United States of America: Implemented obligation to submit progress reports outlined in OMB guidance on advancing responsible acquisition of Artificial Intelligence in government

On 23 March 2025, the guidance on advancing responsible acquisition of Artificial Intelligence (AI) in government issued by the United States Office of Management and Budget enters into force. The guidance highlights that the chief AI officers of agencies must submit a progress report to the OMB on cross-functional collaboration and a plan for coordinating AI acquisition with relevant officials by 23 March 2025. The guidance imposes several obligations for federal agencies acquiring AI, including the early involvement of agency privacy officials to manage privacy risks, collaboration with vendors to identify risk management triggers and the utilisation of outcomes-based acquisition techniques. The guidance requires agencies to negotiate contractual requirements for vendors to provide sufficient information for risk evaluation and protect government data in AI-related decision-making. Additionally, the guidance encourages robust competition among suppliers and mandates the establishment of cross-functional teams to manage risks and inform strategic planning for AI acquisition.