OMB M-25-21: requirements, deadlines and compliance actions
OMB Memorandum M-25-21: Accelerating Federal Use of AI through Innovation, Governance, and Public Trust
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On this page 11 sections
In brief
The OMB M-25-21 is a binding guidance of the United States, issued by the Office of Management and Budget, Executive Office of the President. It has been in force since 3 April 2025. Applies to federal executive agencies' development, acquisition and use of AI, with exceptions for national security systems and certain research. Penalties: None; internal executive-branch policy.
- Jurisdiction
- United States
- Instrument type
- Guidance
- Status
- In force
- Legal force
- Binding
- Issuing body
- Office of Management and Budget, Executive Office of the President
- Adopted
- 3 April 2025
- Published
- 3 April 2025
- In force
- 3 April 2025
- Obligations recorded
- 2
- Source reference
- OMB memoranda index; reviewer to link the PDF directly
- Official source
- M-25-21 Accelerating Federal Use of AI through Innovation, Governance, and Public Trust
- Verification
- Verified against the official source 26 Sep 2026
What is the OMB M-25-21?
M-25-21 directs US federal agencies on how to govern and use AI. It requires agencies to designate Chief AI Officers, maintain AI governance boards, publish AI use-case inventories, and apply minimum risk-management practices to "high-impact" AI, including pre-deployment testing, AI impact assessments, ongoing monitoring, human oversight and training, and remedies for affected individuals. It replaced the 2024 memoranda with a greater emphasis on adoption and innovation while retaining core risk practices.
Status note: Binding on federal agencies as OMB policy; issued together with M-25-22 on federal acquisition of AI. Replaced M-24-10 and M-24-18. Deadlines in the memo run from its issue date; a reviewer should confirm current status.
Who does it apply to?
Applies to federal executive agencies' development, acquisition and use of AI, with exceptions for national security systems and certain research. It does not bind private organisations but sets the expectations vendors must meet to sell AI to federal agencies.
Federal agencies, their Chief AI Officers, and by extension AI vendors and contractors.
- Risk categories
- Not classified by the instrument
- AI system types
- Generative AI systemAutomated decision-making system
When do the requirements apply?
Issued 3 April 2025 with staggered compliance deadlines for governance, inventories and high-impact AI practices.
What must organisations do?
Agencies must implement the governance and high-impact practices; vendors should be able to supply documentation, test results and monitoring support that agencies need for high-impact use cases.
Each duty is one line: open it for the summary, practical action and evidence, or go to its own page.
Legal requirement Apply minimum risk-management practices to high-impact AI Public authority / government body
For AI whose output serves as a principal basis for decisions with significant effects on rights, safety or access to services, agencies must complete pre-deployment testing, an AI impact assessment, ongoing monitoring, operator training, human oversight and a mechanism for affected people to seek remedy, or stop using the AI.
Practical action: Vendors should prepare test evidence and documentation that agencies can reuse in impact assessments.
Evidence examples: AI impact assessment; Pre-deployment test results
Framework mapping (original, editorial): NIST AI RMF 1.0 MAP, MEASURE, MANAGE
Open the obligation page →Section 4 Source-linked (a factual check against the official source, not a legal review)
Legal requirement Publish an annual AI use-case inventory Public authority / government body
Agencies must inventory their AI use cases annually and publish the inventory, identifying high-impact uses, with limited exclusions.
Practical action: Agencies maintain the inventory; vendors may be asked for use-case descriptions.
Evidence examples: AI use-case inventory
Framework mapping (original, editorial): NIST AI RMF 1.0 GOVERN 1.6
Open the obligation page →Section 3 Source-linked (a factual check against the official source, not a legal review)
What are the penalties?
None; internal executive-branch policy.
Public-sector rules and enforcement
- Federal acquisition of AI must follow OMB M-25-22 — The companion memorandum M-25-22 sets requirements for agencies buying AI, including protecting government data and avoiding vendor lock-in, performance-based contracting, and requiring vendors to support the documentation and testing agencies need for high-impact AI. (applies to: Federal executive agencies and their AI vendors)
Official sources
-
OMB Memorandum M-25-21
Office of Management and Budget · 3 Apr 2025 · Tier 1 source
Cite this record
AIPolicyTracker (2026). “OMB M-25-21” [AIPT-POL-0234, record version 1, verified 26 September 2026 by Bhaskar Bhatt]. https://aipolicytracker.org/id/AIPT-POL-0234 (accessed 27 October 2026). Data licensed CC BY 4.0.
Permanent id AIPT-POL-0234: it never changes or gets reused, and its address keeps working if this page moves.
Cite the official text alongside it: M-25-21 Accelerating Federal Use of AI through Innovation, Governance, and Public Trust, Office of Management and Budget, https://www.whitehouse.gov/omb/information-for-agencies/memoranda/.
BibTeX
@misc{aipolicytracker2026_ombm2521,
author = {{AIPolicyTracker}},
title = {{OMB M-25-21}},
year = {2026},
howpublished = {\url{https://aipolicytracker.org/policies/us-omb-m-25-21}},
url = {https://aipolicytracker.org/policies/us-omb-m-25-21},
urldate = {2026-10-27},
note = {Data licensed CC BY 4.0. Accessed 27 October 2026}
}
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Record history
No change to this record's tracked fields has been recorded since 15 October 2026, when field-level history began.
Record version 1: Initial structured record; direct PDF link to be confirmed by reviewer. Every earlier wording is in the GitHub repository.
Frequently asked questions
Is the OMB M-25-21 in force?
Yes. The OMB M-25-21 is in force since 3 April 2025.
Is the OMB M-25-21 legally binding?
Yes. The OMB M-25-21 is a binding guidance; the obligations it creates are legal requirements for the actors it covers.
Who does the OMB M-25-21 apply to?
Applies to federal executive agencies' development, acquisition and use of AI, with exceptions for national security systems and certain research. It does not bind private organisations but sets the expectations vendors must meet to sell AI to federal agencies.
When does the OMB M-25-21 apply?
Issued 3 April 2025 with staggered compliance deadlines for governance, inventories and high-impact AI practices.
What must organisations do under the OMB M-25-21?
Agencies must implement the governance and high-impact practices; vendors should be able to supply documentation, test results and monitoring support that agencies need for high-impact use cases.
What are the penalties under the OMB M-25-21?
None; internal executive-branch policy.
Where is the official text of the OMB M-25-21?
The official text is published by Office of Management and Budget at https://www.whitehouse.gov/omb/information-for-agencies/memoranda/ (M-25-21 Accelerating Federal Use of AI through Innovation, Governance, and Public Trust). This record links to it and is checked against it.
Disclaimer: informational only, not legal advice. Verify every claim against the linked official sources and consult a qualified lawyer before acting.