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.

Governance report

Practice-by-practice evidence

Denominator: 10 records · use cases that answered at least one practice question

Reported in placeReported in progressNot applicableOther or ambiguous answerNo answer reported

Pre-deployment testing

Pre-deployment testing
Reported in place: 4 (40.0%)Pre-deployment testing
Reported in progress: 4 (40.0%)Pre-deployment testing
No answer reported: 2 (20.0%)

AI impact assessment

AI impact assessment
Reported in place: 4 (40.0%)AI impact assessment
Reported in progress: 4 (40.0%)AI impact assessment
No answer reported: 2 (20.0%)

Independent review

Independent review
Reported in place: 6 (60.0%)Independent review
Reported in progress: 2 (20.0%)Independent review
No answer reported: 2 (20.0%)

Ongoing monitoring

Ongoing monitoring
Reported in place: 6 (60.0%)Ongoing monitoring
Reported in progress: 2 (20.0%)Ongoing monitoring
No answer reported: 2 (20.0%)

Operator training

Operator training
Reported in place: 6 (60.0%)Operator training
Reported in progress: 2 (20.0%)Operator training
No answer reported: 2 (20.0%)

Fail-safe

Fail-safe
Reported in place: 3 (30.0%)Fail-safe
Reported in progress: 1 (10.0%)Fail-safe
Not applicable: 6 (60.0%)

Appeal process

Appeal process
Reported in place: 1 (10.0%)Appeal process
Reported in progress: 3 (30.0%)Appeal process
Not applicable: 6 (60.0%)

User and public consultation

User and public consultation
Reported in place: 2 (20.0%)User and public consultation
Reported in progress: 3 (30.0%)User and public consultation
Other or ambiguous answer: 4 (40.0%)User and public consultation
No answer reported: 1 (10.0%)

Practice	In scope	In place	In progress	N/A	Other	No answer	Answered	In place of applicable
Pre-deployment testing	10	4	4	0	0	2	80%	40% of 10
AI impact assessment	10	4	4	0	0	2	80%	40% of 10
Independent review	10	6	2	0	0	2	80%	60% of 10
Ongoing monitoring	10	6	2	0	0	2	80%	60% of 10
Operator training	10	6	2	0	0	2	80%	60% of 10
Fail-safe	10	3	1	6	0	0	100%	75% of 4
Appeal process	10	1	3	6	0	0	100%	25% of 4
User and public consultation	10	2	3	0	4	1	90%	20% of 10

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.

Agency-by-safeguard heatmap

Cell: share reported in place, among applicable recordsIn place Answered

Agency by governance practice
	Testing	Impact assess.	Indep. review	Monitoring	Training	Fail-safe	Appeal	Consultation	n
SBA	75%	75%	75%	75%	75%	100%	100%	50%	4
DOI	–	–	100%	100%	100%	0%	0%	0%	2
DOE	0%	0%	–	–	–	0%	0%	0%	2
DOJ	0%	0%	0%	0%	0%	0%	0%	0%	1
DHS	100%	100%	100%	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

6 records with at least one practice unanswered or in progressOpen in explorer

Use case	Stage	Test	AIA	Review	Monitor	Train	Fail-safe	Appeal	Consult
Insider Threat Management and User Activity Monitoring DOJ · DOJ-0119	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
Bernie-AI: Infrastructure Planning Support POC DOE · DOE-514	Pilot	Reported in progress	Reported in progress	No answer reported	No answer reported	No answer reported	Not applicable	Not applicable	Other or ambiguous answer
NIF Shot Analytics & Predictive Maintenance Support Pilot DOE · DOE-529	Pilot	Reported in progress	Reported in progress	No answer reported	No answer reported	No answer reported	Not applicable	Not applicable	Other or ambiguous answer
Tsunami Hazard Analysis [2024 INV#WO0000000108470] DOI · DOI-0165	Pre-deployment	No answer reported	No answer reported	Reported in place	Reported in place	Reported in place	Not applicable	Reported in progress	Reported in progress
Invasive Carp Harvest Predictive Model DOI · DOI-0061	Pilot	No answer reported	No answer reported	Reported in place	Reported in place	Reported in place	Not applicable	Reported in progress	No answer reported
Business Development SBA · SBA-2	Pre-deployment	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in progress

Unanswered analytical questions

Generated from the data; for follow-up with agencies

VA designated 5 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 mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
1 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.