Federal Agencies Roll Out AI Strategy Plans: Takeaways For Government Contractors

On April 3, 2025, the White House Office of Management and Budget (OMB) released two memoranda, M-25-21 and M-25-22, regarding federal agencies' use and acquisition, respectively, of artificial intelligence (AI) systems. Among other strategies oriented towards the Trump administration's priorities of driving AI innovation, M-25-21 and M-25-22 require “covered agencies”—“any executive department, military department, Government corporation, Government controlled corporation, or other establishment in the executive branch of the Government ... or independent regulatory agency,” subject to specific exclusions as set forth in 44 U.S.C. § 3502(1)—to (1) publish, by September 30, 2025, an AI Strategy identifying and removing barriers to responsible AI use, and (2) issue, by December 29, 2025, detailed policies setting the terms for acceptable use and procurement of AI.