Comptroller Compliance Report
AI Governance Response — Office of the State Comptroller Audit 2024-S-4
AI Governance Compliance Report
State of New York
Response to OSC Audit 2024-S-4 & NYS-P24-001 Compliance Status
Prepared by: Office of Information Technology Services
Submitted to: Office of the State Comptroller, Legislature
Policy framework: NYS-P24-001, NIST AI RMF
Report date: March 20, 2026
Reporting period: FY 2026
RAISE Act status: Active compliance
Comptroller Audit Response Required
OSC Audit 2024-S-4 found that ITS lacks a complete inventory of AI tools in use across state agencies and has not established adequate governance frameworks. This report documents remediation progress toward the July 2026 response deadline.
Executive Summary
In response to the State Comptroller's audit finding that New York State lacks comprehensive oversight of AI systems, ITS has initiated a statewide AI inventory and governance program aligned with NYS-P24-001 and the NIST AI Risk Management Framework. As of the reporting date, 15 of 108 state agencies have been onboarded to the inventory system, with 5 having completed their submissions. A total of 60 AI systems have been registered, of which 21 are classified as consequential decision systems requiring enhanced oversight under NYS-P24-001 Section 3.2.
The RAISE Act (S.145/A.501) requires additional bias testing and transparency obligations for automated employment decision tools. Currently, 18 of 60 systems have completed bias audits, and 20 are aligned with the NIST AI RMF.
60
AI Systems Registered
19
High/Critical Risk
33%
NIST RMF Aligned
97%
Human Oversight
Agency-by-Agency Breakdown
| Agency | Systems | High Risk | Assessed | Status |
|---|---|---|---|---|
| Office of Information Technology Services | 6 | 0 | 5/6 | Submitted |
| Department of Motor Vehicles | 5 | 3 | 4/5 | Submitted |
| Department of Labor | 7 | 2 | 5/7 | Submitted |
| Department of Taxation & Finance | 4 | 2 | 3/4 | Submitted |
| Department of Financial Services | 3 | 1 | 3/3 | Submitted |
| Dept. of Corrections & Community Supervision | 4 | 3 | 0/4 | Incomplete |
| Department of Transportation | 5 | 0 | 0/5 | Incomplete |
| Office for the Aging | 2 | 0 | 0/2 | Incomplete |
| Department of Health | 8 | 2 | 0/8 | Overdue |
| Office of General Services | 3 | 0 | 0/3 | Overdue |
| Dept. of Environmental Conservation | 4 | 0 | 0/4 | Overdue |
| Office of Children & Family Services | 3 | 3 | 0/3 | Overdue |
| Division of Homeland Security & Emergency Services | 2 | 1 | 0/2 | Not Started |
| Department of State | 1 | 0 | 0/1 | Not Started |
| Office for People with Developmental Disabilities | 3 | 2 | 0/3 | Not Started |
| Total | 60 | 19 | 20/60 |
Audit Remediation & Compliance Gaps
Comptroller Finding: Incomplete AI Inventory (93 agencies outstanding)
OSC Audit 2024-S-4 found ITS has no complete inventory of AI tools. Currently 15 of 108 agencies have been onboarded. Remaining agencies must complete registration by the July 2026 response deadline.
Overdue Agency Submissions (4 agencies)
Department of Health, Office of General Services, Dept. of Environmental Conservation, Office of Children & Family Services have not completed their AI inventory submissions. ITS recommends direct outreach and dedicated technical assistance for these agencies.
RAISE Act Compliance: Bias Testing Gap
42 of 60 registered systems have not completed bias audits required under the RAISE Act. Priority should be given to the 21 consequential decision systems that directly affect individuals' rights, benefits, and employment.
NIST AI RMF Alignment Gap
Only 20 of 60 systems (33%) are aligned with the NIST AI Risk Management Framework as required by NYS-P24-001. ITS will prioritize alignment for the 19 high/critical risk systems.
DIGIT Office Coordination
The newly established Division for Innovation, Government, and Technology (DIGIT) announced in the 2026 State of the State will coordinate AI governance alongside ITS. Governance reporting structures will be updated upon DIGIT's operational launch.
This report was generated from the ITS AI Governance Dashboard. For questions, contact the Office of Information Technology Services.
Note: This is a demo. In production, reports would be generated from live data and include full compliance documentation per OSC audit requirements.