Ongoing monitoring | 48 | 1 | 2 | 0 | 0 | 0 | 1 | 44 | 8% | 2% of 48 |
| Operator training | 48 | 0 | 3 | 0 | 0 | 0 | 1 | 44 | 8% | 0% of 48 |
| Fail-safe | 48 | 1 | 2 | 0 | 1 | 0 | 0 | 44 | 8% | 2% of 47 |
| Appeal process | 48 | 1 | 2 | 0 | 0 | 0 | 0 | 45 | 6% | 2% of 48 |
| User and public consultation | 48 | 1 | 2 | 0 | 0 | 0 | 1 | 44 | 8% | 2% 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 | |
|---|---|---|---|---|---|---|---|---|---|
| DOJ | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 10 |
| DOI | – | – | – | – | – | – | – | – | 9 |
| HHS | – | – | – | – | – | – | – | – | 4 |
| VA | – | – | – | – | – | – | – | – | 4 |
| STATE | – | – | – | – | – | – | – | – | 3 |
| SEC | – | – | – | – | – | – | – | – | 2 |
| DOL | 50% | 50% | 50% | 50% | 0% | 0% | 50% | 0% | 2 |
| DHS | – | – | – | – | – | – | – | – | 2 |
| EPA | 50% | 0% | – | 0% | 0% | 50% | – | 50% | 2 |
| NARA | – | – | – | – | – | – | – | – | 2 |
| DOE | – | – | – | – | – | – | – | – | 2 |
| NTSB | – | – | – | – | – | – | – | – | 1 |
| FRB | – | – | – | – | – | – | – | – | 1 |
| DOT | – | – | – | – | – | – | – | – | 1 |
| TREAS | – | – | – | – | – | – | – | – | 1 |
| PBGC | – | – | – | – | – | – | – | – | 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
47 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| AI-Assisted Audio/Video Redaction DHS · DHS-2511 | 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 |
| OpenText for Records Management (File share auto-classification) DOE · DOE-665 | 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 eDiscovery Attorney-Client Privilege Detection DOI · DOI-0021 | 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 |
| FOIA Request Lexical Similarity Tool in the Document Review Platform (Term Frequency – Inverse Document Frequency (TF-IDF) - Cosine) DOI · DOI-0020 | 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 |
| Enabling FOIA Request Clustering Capability in the Document Review Platform (Density Based Algorithm alongside Term Frequency – Inverse Document Frequency (TF-IDF)) DOI · DOI-0019 | 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 |
| FOIA Request Clustering Tool (Embedding based clustering alongside Term Frequency – Inverse Document Frequency (TF-IDF)) DOI · DOI-0018 | 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 |
| FOIA Request Conceptual Similarity Tool (Semantic Similarity Score Generation) DOI · DOI-0017 | 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 |
| Performance Modeling / Performance Forecasting DOI · DOI-0016 | 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 |
| Axon Evidence.com DOJ · DOJ-0015 | 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 |
| Federal Docket Management System DOJ · DOJ-0016 | 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 |
| Veritone Redact DOJ · DOJ-0033 | 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 |
| reCAPTCHA DOJ · DOJ-0162 | 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 |
| Axon DOJ · DOJ-0199 | 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 |
| Axon Video Retention Solution (VRS) - object recognition and redaction DOJ · DOJ-0225 | 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 |
| FOIA Production Tools DOJ · DOJ-0295 | 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 |
| Agency Records Management System EPA · 73 | Deployed | Reported in place | Reported not in place | No answer reported | Other or ambiguous answer | Reported in progress | Reported in place | No answer reported | Reported in place |
| Proposals and Public Comments FRB · FRB-0013 | 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 |
| CRC Call Summarization FTC · FTC-0011 | 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 |
| FOIA REDACTION (FRED) TOOL HHS · R0851 | 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 |
| PRF Program Chatbot HHS · R0887 | 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 |
| Extracting data from FOIA request forms SEC · SEC-40 | 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 |
| FA.gov RedactAid STATE · R3241 | 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 |
| Concept Clustering VA · VA-25-3275 | 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 |
| Privacy Act Automation VA · VA-24-2545 | 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 |
| Axon Body Camera and DMS - OSSO VA · VA-24-200 | 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 |
| FOIA processing automated redaction (RedactAI) DHS · DHS-2567 | 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 |
| OpenText for Records Management (Email Auto-Classification) DOE · DOE-548 | 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 |
| FOIA Record Pre-Review Tool DOI · DOI-0025 | 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 |
| Document Review Platform Generative AI DOI · DOI-0024 | 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 |
| BIA-GEO Assist DOI · DOI-0005 | 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 |
| Evidence.com DOJ · DOJ-0058 | 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 |
| Redaction Tool 2 DOJ · DOJ-0262 | 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 |
| Redaction Tool 1 DOJ · DOJ-0263 | 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 |
| Electronic Records Management DOL · DOL-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 Freedom of Information Act (FOIA) Request Classification DOT · DOT-1000073 | 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 |
| RelativityOne Gov aiR EPA · 56 | 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 |
| Detecting, evaluating, and redacting PII in NAMCS HC Component HHS · R0685 | 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 |
| FOIA Exemption-Aligned Redaction HHS · R0892 | 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 Pilot Project to Screen and Flag for Personally Identifiable Information (PII) in Digitized Archival Records NARA · NARA - 0005 | 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 |
| Freedom of Information Act (FOIA) Discovery AI Pilot NARA · NARA - 0011 | 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 |
| FOIAXpress AI assistant NTSB · NTSB-0004 | 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 |
| AI-Assisted Recognition and Redaction for Legal/Litigation Matters PBGC · PBGC - 06 | 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 |
| Create description of documents for records management in sharepoint SEC · SEC-43 | 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 |
| FOIA Web ML Document Indexer STATE · R3212 | 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 |
| FOIA 360 AI Matching Tool STATE · R3228 | 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 |
| 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 |
| ASKA: Automated Support and Knowledge Assistance VA · VA-25-3670 | 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 |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- 2 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?
- 3 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
- 3 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.