Federal AI Identity Governance

Applying identity governance to the M-25-21 AI Use Case Inventory — a standalone kit and an FMP-governed path

Author

Michael Stratton

Published

June 1, 2026

Federal AI Identity Governance

Federal agencies have deployed over 1,800 AI systems under OMB M-25-21 — and almost none of those systems are governed at the identity layer. No organizational placement. No owned credential. No lifecycle process. This kit closes that gap.

It is runnable two ways:

  • a manual path — a standalone agency runbook that applies M-25-21 identity governance without any external control plane; and
  • a the Federal Modernization Program-governed path — the same outcome, with every AI system’s identity record bound to the drift engine and the ATO reciprocity model.
TipDownload the runnable kit

Invoke-AIInventoryScan.ps1 scans your agency’s OMB inventory extract for identity governance gaps and produces a prioritized findings report. No external dependencies; runs anywhere PowerShell 7 is available.

NoteThe problem this kit solves

The OMB 2025 Federal AI Use Case Inventory has no fields for identity governance: no service account, no credential tier, no owner, no organizational placement. This kit adds that layer — making the invisible identity surface visible before it becomes a breach surface.

What the kit does

Phase What runs Output
1 — Inventory Download or load OMB CSV; parse all deployed and pilot entries Structured record set
2 — Scan Detect six identity governance gaps per M-25-21 obligations Findings list with severity (P1 / P2) and drift class
3 — Report Produce a prioritized HTML or CSV findings report Actionable gap list, ATO cross-walk, shadow AI candidates
4 — Remediate (governed) Owner assignment, ATO reciprocity lookup Updated identity records in the Federal Modernization Program registry

Who this is for

Agency identity governance teams running a M-25-21 compliance program who need to verify that their inventoried AI systems have identity governance coverage.

Federal ISSO/AO staff reviewing ATO packages for AI systems who need to confirm that the credential lifecycle is documented.

OMB/OFCIO program staff evaluating whether the 2026 inventory schema should add identity governance fields. This kit demonstrates what those fields would enable.

Background reading

The Federal AI Governance — Submission Readiness Brief names this kit as the path to operationalizing the DRIFT-COMPLIANCE::ai-agentic-ungoverned P1 finding.

The normative specifications are:

Deployment options

The kit ships as open-source Python and PowerShell. No managed service or external control plane is required to run it.

Standalone (any agency, no the Federal Modernization Program dependency): Run Invoke-AIInventoryScan.ps1 against your OMB inventory extract. All six finding types are produced without connecting to any external system.

Governed (the Federal Modernization Program adopters): The ai-inventory-governance adapter slot (adapter-registry.yaml) binds scanner output to the drift engine and the the program decision ATO reciprocity model. See governed path for activation steps.

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