Compliance Stuff

The Administration’s 2026 AI Action Plan foreshadowed broad efforts to bring Artificial Intelligence (AI) capabilities to government. Now, the General Services Administration (GSA), which leverages government-wide purchasing power, is proposing a new, required clause, GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems, in all solicitations and contracts in which Artificial Intelligence (AI) capabilities are either (a) provided to the government or (b) used by the contractor as part of performance of the contract. The plain language of the draft clause also indicates that its compliance scheme applies to contractors doing business with GSA and also commercial AI service providers supporting GSA contractors. GSA published the draft clause on March 6, 2026, as part of the advance notice for Multiple Award Schedule (MAS) Solicitation Refresh 31 (Solicitation No. 47QSMD20R0001) , at buy.gsa.gov. GSA now seeks public and industry comment on the proposed new clause by ...

States are playing a critical role in the development of AI policy in the United States, as serious legislative efforts at the federal level remain stalled. The Trump Administration and Republican Congress have signaled they plan to take a business-friendly, light-touch approach to AI regulation that prioritizes American innovation and emphasizes competition with China, and there is little prospect of Congress moving a substantive AI bill in the current political climate . Instead, states are moving to fill the federal void by taking up a flurry of AI bills to ensure that—amid AI innovation—regulators also create “guardrails” around uses of AI and that consumers can identify AI-generated content. Much like state legislatures, state attorneys general will likely focus on AI issues as they intersect with consumer protection concerns, including privacy. This alert focuses on the major actions that have occurred thus far in 2025 and how we expect the state regulatory landscape to act as th...