Planisphere Download for Mac

Question · High-Impact AI

What counts as "high-impact AI" under the federal AI memo?

High-impact AI is M-25-21's single risk tier for federal AI: AI whose output is a principal basis for decisions with a legal, material, binding or significant effect on rights or safety, with 15 listed categories presumed high-impact.

AboutHigh-Impact AI
Legal forceBinding on federal agencies
Applies from3 Apr 2026
Checked21 Oct 2026

01 / The answer

The short answer

Under OMB M-25-21, an AI use is high-impact when its output is a principal basis for decisions or actions with a legal, material, binding or significant effect on civil rights, liberties or privacy; access to education, housing, credit, employment and similar programs; critical government services; health and safety; critical infrastructure; or strategic assets. Section 6 lists 15 categories presumed high-impact, including medical functions, law enforcement risk assessments, benefits eligibility and federal employment decisions. Human oversight does not by itself remove a use from scope, and an official must notify the Chief AI Officer in writing when deciding a presumed use is not high-impact.
High-Impact AI · checked 21 Oct 2026

02 / The rule

What High-Impact AI requires

High-impact AI is M-25-21's single risk tier for federal AI: AI whose output is a principal basis for decisions with a legal, material, binding or significant effect on rights or safety, with 15 listed categories presumed high-impact. Each such use must meet seven minimum practices, have a CAIO waiver, or be discontinued.

  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.

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

RELATED

Related: High-Impact AI: the full guide · What does OMB M-25-21 require for high-impact AI?