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: 301 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: 94 (31.2%)Pre-deployment testing
Reported in progress: 163 (54.2%)Pre-deployment testing
Reported not in place: 1 (0.3%)Pre-deployment testing
No answer reported: 43 (14.3%)

301

AI impact assessment

AI impact assessment
Reported in place: 69 (22.9%)AI impact assessment
Reported in progress: 166 (55.1%)AI impact assessment
Reported not in place: 1 (0.3%)AI impact assessment
No answer reported: 65 (21.6%)

301

Independent review

Independent review
Reported in place: 110 (36.5%)Independent review
Reported in progress: 153 (50.8%)Independent review
Reported not in place: 2 (0.7%)Independent review
Waived by CAIO: 1 (0.3%)Independent review
No answer reported: 35 (11.6%)

301

Ongoing monitoring

Ongoing monitoring
Reported in place: 112 (37.2%)Ongoing monitoring
Reported in progress: 154 (51.2%)Ongoing monitoring
Other or ambiguous answer: 1 (0.3%)Ongoing monitoring
No answer reported: 34 (11.3%)

301

Operator training

Operator training
Reported in place: 129 (42.9%)Operator training
Reported in progress: 149 (49.5%)Operator training
Other or ambiguous answer: 3 (1.0%)Operator training
No answer reported: 20 (6.6%)

301

Fail-safe

Fail-safe
Reported in place: 72 (23.9%)Fail-safe
Reported in progress: 84 (27.9%)Fail-safe
Not applicable: 135 (44.9%)Fail-safe
No answer reported: 10 (3.3%)

301

Appeal process

Appeal process
Reported in place: 25 (8.3%)Appeal process
Reported in progress: 118 (39.2%)Appeal process
Not applicable: 143 (47.5%)Appeal process
Precluded by law or guidance: 4 (1.3%)Appeal process
No answer reported: 11 (3.7%)

301

User and public consultation

User and public consultation
Reported in place: 107 (35.5%)User and public consultation
Reported in progress: 111 (36.9%)User and public consultation
Other or ambiguous answer: 47 (15.6%)User and public consultation
No answer reported: 36 (12.0%)

301

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	301	94	163	1	0	0	0	43	86%	31% of 301
AI impact assessment	301	69	166	1	0	0	0	65	78%	23% of 301
Independent review	301	110	153	2	0	1	0	35	88%	37% of 300
Ongoing monitoring	301	112	154	0	0	0	1	34	89%	37% of 301
Operator training	301	129	149	0	0	0	3	20	93%	43% of 301
Fail-safe	301	72	84	0	135	0	0	10	97%	43% of 166
Appeal process	301	25	118	0	143	4	0	11	96%	16% of 154
User and public consultation	301	107	111	0	0	0	47	36	88%	36% of 301

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	29%	12%	22%	21%	39%	91%	58%	72%	89
DOJ	0%	0%	0%	0%	0%	0%	0%	0%	75
DHS	82%	67%	67%	72%	72%	75%	67%	46%	39
DOI	–	–	92%	92%	92%	0%	0%	0%	37
SBA	50%	50%	50%	50%	50%	100%	50%	32%	34
SSA	90%	80%	80%	70%	80%	89%	75%	30%	10
FERC	40%	100%	100%	40%	40%	40%	0%	40%	5
EAC	25%	–	0%	–	–	–	–	100%	4
EPA	100%	0%	0%	50%	50%	100%	0%	50%	2
TREAS	50%	50%	0%	0%	50%	50%	0%	100%	2
STATE	100%	0%	0%	100%	100%	100%	100%	100%	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

240 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
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
Open Source and Social Media Analysis DHS · DHS-2538	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Reported in place	Reported in progress
Cryptocurrency Analysis DHS · DHS-2561	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
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
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
Consular Consolidated Database (CCD) Facial Recognition (FR) On Demand Report (VISA Only) DHS · DHS-365	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
AI-Assisted Resume Screening Tool DHS · DHS-2556	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
Mobile Fortify DHS · DHS-2577	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Other or ambiguous answer	Reported in progress	Reported in progress	Reported in progress
License Plate Capture and Analysis DHS · DHS-2666	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Other or ambiguous answer	Reported in progress	Reported in progress	Reported in progress
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
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
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
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
LivChat DOE · DOE-613	Deployed	Reported in place	No answer reported	No answer reported	No answer reported	No answer reported	Not applicable	Not applicable	Other or ambiguous answer
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
NA-CI Salesforce DOE · DOE-747	Deployed	Reported in progress	Reported in progress	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
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
Rangeland Condition Monitoring Assessment and Projection (RCMAP) [2024 INV#WO0000000107126] DOI · DOI-0171	Deployed	No answer reported	No answer reported	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in progress
use of random forest for species distribution modeling DOI · DOI-0161	Deployed	No answer reported	No answer reported	Reported in place	Reported in place	Reported in place	Not applicable	Reported in progress	No answer reported
Global food-and-water security-support analysis data (GFSAD) project [2024 INV#WO0000000107073] DOI · DOI-0095	Deployed	No answer reported	No answer reported	Reported in place	Reported in place	Reported in place	Not applicable	Reported in progress	No answer reported
Frog vocalization recognition from digital recordings DOI · DOI-0092	Deployed	No answer reported	No answer reported	Reported in place	Reported in place	Reported in place	Not applicable	Reported in progress	No answer reported
Patterns in the Landscape – Analyses of Cause and Effect DOI · DOI-0090	Deployed	No answer reported	No answer reported	Reported in place	Reported in place	Reported in place	Not applicable	Reported in progress	No answer reported
Submersed Aquatic Vegetation Vulnerability Evaluation Application (SAVVEA) DOI · DOI-0081	Deployed	No answer reported	No answer reported	Reported in place	Reported in place	Reported in place	Not applicable	Reported in progress	No answer reported
U.S. Wind Turbine Database DOI · DOI-0080	Deployed	No answer reported	No answer reported	Reported in place	Reported in place	Reported in place	Not applicable	Reported in progress	No answer reported
Machine learning in remote sensing-based wildfire and natural resource risk assessments DOI · DOI-0072	Deployed	No answer reported	No answer reported	Reported in place	Reported in place	Reported in place	Not applicable	Reported in progress	No answer reported
Telemetry Analysis Learning Algorithm (TALA) DOI · DOI-0070	Deployed	No answer reported	No answer reported	Reported in place	Reported in place	Reported in place	Not applicable	Reported in progress	No answer reported
LANDFIRE DOI · DOI-0069	Deployed	No answer reported	No answer reported	Reported in place	Reported in place	Reported in place	Not applicable	Reported in progress	No answer reported
DocketScope DOI · DOI-0040	Deployed	No answer reported	No answer reported	Reported in place	Reported in place	Reported in place	Not applicable	Reported in progress	No answer reported
Airlines Travel Intelligence Program DOJ · DOJ-0002	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
Unmanned Aerial Systems (UAS) DOJ · DOJ-0003	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
Axon FUSUS (via HIDTA partners) DOJ · DOJ-0005	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
Cell Hawk (via HIDTA partners) DOJ · DOJ-0010	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
Axon Evidence.com DOJ · DOJ-0015	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
FINDER DOJ · DOJ-0017	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
First Two DOJ · DOJ-0018	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
Palantir (via access to external state LE system) DOJ · DOJ-0025	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
ShotSpotter (via access to external state/local systems) DOJ · DOJ-0028	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

Showing 80 of 240, deployed first.

Unanswered analytical questions

Generated from the data; for follow-up with agencies

VA designated 215 use cases high-impact but answered none of the minimum-practice questions for any of them. Were the practices assessed, and where is that recorded?
NCUA designated 5 use cases high-impact but answered none of the minimum-practice questions for any of them. Were the practices assessed, and where is that recorded?
TREAS designated 4 use cases high-impact but answered none of the minimum-practice questions for any of them. Were the practices assessed, and where is that recorded?
90 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?
30 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
87 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
75 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.