Artificial Intelligence: Agencies Have Begun Implementation but Need to Complete Key Requirements
GAO-24-105980
Published: Dec 12, 2023. Publicly Released: Dec 12, 2023.
Fast Facts
Artificial intelligence is rapidly changing the world and could improve government operations. For example, federal agencies can use AI to analyze drone photos and large datasets. But safeguards are needed to manage AI risks.
Federal law and guidance have several requirements for agencies implementing AI, but they haven't all been met. For example, there's no government-wide guidance on how agencies should acquire and use AI. Without such guidance, agencies can't consistently manage AI. And until all requirements are met, agencies can't effectively address AI risks and benefits.
Our 35 recommendations address these issues and more.
Highlights
What GAO Found
Twenty of 23 agencies reported about 1,200 current and planned artificial intelligence (AI) use cases—specific challenges or opportunities that AI may solve. Three agencies reported not having uses for AI. Agency reported uses included analyzing data from cameras and radar to identify border activities, analyzing photographs from drones, and targeting of scientific specimens for planetary rovers. The National Aeronautics and Space Administration (NASA) and the Department of Commerce (Commerce) reported the highest number of AI use cases (see figure).
Agency Reported AI Use Cases in Fiscal Year 2022
Most of the reported AI use cases were in the planning phase and not yet in production (i.e., currently used) (see figure). In about 200 instances, agencies reported that they were currently using AI.
Agency Reported Artificial Intelligence (AI) Use Case Lifecycle Stage, as of Fiscal Year 2022
a“Other” includes life cycle stage responses not included in the 2021 Guidance for Creating Agency Inventories of Artificial Intelligence Use Cases, such as “research and design” and “exploratory.”
GAO's analysis of agencies' inventories of use cases identified instances of incomplete and inaccurate data. Specifically, five agencies provided comprehensive information for each of their reported use cases while the other 15 had instances of incomplete and inaccurate data. For example, some inventories did not include required data elements, such as the AI life cycle stage or an indication of whether an AI use case was releasable or not. In addition, two inventories included AI uses that were later determined by the agencies to not be AI. Without accurate inventories, the government's management of its use of AI will be hindered by incomplete and inaccurate data.
Federal agencies have taken initial steps to comply with AI requirements in executive orders and federal law; however, more work remains to fully implement these.
- Commerce and the General Services Administration (GSA) fully implemented selected requirements. Specifically, Commerce created a plan to develop AI technical standards and GSA established the AI Center of Excellence.
- The Offices of Management and Budget (OMB) and Personnel Management (OPM) did not fully implement selected requirements. OMB has not yet developed guidance for the acquisition and use of AI. OPM has not yet established or updated an occupational category for those employees performing AI work.
- The Office of Science and Technology Policy (OSTP) did not communicate its designation of which agencies were expected to fulfill specific AI requirements.
- Ten of 23 agencies implemented all AI requirements specific to their agencies, 12 implemented some but not all, and one was exempt from the requirements. These requirements included preparing an inventory on the use of AI, planning for inventory updates, and planning for AI regulatory authorities.
Addressing these requirements will improve agency identification, development, implementation, and oversight of AI.
Why GAO Did This Study
While there are varying definitions of AI, they generally refer to computing systems that “learn” how to improve their performance. AI has the potential to rapidly change the world and holds substantial promise for improving government operations. However, AI poses risks that can negatively impact individuals, groups, organizations, communities, and society.
The President's fiscal year 2023 budget request included $1.8 billion for nondefense research and development investment in AI. In addition, some agencies are using AI operationally to identify information security threats and facilitate the review of large datasets, among other uses. Given the rapid growth in capabilities and widespread adoption of AI, the federal government should have safeguards to manage AI's complexities, risks, and societal consequences.
In this report, GAO reviewed the implementation of AI at major federal agencies. This report examines (1) federal agency reported current and planned uses of AI, (2) the extent to which federal agencies' AI reporting was comprehensive and accurate, and (3) the extent to which federal agencies have complied with selected federal policy and guidance on AI.
This review focused on agencies with government-wide roles in AI implementation (including OMB and OPM) as well as agencies with individual responsibilities for AI implementation (including 23 of the 24 Chief Financial Officers (CFO) Act of 1990 agencies). The Department of Defense was excluded because GAO had issued recent AI reports on that department.
GAO reviewed the 23 civilian CFO Act agencies' AI inventories and analyzed reported use cases and supporting data. GAO also compared agency reported data to the requirements for developing an AI inventory outlined in federal guidance.
In addition, GAO identified requirements from executive orders, OMB guidance, and a law regarding the implementation of AI. GAO then assessed agencies' implementation of these requirements. GAO also interviewed relevant officials.
Recommendations
GAO is making 35 recommendations to 19 agencies, including OMB, to fully implement federal AI requirements. Specifically, GAO is recommending that:
- Fifteen agencies update their AI use case inventories to include required information and take steps to ensure the data aligns with guidance.
- OMB, OSTP, and OPM implement AI requirements with government-wide implications, such as issuing guidance and establishing or updating an occupational series with AI-related positions.
- Twelve agencies fully implement AI requirements in federal law, policy, and guidance, such as developing a plan for how the agency intends to conduct annual inventory updates; and describing and planning for regulatory authorities on AI.
Of the 19 agencies, ten agencies agreed with their recommendations; three agencies partially agreed with one or more recommendations; four agencies neither agreed nor disagreed; and one agency did not agree with its recommendation. OMB agreed with one recommendation but disagreed with another because it had taken recent action. GAO maintains that the recommendations in the report are warranted.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Office of Management and Budget | The Director of OMB should ensure that the agency issues guidance to federal agencies in accordance with federal law, that is to (a) inform the agencies' policy development related to the acquisition and use of technologies enabled by AI, (b) include identifying responsible AI officials (RAIO), (c) recommend approaches to remove barriers for AI use, (d) identify best practices for addressing discriminatory impact on the basis of any classification protected under federal nondiscrimination laws, and (e) provide a template for agency plans that includes the required contents. (Recommendation 1) |
OMB agreed with the recommendation. As of September 2025, OMB partially addressed the recommendation. Specifically, while OMB has met most of this requirement, the agency has not provided agencies with a template for their plans, as required by the AI in Government Act of 2020. We will continue to monitor the implementation of this recommendation.
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| Office of Management and Budget | The Director of OMB should ensure that the agency develops and posts a public roadmap for the agency's policy guidance to better support AI use, and, where appropriate, include a schedule for engaging with the public and timelines for finalizing relevant policy guidance, consistent with EO 13960. (Recommendation 2) |
OMB disagreed with this recommendation as it appeared in a draft version of this report and stated it believed that this action was superseded by the publication of EO 14110. OMB further noted that the EO contains a list of actions for OMB, alongside deadlines for finalizing policy guidance. EO 14110 was issued in October 2023, after we provided OMB a copy of a draft of this report. We updated our report to show that the issuance of the new EO would implement our recommendation. In July 2024, we assessed EO 14110 and determined that it fully addressed the recommendation.
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| Office of Science and Technology Policy | The Director of the Office of Science and Technology Policy should communicate a list of federal agencies that are required to implement the Regulation of AI Applications memorandum requirements (M-21-06) to inform agencies of their status as implementing agencies with regulatory authorities over AI. (Recommendation 3) |
OSTP did not agree with the recommendation in our report. In particular, the agency stated that EO 13859 did not state that the office must communicate the designation to agencies. As we noted in our report, while we acknowledge that the EO does not require communication, because this is a designation to be determined by OSTP's Select Committee, agencies cannot be expected to know their status unless it is communicated to them. As of August 2025, we have not received any updates on its efforts to address this recommendation. When we confirm what actions the agency has taken to address this recommendation, we will provide updated information.
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| Office of Personnel Management | The Director of OPM should ensure that the agency (a) establishes or updates and improves an existing occupational series with AI-related positions; (b) establishes an estimated number of AI-related positions, by federal agency; and, based on the estimate, (c) prepares a 2-year and 5-year forecast of the number of federal employees in these positions, in accordance with federal law. (Recommendation 4) |
OPM partially concurred with the recommendation. As of August 2025, OPM has partially addressed the requirement. Specifically, while OPM has estimated the number of federal AI-related positions and prepared a forecast of the number of federal employees in the position. It has not established nor updated the occupational series with AI related positions. We will continue to monitor the implementation of this recommendation.
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| Office of Personnel Management | The Director of OPM should ensure that the agency creates an inventory of federal rotational programs and determines how these programs can be used to expand the number of federal employees with AI expertise, consistent with EO 13960. (Recommendation 5) |
OPM concurred with the recommendation. At the time of our report, OPM stated that it had created an inventory after a June 2023 data call. In February 2024, OPM published a memorandum that included the federal inventory of rotational programs. In addition, the memorandum included recommendations on how to expand the rotational programs. In July 2024, we assessed the memorandum and determined that the agency has fully implemented this recommendation.
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| Office of Personnel Management | The Director of OPM should ensure that the agency issues a report with recommendations for how the programs in the inventory can be used to expand the number of federal employees with AI expertise and shares it with the interagency coordination bodies identified by the Chief Information Officers Council, consistent with EO 13960. (Recommendation 6) |
OPM concurred with the recommendation. At the time of our report, OPM stated that it was finalizing a report on how programs in the inventory can be used to expand the number of employees with AI expertise. In February 2024, OPM published a memorandum that provided recommendations to expand rotational programs to employees with AI expertise. In July 2024, we assessed the memorandum and determined that the agency has fully implemented this recommendation.
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| Office of Personnel Management | The Director of OPM should ensure that the agency develops a plan to either achieve consistency with EO 13960 section 5 for each AI application or retires AI applications found to be developed or used in a manner that is not consistent with the order. (Recommendation 7) |
OPM concurred with the recommendation. As of August 2025, we have not received any updates on agency efforts to address this recommendation. When we confirm what actions the agency has taken to address this recommendation, we will provide updated information.
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| Department of Agriculture | The Secretary of Agriculture should ensure that the department (a) reviews the department's authorities related to applications of AI, and (b) develops and submits to OMB plans to achieve consistency with the Regulation of AI Applications memorandum (M-21-06). (Recommendation 8) |
Agriculture agreed with the recommendation. As of August 2025, Agriculture has not provided documentation to address the recommendation. We will continue to monitor the implementation of this recommendation.
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| Department of Agriculture | The Secretary of Agriculture should ensure that the department updates its AI use case inventory to include all the required information, at minimum, and takes steps to ensure that the data in the inventory aligns with provided instructions. (Recommendation 9) |
Agriculture agreed with the recommendation. In February 2025, Agriculture provided their 2024 AI use case inventory. As of August 2025, we determined the agency did not include all the required information in their 2024 AI use case inventory. We will continue to monitor the implementation of this recommendation.
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| Department of Commerce | The Secretary of Commerce should ensure that the department develops a plan to either achieve consistency with EO 13960 section 5 for each AI application or retires AI applications found to be developed or used in a manner that is not consistent with the order. (Recommendation 10) |
Commerce agreed with the recommendation. As of August 2025, the agency has not provided documentation to address the recommendation. We will continue to monitor the implementation of this recommendation.
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| Department of Commerce | The Secretary of Commerce should ensure that the department updates its AI use case inventory to include all the required information, at minimum, and takes steps to ensure that the data in the inventory aligns with provided instructions. (Recommendation 11) |
Commerce agreed with the recommendation. As of August 2025, the agency has not provided documentation to address the recommendation. We will continue to monitor the implementation of this recommendation.
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| Department of Education | The Secretary of Education should ensure that the department develops a plan to either achieve consistency with EO 13960 section 5 for each AI application or retires AI applications found to be developed or used in a manner that is not consistent with the order. (Recommendation 12) |
At the time of our report, Education stated that it concurred in part with the recommendation but did not state with which part of the recommendation it did not concur. In a February 2025 update, the agency stated its Corrective Action Plan has been developed and the recommendation is being implemented. An expected completion date was not provided. We will continue to monitor the implementation of this recommendation
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| Department of Energy | The Secretary of Energy should ensure that the department updates its AI use case inventory to include all the required information, at minimum, and takes steps to ensure that the data in the inventory aligns with provided instructions. (Recommendation 13) |
Energy concurred with the recommendation. In July 2025, Energy stated the department will update its use case inventory to include all required information consistent with OMB's revised instructions. We will continue to monitor the implementation of this recommendation.
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| Department of Health and Human Services | The Secretary of Health and Human Services should ensure that the department develops a plan to either achieve consistency with EO 13960 section 5 for each AI application or retires AI applications found to be developed or used in a manner that is not consistent with the order. (Recommendation 14) |
HHS concurred with the recommendation. In October 2024, HHS provided the M-24-10 Compliance Plan. We determined the compliance plan did not address the requirement to either achieve consistency with EO 13960 or retire AI applications found to be developed or used in a manner that is not consistent with the order. When we confirm what actions the agency has taken to address this recommendation, we will provide updated information.
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| Department of Health and Human Services | The Secretary of Health and Human Services should ensure that the department updates its AI use case inventory to include all the required information, at minimum, and takes steps to ensure that the data in the inventory aligns with provided instructions. (Recommendation 15) |
HHS concurred with the recommendation. In February 2025, HHS provided their 2024 AI use case inventory. As of August 2025, we determined the agency did not include all the required information in their 2024 AI use case inventory. We will continue to monitor the implementation of this recommendation.
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| Department of Homeland Security | The Secretary of Homeland Security should ensure that the department develops a plan to either achieve consistency with EO 13960 section 5 for each AI application or retires AI applications found to be developed or used in a manner that is not consistent with the order. (Recommendation 16) |
DHS concurred with the recommendation. In April 2025, DHS provided documents in response to the recommendation. However, the documents did not clearly define a plan to either achieve consistency with EO 13960 section 5 for each AI application or retire AI applications found to be developed or used in a manner that is not consistent with the order. We will continue to monitor the implementation of this recommendation.
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| Department of Homeland Security | The Secretary of Homeland Security should ensure that the department (a) reviews the department's authorities related to applications of AI and (b) develops and submits to OMB plans to achieve consistency with the Regulation of AI Applications memorandum (M-21-06). (Recommendation 17) |
DHS concurred with the recommendation. In a June 2024 update, DHS stated its OCIO and PLCY offices are working to address this recommendation. These actions are expected to be completed by December 31, 2024. As of August 2025, we have not received documentation to address the recommendation. We will continue to monitor the implementation of this recommendation.
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| Department of Homeland Security | The Secretary of Homeland Security should ensure that the department updates its AI use case inventory to include all the required information, at minimum, and takes steps to ensure that the data in the inventory aligns with provided instructions. (Recommendation 18) |
DHS concurred with the recommendation. In April 2025, DHS provided their 2024 AI use case inventory. As of August 2025, we determined the department did not include all the required information in their 2024 AI use case inventory. We will continue to monitor the implementation of this recommendation.
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| Department of the Interior | The Secretary of the Interior should ensure that the department develops a plan to either achieve consistency with EO 13960 section 5 for each AI application or retires AI applications found to be developed or used in a manner that is not consistent with the order. (Recommendation 19) |
Interior concurred with the recommendation. In August 2025, Interior stated that it launched an AI use case inventory application process and provided an AI inventory-related directive and a procedural guide as evidence of complying with the executive order 13960 section 5 (now superseded). However, the inventory application process does not constitute a plan for achieving consistency with the executive order. In addition, the directive and the guide did not include steps for achieving consistency with executive order 13960 section 5 or retiring any AI use cases that do not comply with the order. We will continue to monitor the implementation of this recommendation.
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| Department of the Interior | The Secretary of the Interior should ensure that the department (a) reviews the agency's authorities related to applications of AI and (b) develops and submits to OMB plans to achieve consistency with the Regulation of AI Applications memorandum (M-21-06). (Recommendation 20) |
Interior concurred with the recommendation. In August 2025, Interior stated that the agency does not have any known legal authorities that might enable Interior to regulate AI and provided a previous plan to comply with OMB guidance M-24-10 (now rescinded). However, that plan did not mention regulatory authorities or compliance with M-21-06. To implement this recommendation, Interior needs to provide evidence that it has created a plan to achieve consistency with M-21-06, which could include a determination that Interior does not have authorities to regulate AI. This plan should be submitted to OMB and posted on a publicly available page on the agency's website, according to requirements.
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| Department of the Interior | The Secretary of the Interior should ensure that the department updates its AI use case inventory to include all the required information, at minimum, and takes steps to ensure that the data in the inventory aligns with provided instructions. (Recommendation 21) |
Interior concurred with the recommendation and in an August 2025 update, the department provided documentation in response to the recommendation. In September 2025, we determined the documentation did not address the recommendation and have requested additional support. We will continue to monitor the implementation of this recommendation.
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| Department of Labor | The Secretary of Labor should ensure that the department updates its AI use case inventory to include all the required information, at minimum, and takes steps to ensure that the data in the inventory aligns with provided instructions. (Recommendation 22) |
Labor did not state whether the department agreed or disagreed with our recommendations. In September 2025, the department stated that it planned to update the AI use case inventory according to new guidance by December 2025. When we confirm what actions the agency has taken to address this recommendation, we will provide updated information.
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| Department of State | The Secretary of State should ensure that the department updates its AI use case inventory to include all the required information, at minimum, and takes steps to ensure that the data in the inventory aligns with provided instructions. (Recommendation 23) |
State did not state whether the department agreed or disagreed with the recommendation. As of August 2025, we determined that department did not include all of the required information in its 2024 AI use case inventory. State needs to ensure that its AI use case inventory includes all information required by the provided guidance. We will continue to monitor the implementation of this recommendation.
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| Department of Transportation | The Secretary of Transportation should ensure that the department (a) reviews the department's authorities related to applications of AI and (b) develops and submits to OMB plans to achieve consistency with the Regulation of AI Applications memorandum (M-21-06). (Recommendation 24) |
Transportation concurred with the recommendation. In May 2024, Transportation provided evidence that showed its authorities related to applications of AI were reviewed and that its plans to achieve consistency with the Regulation of AI Applications memorandum (M-21-06) were submitted to OMB in April 2024. We assessed the documentation provided and determined that this recommendation has been addressed. As a result, the agency has taken steps to increase its transparency with the public and proactively prepare for the complexities and risks that may arise as they strive to implement AI.
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| Department of Transportation | The Secretary of Transportation should ensure that the department updates its AI use case inventory to include all the required information, at minimum, and takes steps to ensure that the data in the inventory aligns with provided instructions. (Recommendation 25) |
Transportation concurred with the recommendation. In April 2024, the department stated it had updated procedures for reviewing AI use case inventory data to ensure completeness and alignment with provided instructions. As of August 2025, the department has not provided an update on its efforts to address the recommendation. We will continue to monitor the implementation of this recommendation.
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| Department of the Treasury | The Secretary of the Treasury should ensure that the department develops a plan to either achieve consistency with EO 13960 section 5 for each AI application or retires AI applications found to be developed or used in a manner that is not consistent with the order. (Recommendation 26) |
Treasury did not state whether the department agreed or disagreed with the recommendation. As of August 2025, the department has not provided documentation to address the recommendation. We will continue to monitor the implementation of this recommendation.
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| Department of the Treasury | The Secretary of the Treasury should ensure that the department updates its AI use case inventory to include all the required information, at minimum, and takes steps to ensure that the data in the inventory aligns with provided instructions. (Recommendation 27) |
Treasury did not state whether the department agreed or disagreed with the recommendation. As of August 2025, the department has not provided documentation to address the recommendation. We will continue to monitor the implementation of this recommendation.
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| Department of Veterans Affairs | The Secretary of Veterans Affairs should ensure that the department updates its AI use case inventory to include all the required information, at minimum, and takes steps to ensure that the data in the inventory aligns with provided instructions. (Recommendation 28) |
VA concurred with the recommendation. In August 2025, VA provided its 2024 AI use case inventory. As of August 2025, we determined that the agency did not include all of the required information in its 2024 AI use case inventory. VA needs to ensure that its AI use case inventory includes all information required by the provided guidance. We will continue to monitor the implementation of this recommendation.
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| Environmental Protection Agency | The Administrator of the Environmental Protection Agency should ensure that the agency fully completes and approves its plan to either achieve consistency with EO 13960 section 5 for each AI application or retires AI applications found to be developed or used in a manner that is not consistent with the order. (Recommendation 29) |
EPA agreed with the recommendation. In a July 2025 update, EPA stated the agency is working on resetting their risk management process back to meeting the requirements under Executive Orders 13960 and 14179 and the new guidance in M-25-21. The deadline for completion of this action is now April 2, 2026. When we confirm what actions the agency has taken to address this recommendation, we will provide updated information.
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| Environmental Protection Agency | The Administrator of the Environmental Protection Agency should ensure that the agency updates its AI use case inventory to include all the required information, at minimum, and takes steps to ensure that the data in the inventory aligns with provided instructions. (Recommendation 30) |
EPA agreed with the recommendation. In January 2025, EPA provided their 2024 AI use case inventory. As of August 2025, we determined the agency did not include all the required information in their 2024 AI use case inventory. We will continue to monitor the implementation of this recommendation.
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| General Services Administration | The Administrator of General Services should ensure that the agency develops a plan to either achieve consistency with EO 13960 section 5 for each AI application or retires AI applications found to be developed or used in a manner that is not consistent with the order. (Recommendation 31) |
GSA agreed with the recommendation. In September 2024, GSA provided the department's AI Action Plan. We determined the plan consistently mentioned Executive Order (EO) 14110 and OMB M-24-10. The EO and memorandum were rescinded by EO 14148 in January 2025. As a result, the plan is outdated and does not address the recommendation. When we confirm what actions the agency has taken to address this recommendation, we will provide updated information.
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| General Services Administration | The Administrator of General Services should ensure that the agency updates its AI use case inventory to include all the required information, at minimum, and takes steps to ensure that the data in the inventory aligns with provided instructions. (Recommendation 32) |
GSA agreed with the recommendation. In January 2025, GSA provided its updated 2024 AI use case inventory. As of May 2025, the use case inventory included some of the required information, but not all, and contained incorrect data inputs that were not in accordance with provided instructions. On August 11, 2025, the agency stated that it was taking further steps to improve the AI use case inventory. We will continue to monitor the implementation of this recommendation.
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| National Aeronautics and Space Administration | The Administrator of the National Aeronautics and Space Administration should ensure that the agency updates and approves the agency's plan to achieve consistency with EO 13960 section 5 for each AI application, to include retiring AI applications found to be developed or used in a manner that is not consistent with the order. (Recommendation 33) |
NASA concurred with our recommendation. In December 2024, NASA provided a list of actions the agency has taken to address the recommendation. For example, NASA stated all use cases were evaluated to ensure consistency with EO 13960. In addition, NASA stated that 38 use cases had been retired and were not subject to a particular reporting requirement. However, NASA did not provide supporting documentation to demonstrate that the agency has a plan to either achieve consistency with EO 13960 section 5 or retire AI applications found to be developed or used in a manner that is not consistent with the order. When we confirm what actions the agency has taken to address this recommendation, we will provide updated information.
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| National Aeronautics and Space Administration | The Administrator of the National Aeronautics and Space Administration should ensure that the agency updates its AI use case inventory to include all the required information, at minimum, and takes steps to ensure that the data in the inventory aligns with provided instructions. (Recommendation 34) |
NASA partially concurred with the recommendation. In January 2025, NASA provided their 2024 AI use case inventory. As of August 2025, we determined the agency did not include all the required information in their 2024 AI use case inventory. We will continue to monitor the implementation of this recommendation.
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| U.S. Agency for International Development | The Administrator of the U.S. Agency for International Development should ensure that the agency updates its AI use case inventory to include all the required information, at minimum, and takes steps to ensure that the data in the inventory aligns with provided instructions. (Recommendation 35) |
USAID did not state whether the agency agreed or disagreed with our recommendation. In December 2024, USAID provided their 2024 AI use case inventory. As of August 2025, we determined the agency did not include all the required information in their 2024 AI use case inventory. We will continue to monitor the implementation of this recommendation.
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