AI Governance Briefing — March 21, 2025
Zeph Tech is consolidating independent evaluation evidence for safety-impacting AI so agencies can certify Appendix C compliance by the March 28 M-24-10 deadline.
Executive briefing: OMB Memorandum M-24-10 requires every safety-impacting AI system to complete pre-deployment testing, independent evaluation, and human fallback controls by . Zeph Tech is packaging red-team findings, bias assessments, resilience drills, and human-in-the-loop playbooks into audit-ready packets for agency Chief AI Officers (CAIOs) and Inspectors General. This briefing connects to the AI pillar hub at Zeph Tech AI tools, the OMB M-24-10 implementation guide, and companion briefs on agency governance and safety controls to deliver a unified compliance runway.
What the memo demands
- Appendix C controls. Agencies must evidence independent evaluation, ongoing monitoring, and human fallback procedures for every safety-impacting AI system.
- Pre-deployment testing. Systems must demonstrate safety, security, and efficacy before launch, including bias, robustness, and red-team assessments.
- Waiver governance. Section 5(c) allows limited waivers, but agencies must justify compensating controls, mitigation timelines, and report status quarterly.
- Transparency and documentation. CAIOs must certify compliance, maintain inventories, and be able to furnish evidence to oversight bodies.
Independent evaluation stack
Zeph Tech’s evaluation plan mirrors M-24-10 language so agencies can reference Appendix C directly.
| Requirement | Zeph Tech deliverable | Evidence format |
|---|---|---|
| Independent evaluation of safety-impacting AI | Third-party review of model, data pipeline, and controls | Signed assessment report, scope statement, tester qualifications |
| Pre-deployment testing | Bias testing, robustness checks, adversarial simulations | Test scripts, datasets or references, pass/fail logs |
| Human fallback and override | Runbooks for escalation, rollback, and manual decision points | Operational playbooks, training receipts, escalation matrix |
| Ongoing monitoring | Telemetry thresholds, drift detection, incident triggers | Monitoring dashboard captures, alert policies, response SLAs |
| Waiver justification (if used) | Risk acceptance memo with compensating controls | Signed waiver package, quarterly status updates |
Plan (scope + risks) -> Test (bias, robustness, red-team) -> Independent evaluation -> Remediate & retest -> Human fallback drills -> CAIO approval & documentation
Alt text: Workflow showing planning, testing, independent evaluation, remediation, fallback drills, and CAIO approval before deployment.
Red-team and robustness focus
Independent evaluations rely on rigorous pre-deployment testing:
- Prompt-attack resilience: Injection, jailbreaking, and content safety bypass attempts to validate guardrails.
- Bias and fairness: Sampling across demographics and scenarios to surface disparate outcomes, with mitigation steps logged.
- Robustness: Perturbation and stress testing to ensure model performance under edge cases and noisy inputs.
- Safety-impacting scenarios: Domain-specific drills (health, benefits eligibility, transportation) aligned to the memo’s safety definition.
Human fallback and accountability
M-24-10 emphasises human oversight. Zeph Tech supplies escalation and override playbooks aligned to agency mission contexts.
- Clear decision points: Identify where humans must approve, override, or review AI outputs before actions execute.
- Escalation ladders: Named roles for operators, supervisors, and CAIO delegates with time-bound response expectations.
- Rollback readiness: Procedures for disabling models, reverting to manual workflows, and notifying impacted users.
- Training and drills: Exercises that measure operator readiness and document attendance, outcomes, and corrections.
Plan tests: Product (R), CAIO (A), Privacy/Security (C) | Execute tests: Safety & Reliability (R), External evaluator (C) | Approve remediation: CAIO (A), Business owner (R), IG (C) | Run fallback drills: Operations (R), Business owner (A), Training (C) | Sign-off & archive: CAIO (A), Records (R)
Alt text: Responsibility matrix showing accountable and responsible roles across planning, testing, remediation, fallback drills, and sign-off.
Evidence and documentation
To support CAIO certifications and oversight reviews, we produce:
- Evaluation scopes, methodologies, tester bios, and independence statements.
- Test logs with inputs, outputs, failures, and remediation tickets.
- Validation of model updates after fixes, including regression results.
- Records of human-fallback drills, attendance, timing, and outcomes.
- Versioned runbooks for deployment, rollback, and incident notification.
Metrics CAIOs can defend
- Test coverage: Percentage of safety-impacting scenarios with passing results and remaining exceptions.
- Time to remediate: Mean days from defect discovery to validated fix.
- Drill performance: Success rate of human fallback exercises and time to execute overrides.
- Independence assurance: Count of evaluations performed by external vs. internal teams and dates of recertification.
- Documentation freshness: Age of inventories, runbooks, and waiver packets.
Waiver handling
If agencies pursue waivers under Section 5(c), Zeph Tech provides the supporting package: rationale tied to mission needs, risk ratings, compensating controls, and timelines for full compliance. Quarterly updates track mitigation progress and any changed risk posture, enabling CAIOs to report status as required.
Timeline to March 28, 2025
| Week | Milestone | Evidence |
|---|---|---|
| Week of Feb 24 | Finalize evaluation scope and independence criteria | Signed scope, evaluator roster, data access approvals |
| Week of Mar 3 | Complete red-team, bias, and robustness testing | Test logs, failure list, mitigation owners |
| Week of Mar 10 | Finish remediation and regression validation | Retest results, updated models/configurations |
| Week of Mar 17 | Run human-fallback drills and capture outcomes | Drill reports, attendance, timing metrics |
| Week of Mar 24 | CAIO approval, records archiving, and deployment readiness | Signed approvals, technical file, communication plan |
Monitoring after deployment
M-24-10 keeps monitoring continuous. Zeph Tech configures alert thresholds and reporting routes so incidents trigger both operational responses and CAIO/IG visibility. Monitoring feeds into the incident-reporting brief and aligns with agency governance expectations.
Stakeholder to-do list
- CAIO: Confirm independence of evaluators, sign off on scopes, and set certification schedule.
- Program owners: Ensure domain-specific safety scenarios are covered and provide data context for testers.
- Security and privacy: Validate that evaluation data handling complies with agency security and privacy baselines.
- Operations: Practice rollback and manual handling for the highest-risk workflows.
- Records management: Archive all artefacts with retention labels to answer oversight requests.
With independent evaluation evidence packaged and fallback controls drilled, agencies can certify Appendix C readiness by the March 28, 2025 deadline and keep documentation aligned with the AI pillar hub, OMB M-24-10 guide, and related governance briefs.
Inventory and risk tiering
Independent evaluation depends on a clean inventory. We catalogue every model version, data pipeline, training set lineage, and deployment context so CAIOs can confirm which systems qualify as safety-impacting. Each entry records mission function, potential harms, user population, and linked system owners. That traceability speeds Appendix C attestations and ensures any waiver discussions rest on complete facts.
Coordination with oversight partners
Inspectors General and privacy officers often request early access to evaluation scopes. We schedule checkpoint reviews so oversight partners can confirm independence, data minimisation, and audit trails. After testing, we provide a consolidated technical file—evaluation reports, remediation evidence, fallback drills, and monitoring plans—so oversight bodies can verify compliance without delaying deployment.
Data handling and provenance
M-24-10 expects responsible data use throughout evaluation. Our testers operate under agency-approved data minimisation rules, log all dataset access, and document provenance for any synthetic-free test corpora used. Output samples are retained with context (prompts, parameters, runtime environment) so findings are reproducible and defensible.
Post-deployment reporting
Independent evaluation does not end at launch. We align monitoring with the memo’s quarterly reporting cadence: incident summaries, control changes, and any waiver progress are compiled for CAIO sign-off. If an incident occurs, the testing corpus is refreshed to include the failure pattern, and fallback drills are rerun to confirm readiness.
Alignment with related briefs
The evaluation package plugs into agency governance workstreams covered in the governance and safety-control briefs. Findings feed the AI inventory, risk register, and incident-reporting templates, ensuring consistent evidence across the AI pillar hub and the OMB implementation guide.
Readiness checklist
Before any CAIO signs the certification, we verify that evaluation scopes are closed, mitigations are retested, fallback drills meet timing targets, and records are archived with retention labels. Only then does deployment proceed.
Continue in the AI pillar
Return to the hub for curated research and deep-dive guides.
Latest guides
-
AI Workforce Enablement and Safeguards Guide — Zeph Tech
Equip employees for AI adoption with skills pathways, worker protections, and transparency controls aligned to U.S. Department of Labor principles, ISO/IEC 42001, and EU AI Act…
-
AI Incident Response and Resilience Guide — Zeph Tech
Coordinate AI-specific detection, escalation, and regulatory reporting that satisfy EU AI Act serious incident rules, OMB M-24-10 Section 7, and CIRCIA preparation.
-
AI Model Evaluation Operations Guide — Zeph Tech
Build traceable AI evaluation programmes that satisfy EU AI Act Annex VIII controls, OMB M-24-10 Appendix C evidence, and AISIC benchmarking requirements.