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

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

Pre-deployment testing

Pre-deployment testing
Reported in place: 55 (51.4%)Pre-deployment testing
Reported in progress: 48 (44.9%)Pre-deployment testing
Reported not in place: 1 (0.9%)Pre-deployment testing
No answer reported: 3 (2.8%)

107

AI impact assessment

AI impact assessment
Reported in place: 34 (31.8%)AI impact assessment
Reported in progress: 45 (42.1%)AI impact assessment
Reported not in place: 1 (0.9%)AI impact assessment
No answer reported: 27 (25.2%)

107

Independent review

Independent review
Reported in place: 40 (37.4%)Independent review
Reported in progress: 42 (39.3%)Independent review
Reported not in place: 2 (1.9%)Independent review
Waived by CAIO: 1 (0.9%)Independent review
No answer reported: 22 (20.6%)

107

Ongoing monitoring

Ongoing monitoring
Reported in place: 44 (41.1%)Ongoing monitoring
Reported in progress: 43 (40.2%)Ongoing monitoring
Other or ambiguous answer: 1 (0.9%)Ongoing monitoring
No answer reported: 19 (17.8%)

107

Operator training

Operator training
Reported in place: 61 (57.0%)Operator training
Reported in progress: 41 (38.3%)Operator training
No answer reported: 5 (4.7%)

107

Fail-safe

Fail-safe
Reported in place: 37 (34.6%)Fail-safe
Reported in progress: 1 (0.9%)Fail-safe
Not applicable: 65 (60.7%)Fail-safe
No answer reported: 4 (3.7%)

107

Appeal process

Appeal process
Reported in place: 8 (7.5%)Appeal process
Reported in progress: 2 (1.9%)Appeal process
Not applicable: 87 (81.3%)Appeal process
Precluded by law or guidance: 2 (1.9%)Appeal process
No answer reported: 8 (7.5%)

107

User and public consultation

User and public consultation
Reported in place: 107 (100.0%)

107

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	107	55	48	1	0	0	0	3	97%	51% of 107
AI impact assessment	107	34	45	1	0	0	0	27	75%	32% of 107
Independent review	107	40	42	2	0	1	0	22	79%	38% of 106
Ongoing monitoring	107	44	43	0	0	0	1	19	82%	41% of 107
Operator training	107	61	41	0	0	0	0	5	95%	57% of 107
Fail-safe	107	37	1	0	65	0	0	4	96%	88% of 42
Appeal process	107	8	2	0	87	2	0	8	93%	44% of 18
User and public consultation	107	107	0	0	0	0	0	0	100%	100% of 107

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
DOE	27%	3%	14%	17%	39%	100%	0%	100%	64
DHS	100%	89%	89%	94%	100%	100%	100%	100%	18
SBA	100%	100%	100%	100%	100%	100%	100%	100%	11
EAC	25%	–	0%	–	–	–	–	100%	4
SSA	67%	67%	67%	33%	67%	100%	0%	100%	3
FERC	100%	100%	100%	100%	100%	100%	0%	100%	2
TREAS	50%	50%	0%	0%	50%	50%	0%	100%	2
STATE	100%	0%	0%	100%	100%	100%	100%	100%	2
EPA	100%	0%	–	0%	0%	100%	–	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

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

Use case	Stage	Test	AIA	Review	Monitor	Train	Fail-safe	Appeal	Consult
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
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
ServiceNow Predictive Intelligence DOE · DOE-430	Deployed	Reported in place	Reported in progress	Reported in place	Reported in place	Reported in place	Not applicable	Not applicable	Reported in place
Hanford Ai Liaison (HAL) 1.1 DOE · DOE-469	Deployed	Reported in place	No answer reported	Reported in place	Reported in place	Reported in place	Not applicable	Not applicable	Reported in place
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
LANL AI Portal DOE · DOE-495	Deployed	Reported in place	Reported in progress	Reported in place	Reported in place	Reported in place	Not applicable	Not applicable	Reported in place
ChatGPT Enterprise DOE · DOE-498	Deployed	Reported in place	Reported in progress	Reported in place	Reported in place	Reported in place	Not applicable	Not applicable	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
Microsoft Bing Service DOE · DOE-510	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Visual Studio Enterprise DOE · DOE-519	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft OneNote DOE · DOE-525	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Azure Authoring Tools DOE · DOE-536	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Apple Intelligence DOE · DOE-549	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft ScreenSketch DOE · DOE-551	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Visual C++ Additional Runtime DOE · DOE-552	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Project DOE · DOE-556	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Google Chrome Generative AI DOE · DOE-561	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
GitHub Co-Pilot DOE · DOE-571	Deployed	Reported in place	No answer reported	Reported in place	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Copilot DOE · DOE-577	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	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
Microsoft Visual C++ Redistributable DOE · DOE-596	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Teams DOE · DOE-599	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Search in Bing DOE · DOE-602	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Teams Classic DOE · DOE-608	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft MSPaint DOE · DOE-623	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Visual Studio Community DOE · DOE-631	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Invoice Scanning System DOE · DOE-632	Deployed	Reported in place	No answer reported	Reported in place	Reported in place	Reported in place	Not applicable	Not applicable	Reported in place
Microsoft OneDrive DOE · DOE-634	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	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
Microsoft 365 DOE · DOE-651	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	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
Microsoft Visual C++ Minimum Runtime DOE · DOE-667	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft OneDrive MUI DOE · DOE-669	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	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
Microsoft 365 Apps for Enterprise DOE · DOE-685	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Outlook MUI DOE · DOE-691	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Edge DOE · DOE-698	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
SQL Server Management Studio DOE · DOE-710	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Exchange Server DOE · DOE-711	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Skype App DOE · DOE-721	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft OneNote MUI DOE · DOE-735	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft PowerPoint MUI DOE · DOE-744	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Power BI Desktop DOE · DOE-748	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Azure PowerShell DOE · DOE-749	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Grants Lifecycle Application System EAC · EAC-3	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	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
Ariculate 360 AI Assistant DOE · DOE-511	Pre-deployment	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Co-Pilot DOE · DOE-518	Pilot	Reported in place	No answer reported	Reported in place	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Ask CAS DOE · DOE-522	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
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
Poseidon DOE · DOE-544	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	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
Ask Alan DOE · DOE-569	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
DIRECTIVES DOE · DOE-587	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
FindMATID DOE · DOE-604	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
Ask IT DOE · DOE-615	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
ChatSRS DOE · DOE-638	Pre-deployment	Reported in place	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
UNSPSC Codes DOE · DOE-642	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
Hanford Ai Liaison (HAL) 2.0 DOE · DOE-653	Pre-deployment	Reported in place	No answer reported	Reported in place	Reported in place	Reported in place	Not applicable	Not applicable	Reported in place
Sindri DOE · DOE-695	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
Ask HR DOE · DOE-704	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
mass3 DOE · DOE-707	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
Crickets DOE · DOE-723	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
Neptune DOE · DOE-724	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
AccessAI DOE · DOE-725	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
AI Answers in Clearinghouse Network EAC · EAC-1	Pilot	Reported in place	No answer reported	Reported not in place	No answer reported	No answer reported	No answer reported	No answer reported	Reported in place
Internal Generative AI Tools for Staff Productivity EAC · EAC-2	Pilot	Reported not in place	No answer reported	Reported not in place	No answer reported	No answer reported	No answer reported	No answer reported	Reported in place
Routing emails from shared inboxes EAC · EAC-4	Pilot	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	Reported in place
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
GenAI Procurement Tool TREAS · TREASURY-OCIO-003	Pre-deployment	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	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?
14 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?
48 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.