OMB M-25-21 is a memorandum issued by the Office of Management and Budget (OMB) on April 3, 2025, that directs federal agency use of artificial intelligence. It replaced the Biden administration's OMB M-24-10 (March 2024, Advancing Governance, Innovation, and Risk Management for Agency Use of AI) and was issued pursuant to Executive Order 14179 (Removing Barriers to American Leadership in AI, January 2025). A companion memorandum on AI acquisition, OMB M-25-22, was issued the same day.
Status and background
EO 14179, signed in January 2025, directed OMB to revise M-24-10 to accelerate federal AI adoption while maintaining governance standards. M-25-21 was issued pursuant to that directive. It reorients federal AI policy from the safety and risk-management emphasis of M-24-10 toward faster adoption and reduced barriers to deployment. The memorandum directs OMB to update M-25-21 at least every two years through 2037.
Requirements for OMB
The memorandum tasks OMB with several actions. It is to develop and provide agencies with an AI strategy template and a compliance plan template for ensuring consistency with M-25-21, neither carrying a stated due date. OMB is also to issue detailed instructions for agencies on documenting AI waivers, again with no stated due date. The memorandum directs OMB to convene and chair an interagency Chief AI Officer (CAIO) Council to coordinate AI development and use; the council was to be established before July 2, 2025, and sunsets after five years.
Requirements for federal agencies
Agencies are required to establish generative AI policies, a requirement new relative to M-24-10. Each agency must develop and publicly release an AI strategy by September 30, 2025, and must ensure it has a Chief AI Officer (CAIO). Agencies are to prepare and maintain annual AI use case inventories, a requirement carried over from M-24-10, and to adhere to guidance for AI contracts by September 30, 2025.
Comparison to M-24-10
M-25-21 retains several structural elements of the Biden-era M-24-10 while shifting its framing. Both memoranda require a Chief AI Officer, a CAIO Council, and annual AI use case inventories. M-25-21 frames federal AI policy around innovation and acceleration where M-24-10 emphasized governance and risk management, and it adds an explicit requirement that agencies develop generative AI policies, which M-24-10 did not address. The CAIO Council under M-25-21 is reformed under EO 13960 principles.
| Dimension | M-24-10 (Biden, Mar 2024) | M-25-21 (Trump, Apr 2025) |
|---|---|---|
| Framing | Governance + risk management | Innovation + acceleration |
| Generative AI | Not explicitly addressed | Agencies must develop GenAI policies |
| Tone | Cautionary; risk-first | Enablement-first |
| Reporting | Annual inventories | Annual inventories (continued) |
| Chief AI Officer | Required | Required (continued) |
| CAIO Council | Required | Required (reformed under EO 13960 principles) |
Implementation
GAO-25-107933 (September 2025) documented that as of July 2025, 31 of 35 compliance recommendations from GAO's 2023 report remained unimplemented, and that M-25-21 added new requirements on top of this backlog (Source: GAO-25-107933: AI Federal Efforts Guided by Requirements and Advisory Groups).
Relationships
- supersedes: OMB Memorandum M-24-10
- depends-on: Executive Order 14179 — Removing Barriers to American Leadership in Artificial Intelligence (directive authority)
- related: OMB M-25-22 — Driving Efficient Acquisition of Artificial Intelligence in Government (companion acquisition memo), GAO-25-107933: AI Federal Efforts Guided by Requirements and Advisory Groups (compliance audit), GSA — General Services Administration (AI Deployer) (implementation vehicle), Government AI Procurement