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: M-24-10 requires safety-impacting AI to complete pre-deployment testing, independent evaluation, and documented human fallback controls before the compliance milestone. Zeph Tech is harmonising red-team reports, bias testing, and resilience drills into agency-ready packets, giving Chief AI Officers and Inspectors General traceable evidence.
Regulatory checkpoints
- Appendix C controls. Agencies must evidence independent evaluation, ongoing monitoring, and fallback procedures for every safety-impacting AI system.
- Waiver governance. Section 5(c) allows limited waivers, but agencies must justify compensating controls, mitigation timelines, and report status quarterly.
- Public transparency. M-24-10 directs agencies to publish inventory summaries that reference evaluation results and human oversight structures.
Operational safeguards
- Crosswalk red-team, bias, and robustness results to NIST AI RMF functions and ISO/IEC 42001 clauses so evidence aligns with federal governance vocabularies.
- Implement configuration management for model cards, evaluation scripts, and datasets so auditors can reproduce findings.
- Document escalation paths when evaluation findings trigger remediation or shutdown decisions, including CAIO approvals.
Next steps
- Bundle evaluation artefacts into secure data rooms shared with agency leads, Inspectors General, and oversight bodies.
- Integrate evaluation lessons into Zeph Tech’s product roadmaps to accelerate future safety-impacting AI launches.
- Update quarterly reporting templates with evaluation scores, waiver statuses, and corrective-action milestones.