AI Compliance for Federal and State Agencies
Government AI is under scrutiny from Congress, the courts, civil rights advocates, and the public. OMB M-24-10, Executive Order 14110, and a growing body of state AI legislation create specific compliance obligations that conventional AI safety tools were not designed to meet. CoreGuard provides the pre-decisional enforcement layer that government agencies need — deterministic bias prevention, mandatory human oversight hooks, and signed audit certificates for every AI decision affecting the public.
The Government AI Compliance Problem
Federal agencies are deploying AI across a wider range of functions than any prior period — from benefits eligibility determination and fraud detection to immigration case processing, criminal justice risk assessment, and public-facing information services. State agencies are following, with AI deployments in social services, DMV systems, tax administration, and court support functions.
The governance problem is structural. Government AI is not merely a commercial AI governance question — it is a constitutional and administrative law question. When an AI system recommends denial of a Social Security benefit, it is not just a policy decision; it is a due process event. When an AI system uses algorithmic risk scoring in parole recommendations, it is not just a risk management tool; it is a Fourteenth Amendment matter. When an AI system processes immigration applications, it is operating in a domain where the human stakes are among the highest possible.
Existing commercial AI governance frameworks — red-teaming, output filtering, content moderation — are not designed for this environment. Government agencies need a governance layer that operates before AI outputs affect individuals, maintains an immutable audit trail suitable for Freedom of Information Act (FOIA) production and congressional inquiry, and provides the human oversight mechanism that federal law increasingly requires.
High-Risk Government AI Use Cases Requiring Governance Controls
Benefits Eligibility
AI determining eligibility for Social Security, SNAP, Medicaid, housing assistance, and other public benefits programs must be governed against disparate impact and due process requirements.
Immigration Processing
AI assisting with visa processing, asylum case analysis, or removal proceedings requires strict human oversight controls and complete audit documentation for immigration court proceedings.
Criminal Justice Screening
AI risk scoring, facial recognition assistance, or predictive policing tools used by federal or state law enforcement require pre-decisional civil rights impact controls.
Tax and Revenue Enforcement
AI systems that identify audit targets, flag suspicious returns, or generate enforcement recommendations require bias controls to prevent discriminatory enforcement patterns.
Procurement and Contracting
AI systems that evaluate contract proposals, score vendor applications, or make award recommendations must be governed against conflict-of-interest and small business preference requirements.
Public Information Services
AI chatbots and virtual assistants that serve the public on government websites must be governed for accuracy, accessibility (ADA compliance), and prohibition on providing unauthorized legal advice.
The Federal Regulatory Landscape for Government AI
Executive Order 14110 on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence (October 2023)
Executive Order 14110 directed federal agencies to develop sector-specific AI governance guidance, established the AI Safety and Security Board, and required agencies to assess and mitigate AI risks before deployment. Section 10 of the Order specifically addresses AI in the civil rights context, directing agencies to prevent AI from undermining the rights of the American public. While subsequent administrations have modified certain provisions, the core civil rights and safety mandates remain in effect through existing statutory authority. Agencies procuring or deploying AI systems must document their compliance with Section 10 requirements.
OMB Memorandum M-24-10: Advancing Governance, Innovation, and Risk Management for Agency Use of Artificial Intelligence (March 2024)
OMB M-24-10 is the most comprehensive federal AI governance directive currently in effect. It requires agencies to: (1) designate a Chief AI Officer (CAIO) by November 2024; (2) maintain a public AI use case inventory; (3) implement minimum risk management practices for AI that impacts rights or safety, including pre-decisional human review for high-impact determinations; (4) establish AI incident reporting mechanisms; and (5) document AI governance procedures. M-24-10 explicitly identifies CoreGuard-type enforcement controls as appropriate for meeting the minimum risk management practice requirements for high-impact AI use cases.
OMB Memorandum M-25-21: Accelerating Federal Use of AI through Streamlined Governance (2025)
M-25-21 streamlined certain M-24-10 requirements while maintaining the core civil rights and safety protections. The memo emphasizes that governance frameworks should enable responsible AI adoption rather than impede it — a design principle that aligns with CoreGuard's sub-millisecond enforcement approach. M-25-21 maintains the requirement for documented pre-decisional controls for rights-impacting AI and emphasizes the importance of auditable AI decision records for agency accountability.
Administrative Procedure Act (APA) — Arbitrary and Capricious Review
The APA's prohibition on arbitrary and capricious agency action (5 U.S.C. § 706(2)(A)) applies to AI-assisted agency decisions. Courts have increasingly scrutinized whether agencies adequately explained AI-assisted decisions, whether agencies considered relevant factors, and whether human reviewers genuinely exercised independent judgment rather than rubber-stamping AI recommendations. CoreGuard's pre-decisional governance record and the mandatory human oversight hook for high-impact decisions directly address the APA's reasoned decision-making requirement and support the administrative record in judicial review proceedings.
State AI Legislation for Government Use
More than 20 states have enacted or advanced legislation governing AI use by state agencies. Common provisions include: mandatory algorithmic impact assessments before deployment, required public notice of AI use in specified decisions, mandatory human review for adverse decisions, prohibition on sole-AI decision-making for specified categories, and appeals rights for individuals affected by AI-assisted decisions. Colorado, Connecticut, Illinois, and New York have enacted particularly comprehensive state government AI statutes, and California, Texas, and Washington have advanced pending legislation. CoreGuard's enforcement layer and decision certificate trail are designed to satisfy all common provisions across these state frameworks.
How CoreGuard Implements Government AI Governance
CoreGuard's government policy pack translates the abstract governance requirements of M-24-10, EO 14110, APA standards, and state AI laws into concrete, deterministic enforcement rules that operate before any AI-assisted decision affects an individual.
AI Recommendation Generated
A government AI system generates a recommendation — benefit eligibility determination, risk score, case classification, enforcement recommendation, or public-facing response. The raw AI output is intercepted before it enters the agency's decision workflow.
Pre-Decisional Governance Evaluation
The output is submitted to CoreGuard with the government policy pack. Evaluation runs: civil rights disparate impact check, constitutional minimum rationality check, protected characteristic bias detection, required disclosure verification, ADA accessibility check for public-facing outputs, and human oversight trigger assessment for high-impact decision categories.
Disposition and Human Oversight Routing
ALLOWED: Recommendation passes governance checks. Proceeds to agency workflow with certificate. MODIFIED — Human Review Required: Recommendation is in a high-impact category that requires human review per M-24-10. Output is queued for human reviewer; AI recommendation is advisory until human reviewer acts. BLOCKED: Civil rights violation or constitutional concern detected. Recommendation suppressed; exception created for agency counsel review.
M-24-10 Compliant Certificate Issued
Every governance decision produces a signed Decision Certificate structured for the agency's records management requirements. Certificates are retained per NARA schedule (minimum 7 years for program records), support FOIA production, and provide the pre-decisional documentation that APA administrative record requirements need for judicial review defense.
M-24-10 Mandate Implementation Mapping
The following shows how CoreGuard's enforcement capabilities map to specific M-24-10 minimum risk management practice requirements for AI that impacts rights or safety:
Sample: Human Oversight Hook in Action
FedRAMP authorization status: CoreGuard is pursuing FedRAMP Moderate authorization through the JAB process. Federal agencies may currently deploy CoreGuard under an Agency ATO using CoreGuard's NIST SP 800-53 Rev. 5 security control documentation package. For IL4/IL5 and classified system requirements, on-premises deployment documentation is available. Contact [email protected] for current authorization status and agency ATO support materials.
Frequently Asked Questions
CoreGuard is pursuing FedRAMP Moderate authorization through the JAB process. In the interim, federal agencies may deploy CoreGuard under an Agency Authority to Operate (ATO) using CoreGuard's security control documentation package mapping to NIST SP 800-53 Rev. 5 at the Moderate impact level. For agencies operating classified or CUI systems, CoreGuard supports on-premises deployment within agency IL2/IL4/IL5 environments. Contact our federal team at [email protected] for current authorization status.
OMB M-24-10 requires agencies to implement minimum risk management practices for AI impacting rights or safety. CoreGuard directly addresses these requirements: it provides the pre-decisional review mechanism M-24-10 requires for high-impact AI, the human override capability mandate, the incident tracking requirement, and the documentation standard for AI use case records. The CoreGuard decision certificate trail satisfies M-24-10's documentation requirements for AI decisions impacting individuals.
Government AI decisions affecting benefits, services, or enforcement must comply with Title VI of the Civil Rights Act, the ADA, and equal protection requirements. CoreGuard's government policy pack includes disparate impact detection rules that flag AI decisions producing statistically anomalous outcomes across protected class indicators, constitutional minimum rationality checks, and accessibility requirement enforcement for public-facing AI interactions. BLOCKED decisions for civil rights concerns are recorded in signed certificates that constitute the pre-decisional review record agencies need for administrative law compliance.
Yes. CoreGuard's government policy pack includes configurable human oversight hooks that trigger MODIFIED decisions requiring human review before any AI-assisted decision in designated high-impact categories proceeds to effect — including immigration benefit decisions, benefits eligibility determinations, law enforcement screening outputs, and decisions that would deny or reduce government services. All human review actions are recorded in the audit trail alongside the original AI recommendation.
Most enacted and pending state AI laws for government share common elements: algorithmic impact assessment requirements, mandatory human review for high-stakes decisions, appeals and redress rights, and transparency obligations. CoreGuard's policy pack supports all four elements. EVE Core maintains a current state AI law compliance mapping for states with enacted or pending government AI legislation, available to agencies on request.
Deploy AI in government with confidence.
Request a technical briefing with our federal and state government team. We'll walk through CoreGuard's M-24-10 compliance mapping, ATO support documentation, and on-premises deployment options for your specific agency environment.
Request a Briefing Enterprise and Government Pricing