Two of the Ministry of Justice's AI tools publish how likely they are to get a decision wrong. Two more, including the one used in over 1.6 million meetings with people on probation, are not on the government's public register of algorithms at all.
Estimated reading time: 7 minutes
In short. The Ministry of Justice published a one-year review of its AI Action Plan for Justice on 24 September 2026, naming four "non-generative AI" tools now live across probation, prisons and courts [1]. It says "the MOJ requires all AI tools to be tested and evaluated for accuracy, bias, fairness, security and reliability before widescale deployment" [1]. Two of the four named tools, a prison violence estimator and a facial-recognition identity check for probation check-ins, have a public record on the government's Algorithmic Transparency Recording Standard, the mechanism built for exactly this claim [6] [7]. The other two do not appear on the register at all: Acquisitive Crime Mapping, which cross-references the GPS location of people on probation against police crime data, and Justice Transcribe, the department's own flagship tool, used by over 12,000 probation officers to transcribe and summarise more than 1.6 million supervision meetings [1] [5]. Three documented mistakes: four stars.
The Ministry of Justice can show its working on facial recognition. The public record for its probation check-in service states plainly that the system compares a video submission against a reference image using Amazon's Rekognition software, and warns that "as with many facial recognition technologies, there may be variations in accuracy across different demographic groups" [6]. It can show its working on a prison violence risk score too: a public record explains that the tool is "an implementation of an Explainable Boosting Machine," trained on age and custodial history, and warns staff it "must be used with caution and in context, not as a definitive measure" [7]. Both records sit on the Algorithmic Transparency Recording Standard (ATRS), the government's own public register for exactly this kind of tool, mandatory across every ministerial department since 6 February 2024 [3].
The department's one-year review of its AI Action Plan for Justice, published 24 September 2026, names two more operational tools in the same paragraph as those first two. Neither has a public ATRS record.
The tools the plan names, and what the register shows
The action plan groups four tools under one heading, "non-generative AI to support frontline decision-making," and says they are "now live across probation, prisons and courts" [1]:
- Violence in Prisons Estimator, which "uses predictive analytics to assess the risk of involvement in violent incidents in custody" [1] - has an ATRS record [7].
- Online Probation Check-ins, "an online check-in platform that uses facial recognition to support identity verification of people on probation" [1] - matches, function for function, the ATRS record for "Check-In with your probation officer (E-Supervision)" [6].
- Acquisitive Crime Mapping, "a tool which matches GPS location data of people on probation with police crime data to support targeted investigation and prioritisation" [1] - no ATRS record under this or any similar name.
- Justice Transcribe, described elsewhere in the same document as the department's "flagship tool" for probation, using "speech recognition" to "transcribe, summarise and structure records from probation supervision sessions and case interactions," scaled to "over 12,000 probation officers" [1] - no ATRS record under this or any similar name.
The register itself is public and searchable. Reading through all 153 records live on it on 25 September 2026 finds eleven from the Ministry of Justice family, including HM Courts and Tribunals Service and the Crown Prosecution Service, and confirms the pattern above: the prison violence tool and the probation facial-recognition check are both there; the crime-mapping tool and the transcription tool are not, under any title [5].
What the register is actually for
The ATRS is not a voluntary courtesy. The policy that made it mandatory sets out precisely which tools must be recorded: those with "a significant influence on a decision-making process with public effect," or that "directly interact with the general public" [4]. It gives worked examples on both sides of that line. In scope: "a tool intaking and being used to analyse text submitted by members of the public, with the tool providing a summary to then be read by humans who will take decisions based on that information" [4]. Out of scope: "ad-hoc usage of large language models, such as Microsoft Copilot being used by individual civil servants internally within an organisation to transcribe and summarise meetings," because that carries "no significant decision or direct public interaction" [4].
Justice Transcribe does not transcribe internal civil service meetings. It transcribes and summarises probation supervision sessions, meetings between a practitioner and a person on probation, and the plan itself says the resulting record is used because "timely, accurate record-keeping is essential to managing risk and supporting rehabilitation" [1]. That is a summary of a member of the public's own meeting, feeding a case record used to manage risk decisions about them, closer to the standard's in-scope example than its ad-hoc-Copilot exclusion. Acquisitive Crime Mapping fits the standard's other in-scope category even more directly: a tool that uses location and crime data "to score or risk profile a person" for "decisions such as who or what to search or check" [4], a description the plan's own text matches almost word for word.
The claims, tested
| The plan's own words | What checking the citation shows | Verdict |
|---|---|---|
| "The MOJ requires all AI tools to be tested and evaluated for accuracy, bias, fairness, security and reliability before widescale deployment, with ongoing performance monitoring in place" [1] | The cited basis for this, the MOJ AI and Data Science Ethics Framework, is completed by the same team building the tool, with no independent sign-off, and states plainly that it "does not replace" a data protection impact assessment [2] | A self-assessment, not an independent test |
| Four operational AI tools are "now live across probation, prisons and courts" [1] | Two of the four have a public Algorithmic Transparency Recording Standard record; two, including the highest-volume one, do not appear on the register at all [5] | Coverage the plan does not mention is partial |
| The department "established key governance and oversight mechanisms" including "a cross-departmental, cross-functional AI Steering Group and a Risk Working Group" and "an internal portfolio tracking tool" [1] | Every mechanism named is internal to the department; the only public-facing accountability document for any of these tools is the ATRS record, and it exists for two of the four | Oversight that the public cannot see or check |
The mistakes, counted
Two of the plan's own four named tools are missing from the mandatory register (1). Justice Transcribe and Acquisitive Crime Mapping both fit the scope policy's own in-scope worked examples more closely than its narrow ad-hoc-transcription exclusion, yet neither has a public ATRS record under any name, while the other two tools named in the same paragraph do.
The blanket testing claim rests on a self-graded exercise (2). The plan's claim that all AI tools are "tested and evaluated for accuracy, bias, fairness, security and reliability before widescale deployment" cites the MOJ AI and Data Science Ethics Framework as the mechanism. That framework's own introduction document says responsibility for completing it "lies with the project team," names no independent reviewer, and explicitly does not replace a data protection impact assessment, which is a separate process this document does not show has been published for any of the four named tools [2].
The oversight described is entirely internal (3). The AI Steering Group, Risk Working Group and portfolio tracking tool the plan credits with "senior oversight, risk management and collaboration" produce nothing a member of the public, a defence solicitor or a probation client can read [1]. The only mechanism in this entire document that does is the ATRS record, and it is missing for the two tools with the widest reach into individual cases.
Credit where due
This is not a department that refuses transparency in principle. Two of its own tools prove the opposite is possible: the facial-recognition record volunteers a demographic-accuracy caveat most organisations would rather not put in writing, and the prison violence tool's record explains its model type, its training data and its limits in plain language, stating outright that "no punitive decisions or automated decisions are taken solely on the basis of the tool's estimates" [6] [7]. Justice Transcribe is not entirely unreported either: the department publishes usage volumes for it separately, most recently showing over 1,600,000 meetings summarised by 14 September 2026, a slightly higher figure than the 1.5 million the action plan itself cites for the same end date [8]. That data is real and checkable. It answers how much the tool is used. It does not answer the question the ATRS exists to answer, which is how the tool was tested and what its risks are, and its own text says its quality checks covered "validation of counting logic," not the transcription tool's accuracy or bias [8].
Verdict
Four stars, from three documented mistakes. The Ministry of Justice has already shown, twice, that publishing exactly the kind of assurance its action plan claims for every tool is not hard. It has not done it for the tool with the most reach into individual case records, or for the one that cross-references a probation caseload against crime scene data. A plan whose own strategic priorities include making "transparency a cornerstone" of AI adoption is, on its own register, only half right.
Sources
- Ministry of Justice, "AI action plan for justice: one year on" (policy paper, published 24 September 2026, checked 25 September 2026). https://www.gov.uk/government/publications/ai-action-plan-for-justice-one-year-on/ai-action-plan-for-justice-one-year-on - landing page: https://www.gov.uk/government/publications/ai-action-plan-for-justice-one-year-on
- Ministry of Justice, "Introduction to the MOJ AI and Data Science Ethics Framework" (PDF, checked 25 September 2026). https://assets.publishing.service.gov.uk/media/683f16077cbfa6ac6e0d32dd/1._MoJ_AI___Data_Science_Ethics_Framework_Introduction_Booklet.pdf - landing page: https://www.gov.uk/government/publications/ministry-of-justice-ai-and-data-science-ethics-framework
- Government Digital Service, "Algorithmic Transparency Recording Standard (hub)" (collection page, checked 25 September 2026). https://www.gov.uk/government/collections/algorithmic-transparency-recording-standard-hub
- Cabinet Office and Department for Science, Innovation and Technology, "Algorithmic Transparency Recording Standard: mandatory scope and exemptions policy" (guidance, checked 25 September 2026). https://www.gov.uk/government/publications/algorithmic-transparency-recording-standard-mandatory-scope-and-exemptions-policy/algorithmic-transparency-recording-standard-atrs-mandatory-scope-and-exemptions-policy
- GOV.UK, "Algorithmic transparency records" (register, 153 records checked 25 September 2026). https://www.gov.uk/algorithmic-transparency-records
- Ministry of Justice, "Check-In with your probation officer (E-Supervision)" (algorithmic transparency record, checked 25 September 2026). https://www.gov.uk/algorithmic-transparency-records/moj-check-in-with-your-probation-officer-e-supervision
- HM Prison and Probation Service, "Violence in Prisons Estimator" (algorithmic transparency record, checked 25 September 2026). https://www.gov.uk/algorithmic-transparency-records/hmpps-violence-in-prisons-estimator
- Ministry of Justice, "Justice Transcribe data: 7 October 2025 to 14 September 2026" (transparency data, checked 25 September 2026). https://www.gov.uk/government/publications/justice-transcribe/justice-transcribe-data-7-october-2025-to-14-september-2026 - landing page: https://www.gov.uk/government/publications/justice-transcribe