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: 28 records · use cases designated high-impactReported in place: 26 (92.9%)Pre-deployment testing
Reported in progress: 2 (7.1%)
Reported in place: 23 (82.1%)AI impact assessment
Reported in progress: 5 (17.9%)
| 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 | 28 | 26 | 2 | 0 | 0 | 0 | 0 | 0 | 100% | 93% of 28 |
| AI impact assessment | 28 | 23 | 5 | 0 | 0 | 0 | 0 | 0 | 100% | 82% of 28 |
| Independent review | 28 | 23 | 5 | 0 | 0 | 0 | 0 | 0 | 100% | 82% of 28 |
| Ongoing monitoring | 28 | 24 | 4 | 0 | 0 | 0 | 0 | 0 | 100% | 86% of 28 |
| Operator training | 28 | 27 | 1 | 0 | 0 | 0 | 0 | 0 | 100% | 96% of 28 |
| Fail-safe | 28 | 21 | 1 | 0 | 6 | 0 | 0 | 0 | 100% | 95% of 22 |
| Appeal process | 28 | 0 | 0 | 0 | 28 | 0 | 0 | 0 | 100% | n/a of 0 |
| User and public consultation | 28 | 13 | 1 | 0 | 0 | 0 | 14 | 0 | 100% | 46% of 28 |
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 | 100% | 85% | 85% | 90% | 95% | 93% | 0% | 55% | 20 |
| SSA | 100% | 100% | 100% | 100% | 100% | 100% | 0% | 25% | 4 |
| DOE | 0% | 100% | 100% | 0% | 100% | 100% | 0% | 0% | 2 |
| EPA | 100% | 0% | 0% | 100% | 100% | 0% | 0% | 0% | 1 |
| STATE | 100% | 0% | 0% | 100% | 100% | 100% | 0% | 100% | 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
7 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| Passive Body Scanner DHS · DHS-2380 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Not applicable | Other or ambiguous answer |
| CBP Translate DHS · DHS-2388 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in progress | Reported in place | Not applicable | Not applicable | Reported in place |
| Mobile Fortify DHS · DHS-2731 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in place | Reported in place | Reported in place | Not applicable | Reported in place |
| 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 |
| RCRA PA EPA · 78 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in place | Reported in place | Not applicable | Not applicable | Reported in progress |
| Electronic Health Record AI Enhancements STATE · R3248 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in place | Reported in place | Reported in place | Not applicable | Reported in place |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- 5 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?
- 28 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
- 7 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
- 31 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.