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Taking AI into production

Five decisions that decide whether a government AI pilot becomes a service, from a dozen proofs of concept in Australian agencies

Version 3.0November 5, 202615 min read3 downloads

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What happens to most government AI pilots

Most government AI proofs of concept end the same way. The system does what it was built to do, the team presents it, and nothing happens next. The Digital Transformation Agency (DTA) describes this in a scenario in its guidance on taking AI from proof of concept to scale.1 A data science team builds a model to find corporations with questionable registration information. The model works, but when the team presents it to leadership the project goes no further.

The reason the DTA gives has nothing to do with the model. Leadership "did not fully grasp how the model worked and were hesitant to trust an AI to support decision-making". The DTA's account names lack of trust, risk aversion, misaligned goals and the lack of a strong business case.

I have run about a dozen AI proofs of concept in Australian government over the past 2 years, mostly in state and territory agencies. Some became services an agency now runs. Others showed what they were built to show and were never taken into production. What separated them had little to do with the technology, which performed much the same either way. The difference was whether 5 decisions had been made, and whether they had been made early enough.

A dozen engagements is a small sample. Where a published study supports a point, I cite it so the reader can check. Where a point rests on my experience alone, I say so.

The paper is about systems built on large language models that answer from an agency's own documents. That is most of what agencies are piloting for legal and policy work. Two of the examples below involve other kinds of model. The same governance failures apply to them. The evaluation method in Decision 3 applies only to systems that write from source material.

About the author

I founded AccuFind, which builds retrieval-based AI for legal and policy work in government, and I ran the engagements drawn on here as its supplier. Before that I was Executive Director of Information Systems and Technology at South Australia Police, and a chief information officer for about 15 years.

Why pilots stop

The same problem shows up in 3 published sources. They are the DTA's own scenario, an audit of the Australian Taxation Office (ATO), and a randomised trial run by METR.

In the DTA scenario, a working model is not adopted because leadership does not trust it. The DTA's lesson from it is that "technical teams alone cannot carry an AI initiative", and that success requires business ownership and clear governance.2

The Australian National Audit Office (ANAO) examined AI governance at the ATO and found the arrangements only partly effective. As at August 2024, 74 per cent of the 43 AI models the ATO had in production lacked a completed data ethics assessment. There was no centralised inventory of AI in use. Nor was there evidence of structured and regular monitoring of the models the ATO had built and put into production.3 The ATO had models in production without the governance processes its own frameworks required.

METR ran a randomised controlled trial with 16 experienced open source developers across 246 real issues from their own repositories. Before the trial the developers expected AI to make them 24 per cent faster. The measured result was that they took 19 per cent longer, and afterwards they still believed they had been 20 per cent faster.4 The trial is small, and METR cautions readers against generalising from its setting. Even so, the tool slowed these developers down, and they did not notice.

In February 2026 METR said these results are out of date for later AI tools. Its follow-up repeats the point that matters here: developers' own estimates of their speed-up can be quite unreliable.

One randomised trial in early 2025, 16 developers, 246 real issues
+24%faster, expected before the trial
+20%faster, believed afterwards
19%longer, measured

I saw the same pattern repeatedly. The model performs as designed. But nobody is accountable for the decision it changes, and the existing process was never measured. Nobody can say how accurate the system is, and there is no budget to operate it. The pilot ends because none of those things was within its scope.

None of this needs a new assurance framework. The existing frameworks say to use the processes an agency already has. The NIST AI Risk Management Framework says AI risk management "should be integrated and incorporated into broader enterprise risk management strategies and processes".5 Australia's National framework for the assurance of AI in government says the same. "Existing decision-making and accountability structures should be adapted and updated to govern the use of AI."6 HM Treasury's guide on evaluating AI interventions says: "The key principles of robust impact evaluation are no different for AI interventions than for any other type of government programme."7

Every agency already has budget, benefits and evaluation processes. The 5 decisions below are the points at which a pilot has to connect with those processes. Each has a stage by which it must be made.

Which decision the system changes, and who owns it

Name the decision or process the system will change, and the person accountable for that decision today. If no such person exists, nobody will take ownership of the system after the pilot.

Most teams frame a pilot around a use case, which describes what the system will do. A use case does not name anyone who is worse off if the system never exists. So it can attract broad support from people who carry no responsibility for the outcome.

The DTA readiness checklist asks a more useful question than a use case does. It asks whether there is "a principal Business Owner involved that can ensure proposed outcomes are validated".8 The scenario at the start of this paper shows what happens without one.

Research on adoption made the same point more than 20 years ago. Greenhalgh and colleagues reviewed how innovations spread through service organisations. They separate adoption by individuals from take-up by the organisation. Take-up depends on the organisation's capacity to absorb change, spare resources, dedicated funding and leadership.9 A proof of concept scope leaves all of those out.

In my engagements, those that reached production had that person named before the build started. Most of those that stopped had an enthusiastic sponsor and no such person.

How to check

  • Name the decision, determination, assessment or task the system changes. One sentence, in the agency's own language.
  • Name the person accountable for that decision today, by role. If the role does not exist, stop here.
  • Confirm that person controls, or can reach, the operating budget the service would sit in.
  • Record what that person will do differently once the system is in use, and which current activities will stop.
  • Check the agency's AI use case register for the same problem already solved elsewhere.

How the current process performs

Measure the current process before anything is built: volume, time, effort and error rate. Without those numbers, results measured after the system is introduced cannot be compared with the previous process.

This is the cheapest of the 5 decisions and the one most often skipped, because the cost comes early and the benefit comes much later.

The METR trial shows why. People's reports of how much time they saved can be the opposite of the measured result, and they are not aware of the difference. A pilot with no baseline has to ask users whether the system saved them time. That is the one measure the trial showed to be unreliable.

The DTA guidance asks for this. Principle 5 requires AI initiatives to have "defined success metrics and baselines, systematic evaluation methods and pathways to value".10 It does not say how to establish a baseline, and in my experience nobody does unless someone insists before the build starts.

How to check

  • Record volume, elapsed time, effort and error or rework rate for the current process before the build starts.
  • Take the numbers from records the agency already keeps where possible, rather than from asking people.
  • Identify a comparison group, even an imperfect one. A comparison team that is not using the system gives better evidence than a larger sample of users alone.
  • Write down in advance what result would cause the agency to stop.
  • Say what the saved time is expected to be used for, and check afterwards whether it was.

Whether the system performs well enough

Score whether the output is supported by its source, and separately whether it is worth acting on. A demonstration using inputs chosen by the builders does not show how the system performs on real work.

A grounded system finds material and then writes from it. The method here is for that kind of system. Score whether the output is supported by the material it cites, and separately whether it is worth acting on. The first can be checked by anyone who can read the source. The second needs someone who knows the subject. Keeping them apart shows which part failed, and the 2 failures have different fixes. AccuFind has published the method it uses for this, including a variant for exploratory work where no gold standard exists.11 Other methods that keep the 2 questions apart will serve as well.

A general impression is not enough, because a model's performance varies between tasks in ways that cannot be predicted without testing. Dell'Acqua and colleagues ran a preregistered experiment with 758 consultants, in collaboration with Boston Consulting Group. On 18 tasks the model was capable of performing, people using AI completed 12.2 per cent more tasks and worked 25.1 per cent faster. On a task chosen to sit outside it, "subjects using AI were 19% less likely to produce correct solutions compared with those without AI".12 That is one task in one experiment. It shows that there are tasks a model performs poorly, without identifying which tasks those are. That is why each use case has to be evaluated separately.

Three-point scoring

This is our practice rather than a research finding. Given 5 options, evaluators who are unsure tend to pick the middle one. Those answers cannot be told apart from outputs that really are middling. We use 3: wrong, partly right, right. The 3 are easier to define in advance and easier for 2 scorers to agree on.

How to check

  • Score 2 axes separately: whether the output is supported by the source, and whether it is worth acting on.
  • Give the checkable axis to staff who can read the source material. It needs no subject expertise. Reserve subject matter experts for the judgement axis.
  • Have 2 people score a sample independently and report how often they agreed, even when agreement is low.
  • Evaluate the use case in question. Do not reuse a score from another task or another agency.
  • Record the questions the system got wrong, not only the proportion.

Whether to fine-tune a model or buy one

For work that depends on knowing the agency's documents, which covers most legal and policy work, buy a model and build retrieval around it. Fine-tuning is justified only in a few narrow cases.

Mistral's published method places building tailored models second of 4 steps, immediately after choosing the use cases.13 For a government agency working from its own documents, the model training in that step is usually the part to skip. The published evidence on how to give a model access to new factual material supports that.

The published comparison of the 2 approaches favours retrieval. Ovadia and colleagues found retrieval consistently outperformed continued pre-training for injecting new factual knowledge, and that fine-tuning on new facts can degrade performance.14 That is the finding most relevant to an agency whose material is legislation and policy.

Light fine-tuning is cheap. On narrow legal annotation tasks, a few hundred to a thousand labelled examples were usually enough to beat the frontier commercial models of the time.15 An agency that wants to try it on an open-weight model can afford to.

The cost that matters is the recurring obligation. A fine-tune is tied to a base model, and the vendor withdraws base models on its own schedule. OpenAI gives generally available models at least 6 months' notice, and it shut down a set of older models on 23 October 2026. It is also winding down self-serve fine-tuning. Organisations that had never fine-tuned could not start after 7 May 2026. From 6 January 2027, active customers will no longer be able to create new jobs.16 A vendor can withdraw the fine-tuning capability as well as the base model. Every base model change means redoing the tune, on top of the evaluation any deployment needs.

Open-weight models carry the same obligation for a different reason. The weights persist, so nobody can withdraw them. But a tuned model does not improve, while bought frontier models do, so an agency that wants current performance will need to re-tune periodically. Self-hosting adds hosting, patching and security assessment. Someone still has to maintain the evaluation set either way.

Privacy law applies as well. The Office of the Australian Information Commissioner treats training a model on personal information as a secondary use. That applies where training was not a primary purpose of collection. An entity that cannot establish the use is within reasonable expectations, and related to the original purpose, should seek consent, offer an opt-out, or both.17 That guidance applies under the Privacy Act. State agencies operate under their own privacy arrangements, which in South Australia are administrative rather than statutory, but the same question about secondary use arises.

The Commonwealth already provides bought models. GovAI, run by the Department of Finance, brokers models to Commonwealth agencies. Its chat app for Australian Public Service staff, GovAI Chat, ran an alpha trial from April to June 2026. A beta trial has run since July, and staff can use it if their agency has joined.18 A Commonwealth agency should check what it already has access to before building anything.

When tuning is warranted

I have seen 2 cases where tuning was justified, and in both the bought model could not do the task at all. First, where no available model can do the task, for example First Nations languages, subject to Indigenous data sovereignty principles and community agreement. Second, narrow, high-volume, repetitive classification where labelled data already exists and the task will not change. Neither describes an agency drafting or applying policy in English.

How to check

  • Establish what a frontier model with retrieval and structured prompting achieves on the task first. Any other option has to perform better than that result.
  • If fine-tuning is proposed, name in one sentence the capability gap it closes that retrieval cannot.
  • Price the recurring obligation as well as the build: who redoes the work on each base model change, and who maintains the evaluation set.
  • Check whether the training data includes personal information the agency holds for another purpose.
  • Check the whole-of-government arrangements before the proof of concept starts, not at the end.

What production costs, and who pays

Identify the operating budget the service will sit in. Name the person who owns the benefit from a business-as-usual role, and the process change the benefit depends on. Settle this before the pilot puts anything in front of real users.

Most of the pilots I have seen stop did so because this decision had not been made.

A proof of concept is usually paid for from an innovation line, a central pool or a discretionary budget. A production service needs ongoing money, which needs a costed benefits case, which needs the baseline from Decision 2 and the evaluation from Decision 3. An agency that skipped those cannot build the case. In my engagements the reasons given for stopping were usually about confidence, and the underlying obstacle was usually money.

The DTA checklist asks about this twice. After the proof of concept, it asks whether adequate funding is available. Before scaling, it asks whether adequate funding has been sought and approved for the pathway to production, and whether there is provision for top-up funding.8 Whether an agency can answer depends on who was named in Decision 1.

The benefit also has to belong to someone who is not on the project. The Commonwealth's benefits management guidance is explicit. The benefit owner "must hold a business as usual role in the organisation (as opposed to a project delivery role)".19 That guidance was written for digital and ICT investment generally, not for AI.

The lag between a technology and its measured benefit is well documented. Brynjolfsson, Rock and Syverson argue that general purpose technologies deliver measured productivity only after a lagged wave of complementary investment in process, skills and organisation. In their view this lag has likely been the biggest contributor to the productivity paradox.20

Two further costs belong in the production case and are usually missing. Where the work itself changes, consultation requirements under the agency's enterprise agreement or award apply before the change. And because vendors change and withdraw models on their own schedule, evaluation is a standing operating cost rather than a project activity.

The DTA's Scenario 6 shows a cost nobody budgeted for. A complaint triage model reached 85 per cent accuracy and could not be deployed. The model needed frequent training and updating. The agency's change management process required manual approvals for even minor code changes, and could not keep up. The lesson drawn is that AI development and IT modernisation "should be treated as a unified program".21

How to check

  • Name the operating budget line the service will sit in, and the person who controls it.
  • Name the benefit owner by role, and confirm the role is business-as-usual rather than project.
  • Write down the process change the benefit depends on, and get the owner of that process to agree in writing.
  • Cost the recurring items: evaluation, monitoring, support, and migration to successor models.
  • Cost the assurance steps that already apply: privacy impact assessment, security assessment, and an AI impact assessment where the agency requires one.
  • Check the consultation obligations that apply if the work changes, and start them before the change.
  • Confirm the procurement pathway from pilot to production, and whether the pilot contract allows it.
  • Confirm the production pathway before the pilot starts, while it is still cheap to change.

When each decision must be made

The DTA describes a 3-stage path: proof of concept, pilot, and release into production.22 Each of the 5 decisions has to be made by a fixed point on that path. The points are earlier than most project teams assume.

Each of the 5 decisions, the stage by which it must be made, and the evidence needed to make it.
DecisionMake it byEvidence needed
1. Which decision the system changes, and who owns itBefore the proof of concept startsThe decision named, and an accountable role that controls or can reach the budget
2. How the current process performsBefore the proof of concept startsVolume, time, effort and error rate, taken from existing records
3. Whether the system performs well enoughEnd of the proof of concept, repeated at pilot and continuing in productionTwo scores per output, a sample size, and the agreement rate between scorers
4. Whether to fine-tune a model or buy oneEnd of the proof of conceptWhat a bought option achieves on the task, and the gap any tuning would close
5. What production costs, and who paysBefore the pilot startsA named budget line, a benefit owner in a business-as-usual role, and an agreed process change

Decisions 1 and 2 are made before the proof of concept starts. That runs against the instinct that a proof of concept is cheap and exploratory, so the paperwork can wait. An agency can pull records of volume and elapsed time later. What people were doing, and how long each step took, cannot be recovered once they have used the system.

Decision 5 is made before the pilot. At that point the DTA checklist asks only whether funding is available, and it asks for funding to be approved before scaling. A pilot puts a system in front of real users on real data. Doing that without knowing who will pay builds an expectation the agency may not be able to meet.

How the 5 decisions relate to the DTA guidance

In March 2026 the DTA published Guidance for AI proof of concept to scale.23 It is a serious piece of work and it addresses this problem directly. It sets out the 3 stages, 8 principles, and 12 dimensions of transition, from business and strategic alignment through to AI types and fit-for-purpose selection.22 It gives 6 scenarios, and a readiness checklist that applies at 5 points in the lifecycle.

The checklist asks the right questions. It asks whether success criteria and measurable outcomes have been defined. It asks whether there is a baseline understanding of user needs and current workflows, and whether there is a principal business owner. It asks whether funding is available after the proof of concept, and whether it has been approved before scaling. Decision 5 asks for funding to be settled before the pilot. It asks whether a decision register has been established.8

The guidance leaves the method to the agency. Appendix 2 names 5 evaluation areas and offers tactics such as testing on edge cases and testing latency.24 Appendix 3 suggests indicators to include in procurement, such as accuracy, fairness, explainability and user satisfaction, and gives no method for measuring them.25 It does not give a baseline method, a scoring method or a register. The guidance describes itself as a complement to existing frameworks, to be adapted by agencies. That is a reasonable choice. It also means the method is the agency's to supply.

The checklist runs to about 60 questions. The 5 decisions are my reading of which of those questions stop a project if left unanswered, and when they have to be answered. The register published with this paper is a workbook. For each of the 5 decisions it records who owns it, the evidence needed, and the date it was made. It includes a baseline worksheet and the timing against the DTA stages. The checklist asks whether a decision register has been established. This workbook can serve as one, and can be downloaded from /resources/taking-ai-into-production/. Both are free to reuse and neither replaces the guidance.

What is different about AI

In most respects AI follows the path of earlier technology waves. Four things are different, and each has a precedent.

A user cannot tell from a model's outputs which tasks it can and cannot perform reliably. Automation complacency and automation bias are documented in aviation and clinical decision support.26 With AI the boundary moves with each model release and is not published, so an agency cannot tell staff where it sits.

Self-reported benefit can be wrong by a wide margin. What the METR trial shows is the size of the gap, and that it appeared among experienced users on their own work.

The system changes without notice. Software as a service also changes without the customer's control, but a regression test can detect those changes. A model that gives a different but still acceptable answer after an update will not fail a pass-or-fail test, so the change goes undetected.

Prompt injection has no general fix. The United Kingdom's National Cyber Security Centre wrote in 2023 that "at present, there are no failsafe security measures that will remove this risk". Its advice is to design systems so that a successful injection has limited effect, rather than to rely on detecting injections. Mitigations published since reduce the risk and do not remove it. SQL injection is the closest earlier analogue. The difference is that SQL injection has a reliable fix in parameterised queries.27

Each of those makes evaluation harder, and means evaluation continues after the project closes. None of them removes the need for a baseline, a benefit owner, a funding route, or a date by which each decision is made.

References

  1. Digital Transformation Agency, Guidance for AI proof of concept to scale: Scenario 5, Gap in business buy-in (Canberra: Australian Government, 2026). The quotation in the following paragraph is from the same page. digital.gov.au ↩
  2. DTA, Scenario 5, as above. digital.gov.au ↩
  3. Australian National Audit Office, Governance of Artificial Intelligence at the Australian Taxation Office, Auditor-General Report No. 26 of 2024-25 (Canberra: ANAO, February 2025). Model count as at 14 May 2024; assessment status as at August 2024. anao.gov.au ↩
  4. METR, Measuring the impact of early-2025 AI on experienced open-source developer productivity, 10 July 2025. Randomised controlled trial, 16 developers. metr.org. Update: METR, We are changing our developer productivity experiment design, 24 February 2026, which marks the 2025 results as out of date. metr.org ↩
  5. National Institute of Standards and Technology, Artificial Intelligence Risk Management Framework (AI RMF 1.0), NIST AI 100-1 (Gaithersburg: NIST, 26 January 2023). NIST AI 100-1 ↩
  6. Data and Digital Ministers Meeting, National framework for the assurance of artificial intelligence in government (Canberra: Department of Finance, 21 June 2024). Framework PDF ↩
  7. HM Treasury, Guidance on the impact evaluation of AI interventions, Magenta Book supplementary guide, first published 17 December 2024, updated 15 May 2026. gov.uk ↩
  8. Digital Transformation Agency, Guidance for AI proof of concept to scale: Appendix 1, AI readiness checklist. digital.gov.au ↩
  9. T. Greenhalgh, G. Robert, F. Macfarlane, P. Bate and O. Kyriakidou, 'Diffusion of innovations in service organizations: systematic review and recommendations', The Milbank Quarterly 82, no. 4 (2004): 581-629. Milbank Quarterly ↩
  10. Digital Transformation Agency, Guidance for AI proof of concept to scale: context and principles. digital.gov.au ↩
  11. AccuFind, Evaluating grounded AI systems, version 1.0, August 2026. /resources/evaluating-grounded-ai-systems/ ↩
  12. F. Dell'Acqua, E. McFowland III, E. Mollick, H. Lifshitz, K. Kellogg, S. Rajendran, L. Krayer, F. Candelon and K. Lakhani, 'Navigating the jagged technological frontier: field experimental evidence of the effects of artificial intelligence on knowledge worker productivity and quality', Organization Science 37, no. 2 (2026): 403-423. Run in collaboration with Boston Consulting Group, with BCG co-authors. DOI, working paper at SSRN ↩
  13. Mistral AI, Our method, accessed 5 November 2026. It replaces the page cited in earlier versions of this paper, mistral.ai/ai-transformation/, which no longer exists. mistral.ai/our-method/ ↩
  14. O. Ovadia, M. Brief, M. Mishaeli and O. Elisha, 'Fine-tuning or retrieval? Comparing knowledge injection in LLMs', Proceedings of EMNLP 2024. ACL Anthology ↩
  15. R. Dominguez-Olmedo, V. Nanda, R. Abebe and others, 'Lawma: the power of specialization for legal annotation', International Conference on Learning Representations (ICLR) 2025. The figure quoted is from the revised version, arXiv:2407.16615v2, 23 April 2025. arXiv ↩
  16. OpenAI, Deprecations, developer documentation, accessed 5 November 2026. developers.openai.com ↩
  17. Office of the Australian Information Commissioner, Guidance on privacy and developing and training generative AI models, 21 October 2024, updated 23 October 2024. oaic.gov.au ↩
  18. Department of Finance, GovAI Chat, last updated 3 November 2026, accessed 5 November 2026. govai.gov.au ↩
  19. Digital Transformation Agency, Benefits Management Policy: guidance, accessed 5 November 2026. digital.gov.au ↩
  20. E. Brynjolfsson, D. Rock and C. Syverson, Artificial intelligence and the modern productivity paradox: a clash of expectations and statistics, NBER Working Paper 24001, November 2017. NBER ↩
  21. Digital Transformation Agency, Guidance for AI proof of concept to scale: Scenario 6, New AI model and legacy systems. digital.gov.au ↩
  22. Digital Transformation Agency, Guidance for AI proof of concept to scale: AI transition stages and dimensions. digital.gov.au ↩
  23. Digital Transformation Agency, Guidance for AI proof of concept to scale (Canberra: Australian Government, 2026). Released 11 March 2026, the date of the DTA media release New guidance to support AI project success. The landing page gives the same date as its last update. digital.gov.au ↩
  24. Digital Transformation Agency, Guidance for AI proof of concept to scale: Appendix 2, AI evaluation. digital.gov.au ↩
  25. Digital Transformation Agency, Guidance for AI proof of concept to scale: Appendix 3, Informing procurement. digital.gov.au ↩
  26. R. Parasuraman and D. H. Manzey, 'Complacency and bias in human use of automation: an attentional integration', Human Factors 52, no. 3 (2010): 381-410. doi.org ↩
  27. UK National Cyber Security Centre, Thinking about the security of AI systems, 30 August 2023, ncsc.gov.uk; and Prompt injection is not SQL injection (it may be worse), 8 December 2025, ncsc.gov.uk. ↩

Version 3.0, 5 November 2026. Hamish Cameron, AccuFind Pty Ltd. The 5 decisions and the register are free to reuse.

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A pilot that has reached the end?

AccuFind builds grounded legal and policy AI for Australian government, and runs the baseline and evaluation work described here inside its engagements. The 5 decisions and the register are free to reuse.