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Version: 0.2 Draft 3

Namespace: x-ai-us-fed:

US Federal AI Governance Framework​

Jurisdiction: United States (US) Frameworks addressed: NIST Artificial Intelligence Risk Management Framework (AI RMF 1.0, 2023); OMB Memorandum M-25-21 on advancing governance, innovation, and risk management for agency use of AI (3 April 2025); OMB Memorandum M-25-22 on AI acquisition; agency-specific AI guidance from FTC, EEOC, CFPB, and DOJ. Note: Executive Order 14110 on Safe, Secure, and Trustworthy AI was rescinded on 20 January 2025. OMB Memorandum M-24-10 was rescinded and replaced by M-25-21. Registration tier: Open Review status: ai_reviewed Review date: 2026-03-20

Overview​

The US federal approach to AI governance is characterised by voluntary frameworks, agency guidance, and OMB policy rather than comprehensive legislation. Executive Order 14110 was rescinded on 20 January 2025 and its associated reporting requirements are no longer operative as executive order requirements. The current federal baseline for agency AI use is OMB Memorandum M-25-21 (April 2025), which replaced M-24-10. The NIST AI RMF 1.0 is a voluntary framework widely adopted by federal agencies and the private sector but does not prescribe standard risk tier categories. Multiple US states have enacted AI-specific legislation.

Fields​

FieldTypeRequiredDescription
x-ai-us-fed:nist_ai_rmf_profile_refstring (URI)OPTIONALReference to the organisation's NIST AI RMF profile for this AI system, documenting the risk management approach across the Govern, Map, Measure, and Manage functions.
x-ai-us-fed:omb_policy_versionenumOPTIONALThe current OMB AI policy under which this federal agency deployment is governed. Permitted values: m_25_21, m_25_22, other_current_federal_guidance. Note: M-24-10 was rescinded and replaced by M-25-21 on 3 April 2025.
x-ai-us-fed:federal_agency_use_flagbooleanOPTIONALSet to true where the AI system is used by or on behalf of a US federal agency and is subject to OMB M-25-21 requirements including minimum risk management practices, annual inventories, and designated Chief AI Officers.
x-ai-us-fed:federal_inventory_flagbooleanOPTIONALSet to true where the AI system is included in a federal agency AI inventory as required under current OMB policy.
x-ai-us-fed:algorithmic_discrimination_assessment_flagbooleanOPTIONALSet to true where an assessment has been conducted for algorithmic discrimination under applicable law including the Fair Housing Act, Equal Credit Opportunity Act, Title VII, ADA, and guidance from the FTC, EEOC, CFPB, and DOJ.
x-ai-us-fed:state_ai_law_applies_flagbooleanOPTIONALSet to true where a US state AI law applies to this AI system, including Colorado AI Act, Illinois AI Video Interview Act, New York City Local Law 144, or equivalent. The specific applicable law should be documented separately.

Revision notes (from ai_reviewed pass, 2026-03-20)​

  • Critical correction: Namespace renamed from x-ai-us-eo: to x-ai-us-fed:. Executive Order 14110 was rescinded 20 January 2025 and is not an operative federal requirement.
  • nist_ai_risk_tier removed: NIST AI RMF does not prescribe standard risk tier categories.
  • ai_generated_content_flag removed: watermarking requirement under EO 14110 is no longer operative.
  • dual_use_foundation_model_flag removed: EO 14110 reporting requirement no longer operative.
  • federal_agency_use_flag description updated to reference M-25-21 rather than M-24-10.
  • omb_policy_version added reflecting current M-25-21 and M-25-22 framework.
  • federal_inventory_flag added reflecting current OMB inventory requirements.

Citations​

  • NIST, AI RMF 1.0 (2023)
  • NIST confirmation that EO 14110 was rescinded 20 January 2025
  • OMB Memorandum M-25-21, 3 April 2025
  • OMB Memorandum M-25-22, 3 April 2025

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