OMB issues governance memo for federal agency use of AI
Agencies had until September 2024 to publish compliance plans and until December to make their AI use-case inventories public, under an order later revoked.
- Government & policy
- Notable
The White House Office of Management and Budget issued Memorandum M-24-10, “Advancing Governance, Innovation, and Risk Management for Agency Use of Artificial Intelligence,” implementing the federal-agency-use provisions of Executive Order 14110, which President Biden had signed the previous October. The memo was the first government-wide binding policy setting minimum standards for how US federal agencies could deploy AI internally, as distinct from how they regulated AI built by others.
It required every covered agency to designate a Chief AI Officer responsible for coordinating the agency’s AI use, managing associated risks and promoting adoption where appropriate, and to maintain a public inventory of its AI use cases, with exceptions for cases where disclosure would create security or law-enforcement risks. For uses the memo classified as “rights-impacting” or “safety-impacting” — decisions materially affecting benefits eligibility, medical treatment or law enforcement, for instance — agencies had to apply a defined set of minimum risk-management practices, including impact assessments, human oversight and the ability to opt out of an AI-driven decision in favour of human review, or else stop using the system and seek a waiver. Agencies were given until September 2024 to publish a compliance plan, or a written determination that they neither used nor anticipated using covered AI, and until December 2024 to make their use-case inventories public.
The memo represented a middle position between unrestricted adoption and prohibition: it did not ban any category of government AI use but made continued use conditional on documented risk management, with public transparency as the primary enforcement mechanism rather than penalties. Agencies including the Federal Reserve and the EEOC published compliance plans on the schedule the memo set.
The policy’s durability proved limited. President Trump revoked Executive Order 14110 in January 2025, and OMB’s subsequent guidance replaced M-24-10’s framework with a lighter-touch approach, leaving the March 2024 memo as a marker of one administration’s approach to federal AI governance rather than a settled standard.