The Office of Personnel Management (OPM) is the federal government's human resources agency, responsible for civil-service policy, the government-wide hiring platforms, and classification and qualification standards. Its AI activity runs along two tracks: building AI features into the hiring systems agencies use, and issuing policy guidance on how the government-wide AI governance framework in OMB M-25-21 applies to human-capital work. On August 27, 2026 OPM Director Scott Kupor issued a memorandum to heads of departments and agencies concluding that several common uses of AI in federal hiring are generally not "high-impact" under that framework.
Mandate
OPM sets and administers civil-service policy, including position classification under 5 U.S.C. Ch. 51 and the job-analysis and validation requirements of 5 CFR 300.103, and operates the government-wide hiring infrastructure. Its AI-relevant policy obligations flow from the same layered framework that binds other agencies — the statutes, executive orders, and OMB memoranda catalogued in Federal AI Compliance Landscape. Among the 35 recommendations the Government Accountability Office made to agencies in 2023 on implementing federal AI requirements, OPM's AI rotational programs were one of the four GAO recorded as implemented by July 2025 (Source: GAO-25-107933: AI Federal Efforts Guided by Requirements and Advisory Groups).
Two executive orders and one plan frame OPM's hiring-modernization work: EO 14179, Removing Barriers to American Leadership in Artificial Intelligence (January 23, 2025); EO 14170, Reforming the Federal Hiring Process and Restoring Merit to Government Service (January 20, 2025); and the Merit Hiring Plan issued by the White House Domestic Policy Council and OPM on May 29, 2025, which sets a target of reducing average time-to-hire to 80 days. The Chance to Compete Act of 2024 (Pub. L. No. 118-188) supplies further statutory basis (OPM Memorandum — Use of Artificial Intelligence in the Federal Hiring Process (August 2026)).
Guidance on AI in federal hiring
The August 27, 2026 memorandum, Use of Artificial Intelligence in the Federal Hiring Process, opens by stating that agencies "may be compromising efficiency and quality in Federal hiring by failing to adopt the use of Artificial Intelligence (AI)." It is framed as clarifying the interpretation and application of M-25-21 in the hiring context rather than modifying it; the memo states that M-25-21 controls in the event of any inconsistency, and that it creates no right or benefit enforceable at law. Nextgov reported that Adam Starr, OPM's chief information officer, wrote that federal hiring takes an average of 87 days (Source: nextgov.com).
The high-impact analysis
M-25-21 treats a use of AI as high-impact where the AI's output "serves as a principal basis for decisions or actions with legal, material, binding, or significant effect on" six enumerated interests, among them an individual's access to employment. The memo restates that definition and adds OPM's own reading of the "principal basis" element: where an appropriate agency official independently reviews the supporting data, evaluates the decisional logic, and adopts the AI-assisted work product, the output generally does not serve as a principal basis, "not because human oversight, by itself, exempts a use from the high-impact definition," but because independent review, evaluation, and adoption "supply the decision's own justification."
Determination of the terms or conditions of federal employment — including pre-employment screening, reasonable accommodation, pay or promotion, performance management, hiring or termination, and reassignment — sits in M-25-21's presumed-high-impact list. Agencies must treat such uses as high-impact unless they determine the use does not actually meet the definition, in which case an appropriate agency official must document that determination in writing to the agency Chief AI Officer. For uses that remain high-impact, agencies must either implement the minimum risk-management practices of M-25-21 § 4(b) or submit a waiver request to the CAIO. Appendix B of the memo supplies model determination and waiver language, and directs that a determination and a waiver request be prepared as separate documents.
Uses OPM treats as generally not high-impact
Applying that analysis, the memo identifies four categories of hiring use that OPM considers generally not high-impact:
| Use category | Scope as described in the memo |
|---|---|
| Content development for job opportunity announcements | Drafting position descriptions, evaluation statements, announcement text, job analyses, qualification requirements, crediting plans, and interview questions, where drafting does not itself affect access to employment |
| Decision support for applicant-level evaluations | Résumé screening, minimum-qualifications and eligibility review, and candidate summarization, where the deciding official independently reviews the underlying record |
| Pre-offer quality control | Review of the staffing case file and selection before a final job offer, limited to administrative completeness and quality control |
| Aggregate hiring program evaluation | Analysis of completed hiring actions, applicant flow, time-to-hire, and assessment performance, where no individual employment decision turns on the output |
Appendix A's Table 1 works seven use cases through a three-step framework and marks the boundary conditions (OPM Memorandum — Use of Artificial Intelligence in the Federal Hiring Process (August 2026)). Résumé screening, veterans'-preference document review, and eligibility determinations are described as presumed high-impact uses that fall outside the definition only where the AI's outputs identify the specific documentation each determination rests on, the documentation remains accessible to the deciding official, and accuracy is established through sampling and quality assurance. Where officials "ratify AI outputs without independent review of the underlying record," the memo states, the output serves as a principal basis notwithstanding the nominal review step. On rating and ranking, it states that where scores cannot be traced to the adopted crediting plan and the applicant's responses, or where AI operates as the sole scoring instrument without a reviewable basis for certification, the score "is itself the underpinning of the decision" and the use should be treated as high-impact whether or not a human official certifies the result.
A non-high-impact determination leaves other obligations intact. The memo requires agencies to verify, before deployment and periodically, that AI-assisted rating, ranking, and referral correctly apply veterans' preference; that AI-enabled steps meet Rehabilitation Act accessibility and reasonable-accommodation requirements; that applicant data is processed only in agency-authorized tools with Privacy Act and privacy-impact-assessment protections; that each hiring action remains documented and auditable; and that a reconsideration avenue remains available for adverse eligibility determinations. FedScoop reported that the memo responds to agencies defaulting to the view that any use of AI in hiring was subject to the high-impact standard (Source: fedscoop.com).
AI in the USA Suite hiring platforms
OPM operates the hiring platforms most federal agencies use — USA Staffing, USAJOBS, USA Hire, USA Class, and USA Performance — and has been adding AI features across them. The August 2026 memo states that OPM will continue introducing such features but that agencies "should not wait for those features to begin adopting AI."
USA Class is an AI-enabled tool for drafting federal position descriptions, trained on thousands of existing position descriptions to generate structured draft duties and to help classifiers align them with OPM classification standards. OPM announced its expansion to all federal agencies using USA Staffing at no additional cost, with functionality, training, and implementation support rolling out beginning in early May. Kupor said the expansion was intended to "cut unnecessary delays, reduce administrative burden, and help agencies move faster to hire" (Source: opm.gov).
OPM also runs an Artificial Intelligence Governance and Adoption Program (AI GAP), which the August 2026 memo names as the channel for agency assistance on AI-assisted hiring processes and for delegated-examining oversight questions.
AI workforce and recruiting programs
A December 15, 2025 memorandum from Kupor, Building the AI Workforce of the Future, directed agencies to designate one non-career appointee and one member of their Agency Talent Team to lead AI-workforce efforts, and described a program whose first pilot wave OPM said it would initiate by spring 2026 with a first on-cycle cohort by September 2026, using centralized outreach through USAJOBS alongside private industry, universities, non-profits, and professional associations (Source: opm.gov).
On June 30, 2026, OPM and the Defense Department launched "War Force," a Pentagon-targeted tech-engineer recruiting initiative run under OPM's Tech Force program (Source: insideaipolicy.com). See DOD — Department of Defense (AI Deployer).
Assessment practice and its critics
Jennifer Pahlka records that the US Digital Service and OPM have piloted subject-matter-expert-led candidate assessment, which she reports produces better hires, but that the practice remains uncommon because "many in government believe it to be illegal" when, she argues, it is not (The Digitalist Papers (Stanford, Volumes 1–2)). That argument concerns the pre-AI assessment process; the August 2026 memo addresses a related question from the other direction, treating the reflexive classification of hiring AI as high-impact as a barrier to adoption rather than a safeguard.
Relationships
- deploys-in: Federal AI Compliance Landscape — OPM applies the government-wide framework to human-capital use cases
- depends-on: OMB M-25-21 — Accelerating Federal Use of AI through Innovation, Governance, and Public Trust — the high-impact standard OPM's guidance interprets
- depends-on: OPM Memorandum — Use of Artificial Intelligence in the Federal Hiring Process (August 2026) — the August 2026 memorandum's full text
- related: Meaningful Human Review — the memorandum's functional test for when human review supplies a decision's justification
- depends-on: Executive Order 14179 — Removing Barriers to American Leadership in Artificial Intelligence
- related: GSA — General Services Administration (AI Deployer) — the other principal federal AI-adoption and procurement vehicle
- related: DOD — Department of Defense (AI Deployer) — joint "War Force" recruiting initiative
- related: Government AI Procurement
- related: Cascade of Rigidity — federal hiring-process rigidity as described by Pahlka
- related: AI Labor Disruption