This is part of an ongoing series of Covington blogs on the AI policies, executive orders, and other actions of the Trump Administration. This blog describes AI actions taken by the Trump Administration in April 2025, and prior articles in this series are available here.
White House OMB Issues AI Use & Procurement Requirements for Federal Agencies
On April 3, the White House Office of Management & Budget (“OMB”) issued two memoranda on the use and procurement of AI by federal agencies: Memorandum M-25-21 on Accelerating Federal Use of AI through Innovation, Governance, and Public Trust (“OMB AI Use Memo“) and Memorandum M-25-22 on Driving Efficient Acquisition of Artificial Intelligence in Government (“OMB AI Procurement Memo”). The two memos partially implement President Trump’s January 23 Executive Order 14179 on “Removing Barriers to American Leadership in Artificial Intelligence,” which, among other things, directs OMB to revise the Biden OMB AI Memos to align with the AI EO’s policy of “sustain[ing] and enhance[ing] America’s global AI dominance.” The OMB AI Use Memo outlines agency governance and risk management requirements for the use of AI, including AI use case inventories and generative AI policies, and establishes “minimum risk management practices” for “high-impact AI use cases.” The OMB AI Procurement Memo establishes requirements for agency AI procurement, including preferences for AI “developed and produced in the United States” and contract terms to protect government data and prevent vendor lock-in. According to the White House’s fact sheet, the OMB Memos, which rescind and replace AI use and procurement memos issued under President Biden’s Executive Order 14110, shift U.S. AI policy to a “forward-leaning, pro-innovation, and pro-competition mindset” that will make agencies “more agile, cost-effective, and efficient.”Continue Reading April 2025 AI Developments Under the Trump Administration