Agency direction
OMB M-25-22 and M-26-04 for contractors
Agency policy and a contractor obligation are different steps in the review.
Identify the acquisition context
M-25-22 provides AI acquisition direction to agencies. M-26-04 addresses agency LLM use and acquisition through its principles and implementation guidance.
Trace the actual obligation
Review the solicitation, contract and subcontract flowdowns that implement applicable requirements. Do not assume every internal assistant is subject to the same terms.
Keep the explanation with the decision
A useful applicability record identifies the source, version, contract alias, relevant use and reviewer. Put unresolved interpretations on the attorney review list.
Primary sources
Reviewed October 17, 2026. Recheck before relying on a finding.
Start with what you know
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