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

Reported in placeReported in progressReported not in placeNot applicablePrecluded by law or guidanceOther or ambiguous answerNo answer reported

Pre-deployment testing

Pre-deployment testing
Reported in place: 58 (80.6%)Pre-deployment testing
Reported in progress: 13 (18.1%)Pre-deployment testing
No answer reported: 1 (1.4%)

AI impact assessment

AI impact assessment
Reported in place: 47 (65.3%)AI impact assessment
Reported in progress: 20 (27.8%)AI impact assessment
Reported not in place: 1 (1.4%)AI impact assessment
No answer reported: 4 (5.6%)

Independent review

Independent review
Reported in place: 47 (65.3%)Independent review
Reported in progress: 19 (26.4%)Independent review
No answer reported: 6 (8.3%)

Ongoing monitoring

Ongoing monitoring
Reported in place: 52 (72.2%)Ongoing monitoring
Reported in progress: 18 (25.0%)Ongoing monitoring
Other or ambiguous answer: 1 (1.4%)Ongoing monitoring
No answer reported: 1 (1.4%)

Operator training

Operator training
Reported in place: 55 (76.4%)Operator training
Reported in progress: 16 (22.2%)Operator training
No answer reported: 1 (1.4%)

Fail-safe

Fail-safe
Reported in place: 72 (100.0%)

Appeal process

Appeal process
Reported in place: 20 (27.8%)Appeal process
Reported in progress: 1 (1.4%)Appeal process
Not applicable: 44 (61.1%)Appeal process
Precluded by law or guidance: 3 (4.2%)Appeal process
No answer reported: 4 (5.6%)

User and public consultation

User and public consultation
Reported in place: 37 (51.4%)User and public consultation
Reported in progress: 8 (11.1%)User and public consultation
Other or ambiguous answer: 27 (37.5%)

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	72	58	13	0	0	0	0	1	99%	81% of 72
AI impact assessment	72	47	20	1	0	0	0	4	94%	65% of 72
Independent review	72	47	19	0	0	0	0	6	92%	65% of 72
Ongoing monitoring	72	52	18	0	0	0	1	1	99%	72% of 72
Operator training	72	55	16	0	0	0	0	1	99%	76% of 72
Fail-safe	72	72	0	0	0	0	0	0	100%	100% of 72
Appeal process	72	20	1	0	44	3	0	4	94%	80% of 25
User and public consultation	72	37	8	0	0	0	27	0	100%	51% of 72

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
DHS	96%	88%	88%	96%	92%	100%	100%	67%	24
DOE	71%	48%	52%	57%	67%	100%	70%	48%	21
SBA	50%	50%	50%	50%	50%	100%	100%	17%	12
SSA	88%	88%	88%	75%	88%	100%	100%	38%	8
FERC	100%	100%	100%	100%	100%	100%	0%	100%	2
STATE	100%	0%	0%	100%	100%	100%	100%	100%	2
USDA	100%	0%	0%	100%	100%	100%	100%	0%	1
EPA	100%	0%	–	0%	0%	100%	–	100%	1
TREAS	100%	100%	0%	0%	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

30 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-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
Verification Match Model DHS · DHS-2384	Deployed	Reported in place	Reported in progress	Reported in progress	Reported in place	Reported in progress	Reported in place	Reported in place	Reported in progress
AI for Operations Center DOE · DOE-10	Deployed	Reported in place	No answer reported	No answer reported	Reported in place	Reported in place	Reported in place	No answer reported	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
OPQ-AI DOE · DOE-477	Deployed	Reported in place	No answer reported	No answer reported	Reported in place	Reported in place	Reported in place	No answer reported	Reported in place
Argo DOE · DOE-499	Deployed	Reported in place	No answer reported	No answer reported	Reported in progress	Reported in place	Reported in place	Not applicable	Reported in place
GitHub Copilot DOE · DOE-586	Deployed	Reported in place	Reported in place	Reported in place	Reported in place	Reported in progress	Reported in place	Not applicable	Reported in place
Georeference Figures DOE · DOE-645	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in place	Not applicable	Reported in place
pComply-AI-High Risk DOE · DOE-658	Deployed	Reported in place	No answer reported	No answer reported	Reported in place	Reported in place	Reported in place	No answer reported	Reported in place
Groundwater Modeling DOE · DOE-659	Deployed	Reported in place	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in place	Not applicable	Reported in place
Scripting DOE · DOE-674	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in place	Not applicable	Reported in place
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
Digital Identity Verification Services SSA · R3122	Deployed	No answer reported	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Precluded by law or guidance	Reported in place
AI-Augmented Declassification Review STATE · R3213	Deployed	Reported in place	Reported in progress	Reported in progress	Reported in place	Reported in place	Reported in place	Reported in place	Reported in place
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
GenAI Productivity Tool TREAS · TREASURY-OCIO-001	Deployed	Reported in place	Reported in place	Reported in progress	Reported in progress	Reported in place	Reported in place	Reported in progress	Reported in place
Video Surveillance System USDA · USDA-025	Deployed	Reported in place	Reported in progress	Reported in progress	Reported in place	Reported in place	Reported in place	Reported in place	Other or ambiguous answer
FLIR 280 HD DHS · DHS-2745	Pilot	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in place	Not applicable	Other or ambiguous answer
Drone Imagery Analysis DOE · DOE-539	Pilot	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in place	Not applicable	Reported in place
Soil Moisture Modeling DOE · DOE-545	Pilot	Reported in place	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in place	Not applicable	Reported in place
M365 Copilot DOE · DOE-574	Pilot	Reported in place	Reported in progress	Reported in progress	Reported in place	Reported in place	Reported in place	Not applicable	Other or ambiguous answer
Microsoft Copilot (Pilot) DOE · DOE-603	Pilot	Reported in progress	Reported in progress	Reported in place	Reported in progress	Reported in progress	Reported in place	Not applicable	Reported in progress
AI Incident Summarization SBA · SBA-35	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
AI Resolution Notes Generation SBA · SBA-36	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
AI Vulnerability Ticket Deduplication SBA · SBA-37	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
AI Vulnerability Remediation Assistance SBA · SBA-38	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
Multi-Agent Orchestration SBA · SBA-40	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
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
Policy Assistance Tool (PAT) SSA · R3116	Pilot	Reported in place	Reported in place	Reported in place	Reported in progress	Reported in place	Reported in place	Not applicable	Reported in place

Unanswered analytical questions

Generated from the data; for follow-up with agencies

6 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?
23 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
9 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
13 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.