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Model act · GAAFA

Government Algorithmic Accountability and AI Fiduciary Act

GAAFA governs computational power. AI may increase government's capacity to execute lawful authority; it does not enlarge that authority.

Version 2.2 · Clean restated legislative candidate · September 2026 · Model legislation, not enacted law

In brief

GAAFA regulates what a system actually does, its authority, consequences, provenance and accountability, rather than banning or mandating particular model families by label. Its governing construction: technical ability to infer does not create authority to infer.

  • Boundary inheritance. AI systems inherit the authority limits of the governmental function they serve. Software is not a fiduciary or a source of authority; accountable people and agencies remain responsible (Section 5).
  • Classification by use. Systems are classified by actual use and consequence, with baseline requirements for each tier (Sections 7 and 8).
  • Authority before deployment. Algorithmic authority and deployment assessment, purpose and question particularity, and provenance for features, models, training and grounding data (Sections 9 to 11).
  • No capability laundering. Commercial scores and outputs do not become authorized governmental knowledge because a vendor produced them (Sections 13 and 34).
  • Rights of affected people. Meaningful human judgment, decisional explanation, notice of automated involvement, contestability and correction, including correction of derived inferences (Sections 14 to 18).
  • Analytics with limits. Population-scale analytics may serve legitimate purposes, but scale does not create authority to search for unspecified patterns. Purpose-bounded enclaves, separation of analytics from adjudication, and limits on signal retention (Sections 20 to 24).
  • Agents and assistants. Specific rules for agentic and tool-using AI, citizen-facing assistants, official-source grounding and synthetic media (Sections 29 to 32).

Section map

SectionsWhat they do
1–6Title, findings, definitions, relationship to PDTA, VIDA and FCGIAS; AI boundary inheritance; governmental informational operations.
7–13Classification by actual use and consequence; tier baselines; authority and deployment assessment; purpose and question particularity; provenance; vendor predeployment assessment; commercial outputs.
14–19Meaningful human judgment; decisional explanation; notice; contestability and independent review; correction; material derived inference.
20–25Bounded discovery; purpose-bounded analytics enclaves; hypothesis-generating analytics; analytics-adjudication separation; signal retention; composite machine action.
26–32Lifecycle impact assessment; civil-rights and disparate-outcome testing; drift and reauthorization; agentic systems; citizen-facing AI; accuracy and grounding; synthetic media.
33–38Procurement and vendor obligations; capability laundering; DTA oversight; conformance; transparency registry; auditability and records.
39–43Enforcement and remedies; legacy transition through PDTA Section 28; review; severability; effective date 180 days after enactment.

Text

  • GAAFA Version 2.2, full textPDF Word

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