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Question · High-Impact AI

What does OMB M-25-21 require for high-impact AI?

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

OMB M-25-21 (April 3, 2025) requires each high-impact AI use to meet seven minimum practices or be safely discontinued: pre-deployment testing, an AI impact assessment, ongoing monitoring, adequate operator training and assessment, human oversight and accountability, consistent remedies or appeals for affected people, and feedback from end users and the public. Agencies had until April 3, 2026 to document these practices and be ready to report them to OMB. A Chief AI Officer may waive a practice only after a written, system-specific risk determination, recertified annually.
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 counts as "high-impact AI" under the federal AI memo?