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Policy guide · OMB M-25-21

Current U.S. federal agency AI policy: OMB M-25-21

Federal AI content must distinguish current agency policy from superseded guidance. M-25-21 emphasizes innovation, governance, public trust, transparency, high-impact AI risk practices, monitoring, and stopping use when proper mitigation is not possible. Its scope is federal agency use—not a universal commercial certification.

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Published Updated Reviewed By LongTermIntelligence.com

Direct answer

Is OMB M-24-10 still the current federal agency AI memorandum?

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No. OMB M-25-21, issued April 3, 2025, explicitly rescinds and replaces M-24-10. Public guidance for covered federal agency AI use should cite M-25-21, define the relevant scope, and avoid presenting older M-24-10 language as current policy.

  • M-25-21 applies to covered federal agency development, acquisition, and use as specified in the memorandum.
  • It directs agencies to pursue innovation while maintaining governance, transparency, privacy, civil-rights, civil-liberties, and high-impact AI safeguards.
  • It does not create a universal private-sector compliance badge.

Source basis: reviewed official references are listed on this page and in the source ledger. Interpretation and implementation guidance retain the stated assurance boundary.

Operational reading

Policy direction and practical evidence

The exact requirement depends on scope; the engineering record should make review possible.

Policy areaOperating implicationExample evidence
Agency AI strategyAI adoption should connect mission outcomes, maturity, infrastructure, governance, data, workforce, and procurement.Use-case inventory, maturity assessment, investment plan, governance charter
Governance and accountabilityNamed leaders and delegated risk responsibilities should enable responsible adoption.CAIO and owner roles, decision rights, risk acceptance, meeting records
TransparencyAgencies continue public strategy, inventory, compliance-plan, and reporting responsibilities as applicable.Inventory record, public summary inputs, reporting workflow, disclosure review
High-impact AIMinimum risk-management practices apply to covered high-impact uses, proportionate to anticipated risk.Impact determination, pre-deployment testing, monitoring, human oversight, appeals or remedies where applicable
Performance and discontinuationWhen high-impact AI is not performing appropriately, agencies need a plan to discontinue use; if mitigation is not possible, use must cease.Thresholds, stop criteria, rollback plan, suspension authority, incident evidence
Acquisition and reuseAgencies should improve value, reuse resources, and address procurement and lifecycle needs.RFP requirements, acceptance tests, AIBOM, portability and exit criteria

Federal engagement check

Before making a federal policy claim

Policy scope should be reviewed for the actual agency, system, contract, and use.

  • Cite M-25-21 rather than superseded M-24-10 for current agency-use guidance.
  • Identify the covered agency, functionality, intended use, and whether high-impact AI analysis is required.
  • Coordinate with agency legal, privacy, civil rights, security, records, acquisition, accessibility, and program officials.
  • Define pre-deployment testing, ongoing monitoring, human oversight, incident, discontinuation, and public-reporting evidence.
  • Separate policy alignment support from FedRAMP authorization, ATO, statutory compliance, procurement approval, or legal opinion.
  • Review current agency-specific policies and contract clauses in addition to OMB guidance.

Primary-source basis

Official references

Verify the version, status, and scope in the named primary sources before implementation or publication.

Executive Office of the President, Office of Management and Budget · Official Federal Policy

OMB Memorandum M-25-21

Federal agency guidance issued April 3, 2025, that rescinds and replaces OMB Memorandum M-24-10 and establishes requirements for agency AI innovation, governance, transparency, and high-impact AI risk management.

Status
Current
Published
2025-04-03
Reviewed
2026-08-01

Use boundary: Applies to covered federal agency use; it is not a universal private-sector compliance standard.

Open official source

Official-source citations establish provenance and scope. They do not establish LongTermIntelligence.com certification, endorsement, legal advice, client outcomes, or a guarantee that a control is effective.

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