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

Properties

jurisdiction: US Federal
level: federal
domain: general
status: in-effect
scope: Binding OMB memorandum governing how all federal agencies procure AI systems and services, including requirements on data handling, IP rights, performance testing, and privacy that flow down to AI vendors through contract terms.
obligations: Agencies must: include contract terms that clearly delineate data ownership and IP rights, ensuring agency information used to train or fine-tune AI is handled appropriately; establish policies ensuring compliance with privacy laws; update internal acquisition procedures within 270 days; convene cross-functional teams for AI procurements; maximize use of American-made AI. Applies to any contract awarded pursuant to a solicitation issued on or after 180 days after April 3, 2025 (i.e., on or after September 30, 2025), and to contract renewals after that date. Rescinds and replaces OMB M-24-18.
effectiveDate: 2025-04-03
enactedDate: 2025-04-03
appliesTo: All federal executive branch agencies procuring AI systems or services; AI vendors and contractors supplying AI to the federal government via contracts subject to this memorandum
officialUrl: https://www.whitehouse.gov/wp-content/uploads/2025/02/M-25-22-Driving-Efficient-Acquisition-of-Artificial-Intelligence-in-Government.pdf
notes: Issued in tandem with M-25-21 on April 3, 2025. The 'AI system' definition (from the Advancing American AI Act) covers data systems, software, applications, tools, or utilities established primarily for researching, developing, or implementing artificial intelligence technology, but excludes common commercial products where AI is embedded incidentally (e.g., word processors).

Properties

jurisdiction

US Federal

level

federal

domain

general

status

in-effect

scope

Binding OMB memorandum governing how all federal agencies procure AI systems and services, including requirements on data handling, IP rights, performance testing, and privacy that flow down to AI vendors through contract terms.

obligations

Agencies must: include contract terms that clearly delineate data ownership and IP rights, ensuring agency information used to train or fine-tune AI is handled appropriately; establish policies ensuring compliance with privacy laws; update internal acquisition procedures within 270 days; convene cross-functional teams for AI procurements; maximize use of American-made AI. Applies to any contract awarded pursuant to a solicitation issued on or after 180 days after April 3, 2025 (i.e., on or after September 30, 2025), and to contract renewals after that date. Rescinds and replaces OMB M-24-18.

effectiveDate

2025-04-03

enactedDate

2025-04-03

appliesTo

All federal executive branch agencies procuring AI systems or services; AI vendors and contractors supplying AI to the federal government via contracts subject to this memorandum

officialUrl

https://www.whitehouse.gov/wp-content/uploads/2025/02/M-25-22-Driving-Efficient-Acquisition-of-Artificial-Intelligence-in-Government.pdf

notes

Issued in tandem with M-25-21 on April 3, 2025. The 'AI system' definition (from the Advancing American AI Act) covers data systems, software, applications, tools, or utilities established primarily for researching, developing, or implementing artificial intelligence technology, but excludes common commercial products where AI is embedded incidentally (e.g., word processors).