What the Executive Order established and what survived

President Biden's Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence (October 2023) was the most comprehensive federal AI governance action in US history. It directed more than 50 actions across federal agencies, established reporting requirements for AI developers training large models, directed NIST to develop AI safety guidelines, and created sector-specific AI governance requirements across healthcare, financial services, national security, and other domains.

The Trump administration that took office in January 2025 revoked the Biden EO and issued its own AI executive order focusing on removing barriers to AI development and maintaining US leadership. However, the agency guidance issued under the Biden EO — including NIST's AI RMF profiles, healthcare AI guidance from HHS, financial services guidance from Treasury, and sector-specific frameworks — has largely remained operative. Federal agencies continue to implement their AI governance programs, and the regulatory expectations established under the Biden EO have become embedded in agency practice regardless of the change in executive direction.

Federal procurement requirements: what contractors need to know

Federal procurement requirements for AI are increasingly significant for companies that sell products or services to US government agencies. The FAR (Federal Acquisition Regulation) has been updated to include AI-related requirements for some procurement categories, and agency-specific acquisition rules have created additional requirements. The practical implications for federal contractors: AI products sold to federal agencies must meet specified security and safety standards; AI used in contract performance may be subject to disclosure requirements; and the human oversight requirements applicable to government AI use create obligations for contractors whose AI products are used by federal agencies in regulated contexts.

NIST AI RMF alignment is increasingly a de facto procurement requirement — not always explicitly required, but expected as evidence of AI governance maturity in proposal evaluation and contract management. Federal contractors that have implemented NIST AI RMF-aligned governance programs are better positioned in competitive procurements and in contract management contexts where AI governance is scrutinised.