https://www.federalregister.gov/documents/2025/07/28/2025-14...
> Sec. 4. Implementation. (a) Within 120 days of the date of this order, the Director of the Office of Management and Budget (OMB), in consultation with the Administrator for Federal Procurement Policy, the Administrator of General Services, and the Director of the Office of Science and Technology Policy, shall issue guidance to agencies to implement section 3 of this order.
A major LLM that did not submit to this would be labeled a "supply chain risk". It's unquestionable that every major LLM would go through this process
It even then goes on to say that existing contracts will be reviewed to ensure they are in compliance (reviewed by OMB)
> (b) Each agency head shall, to the maximum extent consistent with applicable law:
> (i) include in each Federal contract for an LLM entered into following the date of the OMB guidance issued under subsection (a) of this section terms requiring that the procured LLM comply with the Unbiased AI Principles and providing that decommissioning costs shall be charged to the vendor in the event of termination by the agency for the vendor’s noncompliance with the contract following a reasonable period to cure;
> (ii) to the extent practicable and consistent with contract terms, revise existing contracts for LLMs to include the terms specified in subsection (b)(i) of this section; and
> (iii) within 90 days of the OMB guidance issued under subsection (a) of this section, adopt procedures to ensure that LLMs procured by the agency comply with the Unbiased AI Principles.
[0] https://www.whitehouse.gov/wp-content/uploads/2025/12/M-26-0...
Other agencies like the NIST (lookup NIST AI Risk Management Framework), the NAIAC (which was created in 2020) are the ones like in charge of:
> Agencies’ development of metrics, methods, and standards to test and measure AI, where such metrics, methods, and standards are for use by the general public or the Government as a whole, rather than to test AI for a particular agency application
Legality isn't really of much practical concern anymore. It's about what gets/can be enforced immediately.
It takes hundreds of millions of dollars to train a model. If a large customers, the government, says they won't buy it if it doesn't adhere to a set of standards, no one is "required" to change, but it's a pretty heavy hand on the lever. It's like having a job. No one is "required" to have a job, but having one gets you money, and having money is pretty important to modern life.
I'm not claiming that this EO is sensible or enforceable, just that it's not prima facie unconstitutional.
> Implementation. (a) Within 120 days of the date of this order, the Director of the Office of Management and Budget (OMB), in consultation with the Administrator for Federal Procurement Policy, the Administrator of General Services, and the Director of the Office of Science and Technology Policy, shall issue guidance to agencies to implement section 3 of this order.
They even say they will review existing contracts
> (ii) to the extent practicable and consistent with contract terms, revise existing contracts for LLMs to include the terms specified in subsection (b)(i) of this section; and
> (iii) within 90 days of the OMB guidance issued under subsection (a) of this section, adopt procedures to ensure that LLMs procured by the agency comply with the Unbiased AI Principles.
Sec. 3
Unbiased AI Principles.
It is the policy of the United States to promote the innovation and use of trustworthy AI. To advance that policy, agency heads shall, consistent with applicable law and in consideration
of guidance issued pursuant to section 4 of this order, procure only those LLMs developed in accordance with the following two principles (Unbiased AI Principles):
(a) Truth-seeking. LLMs shall be truthful in responding to user prompts seeking factual information or analysis. LLMs shall prioritize historical accuracy, scientific inquiry, and objectivity, and shall acknowledge uncertainty where reliable information is incomplete or contradictory.
(b) Ideological Neutrality. LLMs shall be neutral, nonpartisan tools that do not manipulate responses in favor of ideological dogmas such as DEI. Developers shall not intentionally encode partisan or ideological judgments into an LLM's outputs unless those judgments are prompted by or otherwise readily accessible to the end user.
