Public Sector AI Audit Trails Answer the High-Impact Determination
OMB Memorandum M-25-21, issued April 3, 2025, directs federal agencies to implement minimum risk management practices for high-impact AI, to establish a process for determining and documenting high-impact use cases, to measure and monitor ongoing performance and to centrally track those determinations. An audit trail is what makes those processes examinable. This article maps the memorandum duties to the per-request records an agency has to hold.
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