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High-Impact AI for legal AI workflows

High-Impact AI in legal AI workflows: what compliance requires, who asks for evidence, and the records to keep.

Legal forceBinding on federal agencies
Applies from3 Apr 2026
SectorLaw
Checked21 Oct 2026

01 / The rule

What High-Impact AI requires

Federal agencies and their Chief AI Officers, for each AI use whose output is a principal basis for a decision or action with legal, material, binding or significant effect on rights or safety.

  1. 01Run pre-deployment testing reflecting real-world outcomes; if no access to code, models or data, test by querying the service.
  2. 02Complete and periodically update an AI impact assessment, including independent review and a signed risk acceptance.
  3. 03Monitor performance and adverse impacts after deployment, detecting changes to the system, its data or context of use.
  4. 04Train and assess operators, and provide human oversight, intervention, accountability and a fail-safe where practicable.
  5. 05Offer affected people timely human review and appeal, and collect feedback from end users and the public.
  6. 06Document a decision when a presumed high-impact use is judged not high-impact; notify the CAIO in writing.

02 / In this sector

In a legal AI workflow

This is the federal test for which agency AI uses carry mandatory testing, impact assessment and monitoring duties. Human involvement does not by itself take a use out of scope.

Usually asked by

General counsel and litigation support.

Named alongside

FRE 702 · ABA Model Rules.

Sector pagePlanisphere for law

03 / Records

Records to keep

  1. 01High-impact determination or written not-high-impact justification
  2. 02Pre-deployment test plan, results and risk mitigation plan
  3. 03Signed AI impact assessment with independent review comments
  4. 04Ongoing monitoring logs, reassessment schedule and any CAIO waiver

Optional evidence · where Planisphere fits

Keep a record anyone can check

When your team meets a duty, Planisphere can seal the event it reports as a receipt.

01 · Your teamRecord the event

A disclosure shown, a review signed, a model change approved: the event your system reports.

02 · PlanisphereSeal it

The event becomes a sealed receipt, dated and attributed to whoever is signed in.

03 · AnyoneCheck it

Paste the receipt into Verify. No account or key.

A record supports your compliance evidence process. It is not a legal finding or a certification. Systems that call Planisphere's gate API can also hold or refuse an action before it runs.

SOURCES

Go back to the source

PRIMARY
M-25-21, Sections 4(a), 4(b), 5 and 6

Office of Management and Budget

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