Federal AI / policy

Policy & Frameworks. The direction layer.

NIST AI RMF, OMB memos, AI executive orders, DoD AI policy. The high-level direction that civilian and defense AI programs cite back to.

CURRENT AS OF 2026-06 // SECTIONS 4 // VERIFY BEFORE CITING
POLICY REFERENCE // NIST AI RMF

NIST AI RMF Quick Reference

CURRENT AS OF 2026-06

The voluntary federal framework for managing AI risk. Four functions. Use it to structure your write-up and your conversations.

The NIST AI Risk Management Framework (AI RMF 1.0) was published in January 2023. It is voluntary. OMB M-24-10 and most agency AI policies now reference it as the baseline. If you write AI requirements, run AI evals, or sit on a CAIO's bench, you need to read it in the original at least once. This page is the map.

The four functions

GOVERN

The culture and accountability layer. GOVERN asks who owns AI risk in your org, what your policies say, and how you train people. It produces a governance document, named accountable parties, a risk tolerance statement, and a training plan. In a real program it lands as a GOVERNANCE.md in the repo, a CAIO memo, and a recurring review cadence on the calendar.

MAP

The context layer. MAP asks what the system is, what it is not, who it affects, and where the data comes from. It produces a system card, a stakeholder map, a data provenance log, and a documented intended-use statement with explicit out-of-scope use. In a real program this is the artifact that survives ATO review when someone asks "what does this thing actually do."

MEASURE

The numbers layer. MEASURE asks how the system performs, how it fails, and how you would know. It produces eval sets, drift monitors, bias and fairness measurements where people are affected, and red-team results. In a real program this is the directory of CSVs and the monthly report that proves the system is still inside its risk envelope.

MANAGE

The response layer. MANAGE asks what you do when something breaks or changes. It produces a risk register, an incident runbook, an update policy, and a retirement plan. In a real program this is the page-of-the-week the on-call engineer reads when an alert fires.

The 18 categories

GOVERN (6 categories)

  • GOVERN.1: Policies and procedures for AI risk are in place. Gotcha: most orgs have generic IT risk policy and call it done. AI risk needs its own named policy.
  • GOVERN.2: Accountability structures are defined. Gotcha: "the AI team" is not a person. Name a human.
  • GOVERN.3: Workforce is trained. Gotcha: a one-time slide deck is not training. Recurring is required.
  • GOVERN.4: Organizational culture commits to risk management. Gotcha: this is often the weakest category on paper. Write down how leadership reinforces it.
  • GOVERN.5: Engagement with affected communities is documented. Gotcha: "internal stakeholders only" is usually wrong for rights-impacting systems.
  • GOVERN.6: Third-party and supply-chain risk is addressed. Gotcha: if you call a foundation model API, that vendor is in scope.

MAP (5 categories)

  • MAP.1: Context is established. Gotcha: write down the operational environment, not just the technical stack.
  • MAP.2: AI system categorization is documented. Gotcha: rights-impacting and safety-impacting designations drive the rest of M-24-10. Get this right.
  • MAP.3: AI capabilities, targets, and assumptions are known. Gotcha: "chatbot" is not a capability statement. List the actual tasks.
  • MAP.4: Risks and benefits are mapped. Gotcha: benefits need to be quantified the same way risks are.
  • MAP.5: Impacts to individuals, groups, and society are characterized. Gotcha: this is where bias and disparate-impact analysis lives.

MEASURE (4 categories)

  • MEASURE.1: Appropriate methods and metrics are identified. Gotcha: accuracy alone is not enough for anything that touches people.
  • MEASURE.2: Systems are evaluated for trustworthy characteristics. Gotcha: this includes fairness, robustness, privacy, explainability, not just performance.
  • MEASURE.3: Mechanisms for tracking risks are in place. Gotcha: a one-time eval is not a mechanism. You need continuous measurement.
  • MEASURE.4: Feedback from end users and impacted communities is collected. Gotcha: a feedback button is not the same as actually reviewing the feedback.

MANAGE (4 categories)

  • MANAGE.1: Risks are prioritized and resources allocated. Gotcha: if every risk is "medium," you have not prioritized.
  • MANAGE.2: Strategies to maximize benefits and minimize risks are planned. Gotcha: "we'll monitor" is not a strategy.
  • MANAGE.3: Third-party risks are managed. Gotcha: this is where your vendor's eval reports and SOC 2s land.
  • MANAGE.4: Risk treatment, including response and recovery, is in place. Gotcha: the runbook needs to be tested, not just written.

When the RMF fits, and when it is overkill

Use the full RMF when the system is rights-impacting, safety-impacting, public-facing, or covers more than 100 users. Use it when you are heading toward an ATO. Use it when a vendor will be involved at any scale.

Do not use the full RMF for a small internal tool used by five people on non-sensitive data. A short system card and a named owner is enough. Citing the RMF on a tiny prototype is theater, and it slows everyone down. The Profile guidance in the RMF itself supports this scoping decision.

Five-step on-ramp for day one

  1. Pick the system. One AI system you actually own. Not the whole portfolio.
  2. Categorize it. Rights-impacting? Safety-impacting? Internal only? Write the answer in one paragraph.
  3. Write the system card. Intended use, out-of-scope use, users, data sources, dependencies, known limits. Two pages, not twenty.
  4. Stand up the risk register. Five risks, ranked. What you are doing about each. A markdown table is fine.
  5. Name the owner and the review cadence. Quarterly minimum. Put it on the calendar before you leave the meeting.

You now have GOVERN, MAP, MEASURE, and MANAGE in skeleton form. Iterate from there.

POLICY REFERENCE // OMB MEMOS

OMB Memos Cheat Sheet

CURRENT AS OF 2026-06 CHANGES YEARLY

The operational rulebook for civilian agency AI. Know which memo, which paragraph, which deadline.

OMB memos translate executive direction into agency action. For AI, two memos dominate the conversation. Both were issued in 2024. Both have been partially superseded or amended in the 2025 policy reset. Read them in the original before citing them in a proposal. status as of 2026-06; verify before citing in proposals.

OMB M-24-10: Advancing Governance, Innovation, and Risk Management for Federal Use of AI

Issued March 28, 2024. This is the foundation memo for civilian agency AI governance. It applies to all CFO Act agencies (the big civilian departments) and excludes the Intelligence Community and most DoD national security systems.

What it requires:

  • A Chief AI Officer (CAIO). Each covered agency had to designate one within 60 days. Senior official, reports to the agency head or deputy, accountable for AI strategy and risk.
  • An annual AI use case inventory. Public-facing. Lists every AI use case the agency has in production or development. Updated yearly.
  • Minimum practices for rights-impacting and safety-impacting AI. Specific requirements: pre-deployment testing, AI impact assessments, ongoing monitoring, public consultation where appropriate, and a documented opt-out or human alternative where feasible.
  • An agency AI strategy. Each agency published one. Most are on the agency's AI page or AI.gov.

Status in 2026-06: The memo was rescinded and replaced under the 2025 administration. The replacement memo (M-25-21 series) kept the CAIO role and the use case inventory but loosened the rights-impacting and safety-impacting minimum practices. status as of 2026-06; verify the active memo number and the exact minimum practices before citing in proposals.

Recurring obligations: Use case inventory is annual. AI strategy refresh is at agency discretion but most are on a two-year cycle.

OMB M-24-18: Advancing the Responsible Acquisition of AI in Government

Issued October 3, 2024. The acquisition companion to M-24-10. Applies to civilian agency procurement of AI systems and services.

What it requires:

  • Contracting officers must coordinate with the CAIO on any solicitation that includes AI. Not optional.
  • Specific contract clauses for AI: vendor disclosure of training data sources where feasible, ongoing performance reporting, defined rights to test and audit the system, and a documented exit and data-handoff plan.
  • Risk-based oversight. Higher-risk AI (rights-impacting, safety-impacting) gets more contract scrutiny and more vendor obligations.
  • Workforce training for the acquisition workforce on AI fundamentals.

Status in 2026-06: M-24-18 was also superseded under the 2025 reset, with a successor memo that simplified the clause requirements. The CAIO coordination requirement survived. status as of 2026-06; verify the active acquisition memo and its clause list before drafting solicitation language.

For vendors: if you sell AI to civilian agencies, expect to be asked about training data, evals, monitoring, and exit. Have answers ready in writing.

Later memos through 2026-06

The 2025 administration issued a replacement memo bundle in spring 2025 that reset M-24-10 and M-24-18. The replacements kept the core scaffolding (CAIO, use case inventory, acquisition coordination) and removed or softened some of the rights-impacting protections. There has been at least one further OMB guidance document in 2026 on agency adoption of generative AI tools.

status as of 2026-06: the exact memo numbers, dates, and binding text in the current administration's series should be verified on whitehouse.gov/omb before citing. Treat anything specific in this section as a pointer, not a quote.

The core takeaway: the CAIO role and the public use case inventory have been durable across administrations. Specific minimum practices have not.

How to read these in 5 minutes

  • Find the "Definitions" section first. "Rights-impacting" and "safety-impacting" are defined terms. They drive every other requirement.
  • Read the action items. Skip the preamble. Action items are usually numbered and have deadlines.
  • Look for who is covered and who is exempt. IC and national security systems are usually carved out. Independent agencies sometimes are.
  • Check the appendices. The minimum-practice lists and the inventory schema live in appendices, not the body.
POLICY REFERENCE // EXECUTIVE ORDERS

AI Executive Orders: Active vs Rescinded

CURRENT AS OF 2026-06 CHANGES YEARLY

A chronological read of the AI EOs from EO 13859 to today. Some are active. Some were rescinded. Some were rescinded then replaced. Know the difference before you cite one.

Executive orders set direction. Agencies turn that direction into memos and rules. If you cite an EO in a proposal, you need to know whether it is still in force. The status changes with administrations. This is the read as of 2026-06.

Chronological list

EO 13859: Maintaining American Leadership in Artificial Intelligence (February 2019)

The first AI-specific EO. Directed federal investment in AI R&D, asked agencies to make federal data more available for AI development, and called for AI workforce growth. Created the foundation for the American AI Initiative.

Status: Largely superseded by later EOs but never formally rescinded. Most of its operational direction has been overtaken. The OSTP and NSTC AI coordination structures it set up are still around. status as of 2026-06; verify before citing.

EO 13960: Promoting the Use of Trustworthy Artificial Intelligence in the Federal Government (December 2020)

First EO to require agency AI use case inventories and to set principles for federal AI use (lawful, performance-driven, accurate, safe, understandable, accountable, transparent). The inventory requirement is the direct ancestor of the M-24-10 inventory.

Status: Active in part. Some provisions were carried forward into later memos. The trustworthy AI principles are still cited. status as of 2026-06; verify before citing.

EO 14091: Further Advancing Racial Equity and Support for Underserved Communities Through the Federal Government (February 2023)

Not AI-specific but it explicitly directed agencies to address algorithmic discrimination in federal programs. Often paired with AI EOs in legal analyses of rights-impacting AI.

Status: Rescinded. Rescinded under the 2025 administration. status as of 2026-06; verify the rescission and any replacement language.

EO 14110: Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence (October 2023)

The most comprehensive AI EO to date when issued. Directed NIST to develop testing standards, required agency AI Safety reports, set dual-use foundation model reporting thresholds, and stood up the AI Safety Institute. The OMB M-24-10 memo was issued directly under its authority.

Status: Rescinded January 2025. Rescinded on day one of the 2025 administration. Some downstream artifacts (the AI Safety Institute, NIST work) survived; the EO itself does not. Do not cite EO 14110 as active. status as of 2026-06: confirmed rescinded.

2025 AI Executive Order: Removing Barriers to American Leadership in AI (January 2025)

The replacement direction issued shortly after the EO 14110 rescission. Directs agencies to identify and roll back AI rules that constrain US AI development, asks for a new AI Action Plan, and reframes federal AI policy around competitiveness and growth. It is the current high-level AI direction for civilian agencies.

Status: Active. status as of 2026-06; verify the exact EO number and any amending orders before citing.

2025 follow-on AI EO(s)

The 2025 administration issued at least one follow-on AI EO during the year on federal AI procurement and on infrastructure (data centers, power). Numbers and exact scope should be confirmed on the source. status as of 2026-06; verify EO numbers and scope before citing.

What's actually binding in 2026-06

  • The active 2025 AI EO (Removing Barriers). This is the live direction. Everything else flows from it.
  • EO 13960's trustworthy AI principles, to the extent agencies still reference them in their own policies and the OMB inventory schema. The principles outlived the original EO's operational provisions.
  • The OMB memo bundle issued under the 2025 EO authority. EOs set direction; OMB memos are what contracting officers and CAIOs actually operate against. If you are writing a proposal, cite the OMB memo, not the EO.

A tactical note: EOs change with administrations. Memos and statutes are more durable. When you have a choice in what to cite, cite the statute or the memo first, the EO second.

POLICY REFERENCE // DOD AI

DoD AI Policy

CURRENT AS OF 2026-06 CHANGES YEARLY

The DoD has its own AI direction beyond OMB. CDAO sets the agenda. The services execute it. This is the map.

OMB memos cover civilian agencies. DoD has its own structure. National security systems are exempt from M-24-10. If you work AI for defense, this is the policy stack you cite.

CDAO: Chief Digital and AI Office

The CDAO is the top of the DoD AI org chart. It sits in the Office of the Secretary of Defense (OSD), reporting to the Deputy Secretary. Established January 2022 by merging the Joint AI Center (JAIC), the Defense Digital Service (DDS), the Office of Advancing Analytics (ADVANA), and the Chief Data Officer role.

What CDAO does:

  • Sets DoD-wide policy on data, analytics, AI, and digital.
  • Owns ADVANA (the department's analytics platform) and the Joint Common Foundation (the JCF, a development platform for DoD AI projects).
  • Runs department-level AI initiatives like Task Force Lima (generative AI) and the AI rapid capabilities cell.
  • Coordinates Responsible AI (RAI) implementation across the department.

What CDAO does not do:

  • Field weapons or platforms. The services do that.
  • Run individual programs. CDAO sets policy and provides shared infrastructure; the services and combatant commands execute.
  • Manage clearances or personnel security. That is the security enterprise.

For an engineer or PM, CDAO is the office whose guidance you cite and whose platforms (ADVANA, JCF) you may build on. For a service member, you almost always work for a service AI office, not for CDAO directly.

DoD AI Strategy

2018 DoD AI Strategy

The first one. Set the case for AI as a strategic priority, established the JAIC, and named ethics as a pillar. Most of its operational direction has been overtaken by the 2023 strategy.

Status: Largely superseded.

2023 DoD Data, Analytics, and AI Adoption Strategy

The current strategy. Reframes AI as part of a broader data and analytics push. You cannot do AI without the data infrastructure underneath. Sets adoption goals for the warfighter, business operations, and enterprise services. Names quality data, governance, and trust as enablers.

Status: Active. This is the strategy you cite. status as of 2026-06; verify before citing in proposals. A follow-on strategy may have been issued in 2026.

DoDD 3000.09: Autonomy in Weapon Systems

The directive that governs autonomous and semi-autonomous weapons. Originally 2012, updated January 2023. Requires senior-level review before development and before fielding of any autonomous or semi-autonomous weapon system. Requires appropriate levels of human judgment over the use of force. Sets the verification and validation expectations for weapon system autonomy.

It is short and important. If your work touches lethal autonomy in any form, you need to have read it.

DoD Responsible AI guidance

The five DoD AI Ethical Principles

Adopted February 2020. The principles: Responsible. Equitable. Traceable. Reliable. Governable. Every DoD AI policy document since references these.

RAI Strategy and Implementation Pathway

Published June 2022. Translates the five principles into implementation lines of effort: governance, warfighter trust, AI product and acquisition lifecycle, requirements validation, RAI ecosystem, and workforce. CDAO owns the implementation.

In practice, RAI shows up as required artifacts at program milestones: testing plans, risk assessments, human-machine teaming documentation, and bias and performance evaluations.

Service-level AI offices

  • Army AI Integration Center (AI2C). Carnegie Mellon-based, focused on Army AI capability development, talent, and experimentation.
  • Navy CDIO and Naval Information Warfare Systems Command (NAVWAR). Navy CDIO sets policy; NAVWAR and the AI/ML technical authority deliver capability.
  • Department of the Air Force AI offices (AFRL, the Department of the Air Force AI Accelerator (MIT), and AFWERX). AFRL runs the research portfolio. The Accelerator does applied research with MIT. AFWERX runs the SBIR pipeline and is the most common entry point for small vendors.
  • Marine Corps (Marine Corps Warfighting Lab and Marine Corps Information Command, MCIC). Smaller AI footprint than the other services; experimentation runs through the Warfighting Lab.
  • Space Force: the Space Force Chief Technology and Innovation Office (CTIO) owns AI policy for the Space Force, with capability delivery through Space Systems Command. status as of 2026-06; verify office names before citing in a proposal.

If you are writing a proposal, identify the service-level office that owns the requirement before you write a word. CDAO does not buy capability for the services.