# OMB Memorandum M-25-21: Accelerating Federal Use of AI through Innovation, Governance, and Public Trust

- **Record type**: Policy instrument
- **Jurisdiction**: United States
- **Instrument type**: Guidance
- **Status**: In force
- **Binding**: Yes
- **Issuing body**: Office of Management and Budget, Executive Office of the President
- **Adopted**: 2025-04-03
- **Published**: 2025-04-03
- **In force**: 2025-04-03

## 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.

## Summary

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.

## Scope

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.

## Who it applies to

Federal agencies, their Chief AI Officers, and by extension AI vendors and contractors.

## What organisations must 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.

## Key dates

Issued 3 April 2025 with staggered compliance deadlines for governance, inventories and high-impact AI practices.

## Penalties

None; internal executive-branch policy.

## Obligations recorded against this instrument (2)

- **Apply minimum risk-management practices to high-impact AI** (Section 4) — 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.
  - Binding: yes
  - Record: https://aipolicytracker.org/obligations/us-omb-m-25-21-high-impact-ai-practices
- **Publish an annual AI use-case inventory** (Section 3) — Agencies must inventory their AI use cases annually and publish the inventory, identifying high-impact uses, with limited exclusions.
  - Binding: yes
  - Record: https://aipolicytracker.org/obligations/us-omb-m-25-21-use-case-inventory

## Provenance

- **Permanent id**: AIPT-POL-0234 (https://aipolicytracker.org/id/AIPT-POL-0234; never changes or gets reused)
- **Record page**: https://aipolicytracker.org/policies/us-omb-m-25-21
- **Official source**: https://www.whitehouse.gov/omb/information-for-agencies/memoranda/
- **Source document**: M-25-21 Accelerating Federal Use of AI through Innovation, Governance, and Public Trust
- **Published by**: Office of Management and Budget
- **Provision**: OMB memoranda index; reviewer to link the PDF directly
- **Review status**: verified
- **Confidence**: medium
- **Facts last confirmed**: 2026-09-26
- **Confirmed by**: Bhaskar Bhatt (see https://aipolicytracker.org/reviewers)
- **Retrieved**: 2026-10-27
- **Licence**: https://creativecommons.org/licenses/by/4.0/
- **Cite as**: AIPolicyTracker (2026). "OMB Memorandum M-25-21: Accelerating Federal Use of AI through Innovation, Governance, and Public Trust" [AIPT-POL-0234, record version 1, verified 26 September 2026 by Bhaskar Bhatt]. https://aipolicytracker.org/id/AIPT-POL-0234 (accessed 27 October 2026).

> This record is a structured summary with a link to the official text. It is not legal advice. Open the official source before relying on any date or duty. How current each record type must be is published at https://aipolicytracker.org/verification; what a record must carry at all is published at https://aipolicytracker.org/coverage.