OMB replaces federal AI memos with M-25-21 and M-25-22

The White House announced on 7 April 2025 that OMB had released two revised AI policies: memorandum M-25-21, Accelerating Federal Use of AI through Innovation, Governance, and Public Trust, and memorandum M-25-22, Driving Efficient Acquisition of Artificial Intelligence in Government. The first covers how federal agencies use AI; the second covers how they buy it.

What it is

The memos were rewritten at the direction of Executive Order 14179. The accompanying fact sheet describes them as a deliberate change of direction from the prior administration, toward using emerging technology to modernize government.

What it requires

According to the fact sheet, M-25-21:

• recasts Chief AI Officers as promoters of adoption for lower-risk AI who also mitigate risks for higher-impact AI and advise on AI spending;

• creates one high-impact AI category for uses that need heightened due diligence because they could affect rights or safety;

• asks each agency for an AI adoption maturity assessment.

M-25-22 tells agencies to write clear requirements that avoid vendor lock-in, drop burdensome reporting while still protecting privacy and lawful data use, apply performance-based techniques, and build a shared online repository of AI procurement tools.

What security leaders should do

• If you sell AI to federal agencies, work out whether your product falls into the high-impact category, since that is where heightened due diligence now concentrates.
• Prepare clear positions on data use, portability and exit terms; the acquisition memo's focus on avoiding lock-in puts those clauses on the table.
• Internally, copy the triage idea: fast-track low-risk AI and reserve deep review for systems that could affect people's rights or safety.