Question · OMB M-25-22

What AI clauses must federal contracts include after Sept 2025?

M-25-22 sets how agencies buy AI and rescinds M-24-18.

AboutOMB M-25-22
Legal forceBinding on federal agencies; reaches vendors through contract terms
Applies from30 Sep 2025
Checked21 Oct 2026

01 / The answer

The short answer

For AI contracts under solicitations issued, or options exercised, from September 30, 2025, M-25-22 requires terms that permanently bar vendors from using non-public agency inputs and outputs to train public or commercial AI without agency consent; protect against vendor lock-in through knowledge transfer, data and model portability and licensing transparency; ensure compliance with M-25-21's high-impact practices; and let the agency regularly test and monitor the delivered AI. Where vendors do the testing, results must be detailed enough to verify or reproduce, if practicable. LLM purchases also follow M-26-04.
OMB M-25-22 · checked 21 Oct 2026

02 / The rule

What OMB M-25-22 requires

M-25-22 sets how agencies buy AI and rescinds M-24-18. It requires contract terms on government data, vendor lock-in, compliance with M-25-21's high-impact practices, and agency rights to test and monitor the delivered AI.

  1. 01Apply the memo to contracts under solicitations issued, and options exercised, 180 days or more after issuance.
  2. 02Update internal acquisition procedures within 270 days so acquired AI conforms to M-25-21.
  3. 03Permanently bar vendors from training public or commercial AI on non-public agency inputs and outputs without agency consent.
  4. 04Include vendor lock-in protections such as knowledge transfer, data and model portability, and licensing transparency.

03 / Records

Records to keep

  1. 01Contract clauses on data use, IP rights and portability
  2. 02Agency-held validation and test datasets kept from the vendor
  3. 03Periodic (e.g. quarterly) performance and risk evaluation reports
  4. 04Vendor testing procedures and reproducible test results

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

Go back to the source

PRIMARY
OMB Memoranda index

The White House

RELATED

Related: OMB M-25-22: the full guide · How do I prevent AI vendor lock-in in a federal contract?