Federal AI Governance

High-Impact AI

The class of federal AI use case that OMB Memorandum M-25-21 defines as AI whose output serves as a principal basis for a decision or action with legal, material, binding, or significant effect on rights, services, or safety. M-25-21 narrows the prior M-24-10 categories of "rights-impacting" and "safety-impacting" into the single high-impact tier and triggers the minimum risk management practices: pre-deployment testing, ongoing monitoring, human oversight, and a documented determination that benefits outweigh risks. CAIO approval is required before the use case may operate in production.

The Authority Brief

One compliance analysis per week from Josef Kamara, CPA, CISSP, CISA. Federal and private compliance, written for practitioners.