Compare

OMB M-25-21/22 vs DoW RAI S&IP: how they differ, side by side

How OMB M-25-21/22 and DoW RAI S&IP differ: what each is, who owes it, when it applies and who enforces it.

OMB M-25-21/22Binding on federal agencies; M-25-22 reaches vendors through contract terms

DoW RAI S&IPInternal departmental strategy; directs DoD components, no direct duty on contractors

Checked21 Oct 2026

01 / Side by side

OMB M-25-21/22 and DoW RAI S&IP, side by side

	OMB M-25-21/22	DoW RAI S&IP
What it is	OMB memorandum	guidance
Jurisdiction	United States (federal)	United States (federal)
Legal force	Binding on federal agencies; M-25-22 reaches vendors through contract terms	Internal departmental strategy; directs DoD components, no direct duty on contractors
Status	In force	In force
Applies from	3 Apr 2025	June 2022
Who owes it	Federal agencies using (M-25-21) or buying (M-25-22) AI, and through contracts the vendors that supply it; National Security Systems are excluded from both.	DoD (styled Department of War since September 2025) components and the Chief Digital and AI Officer (CDAO), which leads Responsible AI implementation.
Enforcement	OMB oversight and agency contracting; non-compliant high-impact AI must be discontinued. No monetary penalties.	Internal DoD oversight by CDAO and component leadership; GAO and Congress review implementation. No penalties.

02 / OMB M-25-21/22

What OMB M-25-21/22 requires

Together they cover the federal AI lifecycle: choosing and contracting for AI, then testing, assessing and monitoring it in use. Vendors feel M-25-21 indirectly through M-25-22 clauses.

01Govern AI through a Chief AI Officer, governance board, compliance plan and annual use case inventory (M-25-21).
02Meet seven minimum practices for each high-impact AI use by 2026-04-03, or stop using it (M-25-21).
03Write contract terms that bind vendors to M-25-21 high-impact practices (M-25-22).
04Secure contractual rights to test and monitor delivered AI with agency-held data (M-25-22).
05Bar vendors from training on non-public agency data and protect against vendor lock-in (M-25-22).

03 / DoW RAI S&IP

What DoW RAI S&IP requires

AI-specific. It is DoD's main plan for putting AI ethics into practice for AI systems the department builds, buys and fields.

01Apply the DoD AI Ethical Principles (responsible, equitable, traceable, reliable, governable) across the AI lifecycle.
02Designate Responsible AI leads in each DoD component and resource the lines of effort assigned to that component.
03CDAO provides department-wide Responsible AI guidance, tools and coordination, and tracks implementation progress.
04Build warfighter trust through test and evaluation, assessment and monitoring of AI capabilities.
05Integrate Responsible AI into AI product development and acquisition, including requirements validation.
06Develop metrics for Responsible AI adoption and report progress to the CDAO governing council.

Optional evidence · where Planisphere fits

Keep a record anyone can check

When your team meets a duty, Planisphere can seal the event it reports as a receipt.

01 · Your teamRecord the event

A disclosure shown, a review signed, a model change approved: the event your system reports.

02 · PlanisphereSeal it

The event becomes a sealed receipt, dated and attributed to whoever is signed in.

03 · AnyoneCheck it

Paste the receipt into Verify. No account or key.

A record supports your compliance evidence process. It is not a legal finding or a certification. Systems that call Planisphere's gate API can also hold or refuse an action before it runs.

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