OMB Memorandum M-25-22: Driving Efficient Acquisition of Artificial Intelligence in Government

Summary

Guidance from the Office of Management and Budget to help federal agencies acquire AI responsibly. It rescinds and replaces M-24-18. It sets requirements across the acquisition lifecycle, including cross-functional teams, privacy, intellectual property and government data protections, vendor lock-in safeguards, testing and monitoring, and preference for American-made AI.

Who it applies to

Applies to all agencies defined in 44 U.S.C. § 3502(1), covering AI systems or services acquired by or on behalf of them. Excludes Intelligence Community elements, AI acquired as a component of a National Security System, and common commercial products with embedded AI.

Key points

• Agencies must update internal acquisition procedures within 270 days of the memorandum's issuance.
• Contracts must permanently prohibit use of non-public agency data to further train publicly or commercially available AI algorithms absent explicit agency consent.
• Agencies must disclose in solicitations, when practicable, whether a planned AI use is high-impact.
• Contracts must ensure compliance with minimum risk management practices for high-impact use cases under M-25-21.
• GSA is to develop a plan for AI procurement guides within 100 days and a repository within 200 days.

Key dates

Signed / adopted

Apr 3, 2025