Current OMB Requirements for Federal AI Use and Procurement
The rules surrounding government agency use of artificial intelligence (“AI”) have changed. On April 3 rd , 2025, in accordance with President Trump’s January 23 rd Executive Order regarding AI, the Office of Management and Budget (“OMB”) issued M-25-21 and M-25-22 , reshaping how federal agencies must use, inventory, and buy AI technologies. These sweeping memoranda rescind and substitute the Biden-era OMB memos M-24-10 and M-24-18 , ushering in a full regulatory buildout that prioritizes US-developed AI, mandates risk assessments for AI that may have significant impacts on Americans, and introduces new source-selection and intellectual property (“IP”) language into Requests for Proposals (“RFPs”). M-25-21: How Agencies Must Use AI OMB Memorandum M-25-21 requires agencies to bring structure and transparency to how they use AI— not just in future programs, but with AI tools currently in use as well . By July 2 nd , 2...