Compare

OMB M-25-21/22 vs EO 14179: how they differ, side by side

How OMB M-25-21/22 and EO 14179 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

EO 14179Directs federal agencies; no direct private-sector duties

Checked21 Oct 2026

01 / Side by side

OMB M-25-21/22 and EO 14179, side by side

	OMB M-25-21/22	EO 14179
What it is	OMB memorandum	executive order
Jurisdiction	United States (federal)	United States (federal)
Legal force	Binding on federal agencies; M-25-22 reaches vendors through contract terms	Directs federal agencies; no direct private-sector duties
Status	In force	In force
Applies from	3 Apr 2025	23 Jan 2025
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.	White House advisers, OMB and federal agencies; it places no direct obligations on private companies.
Enforcement	OMB oversight and agency contracting; non-compliant high-impact AI must be discontinued. No monetary penalties.	None directly; internal executive branch management. The order creates no enforceable rights.

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 / EO 14179

What EO 14179 requires

It is the policy root of the current federal AI rules for agency use and purchase. Compliance duties for AI systems come from the OMB memos it triggered, not from the order itself.

01Develop and submit an AI Action Plan to the President within 180 days (named White House advisers).
02Review actions taken under revoked EO 14110 and suspend, revise or rescind those inconsistent with the order's policy.
03Revise OMB memoranda M-24-10 and M-24-18 within 60 days to match the policy (OMB Director).
04Provide available exemptions while revisions of conflicting EO 14110 actions are pending (agencies).

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.

SOURCES