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: 15 records · all use cases in the current filterReported in progressNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in progress: 3 (20.0%)Pre-deployment testing
No answer reported: 12 (80.0%)
15Reported in progress: 3 (20.0%)Pre-deployment testing
No answer reported: 12 (80.0%)
AI impact assessment
AI impact assessment
Reported in progress: 3 (20.0%)AI impact assessment
No answer reported: 12 (80.0%)
15Reported in progress: 3 (20.0%)AI impact assessment
No answer reported: 12 (80.0%)
Independent review15
Ongoing monitoring15
Operator training15
Appeal process15
User and public consultation
User and public consultation
Reported in progress: 3 (20.0%)User and public consultation
No answer reported: 12 (80.0%)
15Reported in progress: 3 (20.0%)User and public consultation
No answer reported: 12 (80.0%)
| 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 | 15 | 0 | 3 | 0 | 0 | 0 | 0 | 12 | 20% | 0% of 15 |
| AI impact assessment | 15 | 0 | 3 | 0 | 0 | 0 | 0 | 12 | 20% | 0% of 15 |
| Independent review | 15 | 0 | 3 | 0 | 0 | 0 | 0 | 12 | 20% | 0% of 15 |
| Ongoing monitoring | 15 | 0 | 3 | 0 | 0 | 0 | 0 | 12 | 20% | 0% of 15 |
| Operator training | 15 | 0 | 3 | 0 | 0 | 0 | 0 | 12 | 20% | 0% of 15 |
| Fail-safe | 15 | 0 | 3 | 0 | 0 | 0 | 0 | 12 | 20% | 0% of 15 |
| Appeal process | 15 | 0 | 3 | 0 | 0 | 0 | 0 | 12 | 20% | 0% of 15 |
| User and public consultation | 15 | 0 | 3 | 0 | 0 | 0 | 0 | 12 | 20% | 0% of 15 |
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 | |
|---|---|---|---|---|---|---|---|---|---|
| DOJ | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 8 |
| SEC | – | – | – | – | – | – | – | – | 3 |
| FHFA | – | – | – | – | – | – | – | – | 1 |
| HHS | – | – | – | – | – | – | – | – | 1 |
| FERC | – | – | – | – | – | – | – | – | 1 |
| OSHRC | – | – | – | – | – | – | – | – | 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
15 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| Thomson Reuters CLEAR DOJ · DOJ-0031 | Deployed | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Thomson Reuters CLEAR - License Plate Recognition DOJ · DOJ-0048 | 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 |
| Westlaw (AI assisted legal research) DOJ · DOJ-0109 | Deployed | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Nlets Nationwide License Plate Reader Pointer Index DOJ · DOJ-0198 | 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 |
| Westlaw (People Search) DOJ · DOJ-0217 | 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 |
| Thomson Reuters CLEAR DOJ · DOJ-0239 | Deployed | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| ProLaw DOJ · DOJ-0266 | Deployed | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| WestLaw FHFA · FHFA-4 | Deployed | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Westlaw Edge OSHRC · OSHRC-0001 | Deployed | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Utilize Westlaw Quick Check to cross check SEC documents. SEC · SEC-35 | Deployed | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Legal Research (Westlaw Precision) SEC · SEC-63 | Deployed | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Cocounsel AI DOJ · DOJ-0313 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| AI Enabled Assistant Legal Research FERC · FERC-0006 | Pre-deployment | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| CoPilot Outlook HHS · R1038 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Westlaw Co-Counsel SEC · SEC-44 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- 3 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?
- 4 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
These are questions the inventory raises but cannot answer. They are not findings of non-compliance.