OMB Memos on Federal Agency AI Use

OMB memoranda translate federal policy and statutes into directions for agencies. They can set deadlines, responsibilities and minimum processes, but their audience and scope are defined in each document. An agency should not assume that one AI memo covers every technology, mission or national-security system, and private organizations should not treat federal internal guidance as a general law that directly governs them. OMB Memorandum M-25-21, issued in April 2025, sets out governance, innovation and public-trust requirements for covered agency AI use. It rescinded and replaced the prior M-24-10. It addresses AI developed, used or acquired by or for covered agencies, including agency governance, use-case inventories and additional requirements for high-impact uses. The memo describes high impact in terms of outputs serving as a principal basis for decisions or actions with legal, material, binding or significant effects on rights or safety. The specific implementation rules and exceptions must be read in the memorandum itself. M-25-22, issued the same day, addresses federal AI acquisition and replaced M-24-18. It focuses on how agencies buy AI, including competition, data portability, interoperability and contract terms. M-26-04, dated December 2025, sets Unbiased AI Principles for covered agency use of large language models and complements M-25-21 and M-25-22. It has its own defined agency and model scope and excludes national-security systems as specified in the memo. These documents are related, but their requirements are not identical. The OMB memorandum index is important because guidance can be revised, rescinded or supplemented. A sound summary identifies the memo number, issue date, covered agencies, technology, requirement, exceptions and any later amendment. When a requirement conflicts with another law or policy, agencies must resolve that through authorized legal and policy channels rather than choosing whichever memo is easier. Public versions of inventories and reporting may have their own exceptions. Always consult current official text and agency implementation materials. Legal offices should review edge cases.