OMB Memorandum M-25-22: Driving Efficient Acquisition of Artificial Intelligence in Government
The procurement companion to M-25-21, replacing M-24-18. Sets what federal agencies must require of AI vendors, and so functions as a de facto baseline questionnaire for anyone selling AI into government.
Overview
Issued on 3 April 2025, this memorandum rescinded and replaced M-24-18 and governs how federal agencies buy AI. Its requirements attach to contracts awarded under solicitations issued on or after 30 September 2025, and to renewal options or extensions exercised on or after 1 October 2025, so it reaches existing vendor relationships at their next decision point rather than only new ones. For private-sector buyers it is worth reading as a published benchmark: it is the clearest public statement of what a very large, risk-averse purchaser now asks AI vendors to evidence.
Key dates
- Apr 3, 2025Issued, rescinding and replacing M-24-18
- Sep 30, 2025Applies to solicitations issued on or after this date
- Oct 1, 2025Applies to renewals and extensions exercised on or after this date
Risk areas addressed
Who it applies to
Federal contracting officers and programme owners, and any vendor whose AI product or service is sold to a federal agency, including through a reseller or as an embedded feature.
Key obligations
- Reflect the memorandum's AI acquisition requirements in agency acquisition policies, procedures and practices.
- Apply the requirements to solicitations issued on or after 30 September 2025 and to renewals or extensions from 1 October 2025.
- Address performance, risk management and market competition in AI acquisitions, including protections around data and vendor lock-in.
How to prepare
- If you sell to federal agencies, assume the next renewal is the trigger and prepare the evidence pack before it, not during the competition.
- If you buy AI commercially, borrow the structure: it is a free, publicly maintained baseline for vendor documentation, evaluation evidence and change notification.
Penalties & enforcement
Contractual and administrative. Requirements attach to solicitations and to renewals.
Enforced by: Office of Management and Budget; agency contracting officers
OMB M-25-22 is enforced by Office of Management and Budget; agency contracting officers. Its obligations are already live, so a gap is a present exposure rather than a future one. In practice that means knowing which of your AI systems fall in scope in public sector, holding assessments that speak to governance & accountability, transparency and data governance, and being able to produce that evidence on request.