OMB Memorandum M-25-22, "Driving Efficient Acquisition of Artificial Intelligence in Government," establishes the current Trump-administration framework for federal AI procurement. The memo applies to any contract awarded pursuant to a solicitation issued on or after September 30, 2025. Coverage from Inside Government Contracts, Wiley, and Brookings.

Scope — what counts as "AI"

M-25-22 applies to AI systems or services acquired by or on behalf of covered agencies (excluding the Intelligence Community). It explicitly includes data systems, software, applications, tools, or utilities established primarily for researching, developing, or implementing AI.

Many commercial SaaS products incorporate AI features but aren't AI-first. The memo's scope guidance is still being tested — vendors should assume broad applicability until agencies issue their specific implementation guidance.

Three policy themes

  1. Competitive American AI marketplace. Maximize use of U.S.-produced AI products and services. Expect Buy-American-like preference treatment in AI procurement.
  2. Safeguard taxpayer dollars. AI performance tracking and risk management baked into contracts. This likely means outcome-based service-level agreements rather than user-count licensing for AI tools.
  3. Cross-functional engagement. Procurement, mission owners, AI technologists, and compliance functions must all participate in AI acquisition — changing the agency buy team composition.

Vendor-specific implications

  • Privacy policies in OMB Circular A-130 must be respected throughout the AI lifecycle
  • Proper use of government data — contracts can restrict AI vendors from training on non-public government data without permission
  • Contractors' IP rights explicitly protected (a shift from some prior drafts)
  • GSA playbooks forthcoming on generative AI and AI-based biometrics procurement

GSA's implementation role

GSA is directed to publish:

  • AI procurement playbooks (generative AI, biometrics, plus general-purpose)
  • AI procurement guides for the acquisition workforce
  • An online repository for agency AI acquisition best practices

This mirrors the AI provisions in GSA MAS Refresh 31, which require vendor permission for training public AI on non-public government data.

What to do this week

  • If you sell any AI-enabled product, verify your proposal and contract language addresses the M-25-22 data-use requirements
  • Review your data-training pipeline for federal-customer data segregation — defaults matter
  • Watch for GSA AI playbooks; they'll define specific procurement language patterns

Sources