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: 24 records · use cases designated high-impactReported in placeReported in progressNot applicablePrecluded by law or guidanceOther or ambiguous answer
Pre-deployment testing
Pre-deployment testing
Reported in place: 21 (87.5%)Pre-deployment testing
Reported in progress: 3 (12.5%)
24Reported in place: 21 (87.5%)Pre-deployment testing
Reported in progress: 3 (12.5%)
AI impact assessment
AI impact assessment
Reported in place: 19 (79.2%)AI impact assessment
Reported in progress: 5 (20.8%)
24Reported in place: 19 (79.2%)AI impact assessment
Reported in progress: 5 (20.8%)
Independent review24
Ongoing monitoring24
Operator training
Operator training
Reported in place: 19 (79.2%)Operator training
Reported in progress: 4 (16.7%)Operator training
Other or ambiguous answer: 1 (4.2%)
24Reported in place: 19 (79.2%)Operator training
Reported in progress: 4 (16.7%)Operator training
Other or ambiguous answer: 1 (4.2%)
Fail-safe
Fail-safe
Reported in place: 15 (62.5%)Fail-safe
Reported in progress: 3 (12.5%)Fail-safe
Not applicable: 6 (25.0%)
24Reported in place: 15 (62.5%)Fail-safe
Reported in progress: 3 (12.5%)Fail-safe
Not applicable: 6 (25.0%)
| 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 | 24 | 21 | 3 | 0 | 0 | 0 | 0 | 0 | 100% | 88% of 24 |
| AI impact assessment | 24 | 19 | 5 | 0 | 0 | 0 | 0 | 0 | 100% | 79% of 24 |
| Independent review | 24 | 19 | 5 | 0 | 0 | 0 | 0 | 0 | 100% | 79% of 24 |
| Ongoing monitoring | 24 | 18 | 6 | 0 | 0 | 0 | 0 | 0 | 100% | 75% of 24 |
| Operator training | 24 | 19 | 4 | 0 | 0 | 0 | 1 | 0 | 100% | 79% of 24 |
| Fail-safe | 24 | 15 | 3 | 0 | 6 | 0 | 0 | 0 | 100% | 83% of 18 |
| Appeal process | 24 | 7 | 0 | 0 | 15 | 2 | 0 | 0 | 100% | 100% of 7 |
| User and public consultation | 24 | 0 | 0 | 0 | 0 | 0 | 24 | 0 | 100% | 0% of 24 |
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 | 93% | 71% | 71% | 71% | 71% | 70% | 100% | 0% | 14 |
| SSA | 100% | 100% | 100% | 100% | 100% | 100% | 100% | 0% | 6 |
| DOE | 0% | 100% | 100% | 0% | 100% | 100% | 0% | 0% | 2 |
| DOL | 100% | 100% | 100% | 100% | 0% | 0% | 100% | 0% | 1 |
| USDA | 100% | 0% | 0% | 100% | 100% | 100% | 100% | 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
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 |
|---|---|---|---|---|---|---|---|---|---|
| Babel DHS · DHS-185 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in place | Other or ambiguous answer |
| 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 |
| Traffic Jam DHS · DHS-2570 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in place | Other or ambiguous answer |
| 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 |
| 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 |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- 4 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?
- 15 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
- 11 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
- 8 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.