The federal government is building a compliance framework for artificial intelligence. If your company uses AI in any capacity on a federal contract, you need to understand what is coming.
On March 6, 2026, the General Services Administration (GSA) published a proposed contract clause called "Basic Safeguarding of Artificial Intelligence Systems." The clause is designated GSAR 552.239-7001. It is the first government-wide contract clause specifically for AI.
The scope is broad. The clause applies to any "AI System" used in contract performance — not just systems you deliver to the government. If you use AI internally to generate content, analyze data, or support decisions on a federal contract, the clause covers that use.
Key provisions include a notification requirement. You must tell the government about any change to your AI system or the provider behind it. This includes changes to the model, the training data, or the underlying service.
The clause also includes decommissioning liability. When the contract ends, you are responsible for removing your AI systems from the government's environment. You must certify that all data used by or generated by the AI has been handled according to the contract's data requirements.
GSA accepted public and industry comments through April 3, 2026. The clause could appear in the next Multiple Award Schedule (MAS) refresh.
These requirements sit on top of an OMB policy stack that is already in motion. OMB Memorandum M-25-22, "Driving Efficient Acquisition of Artificial Intelligence in Government" (April 2025), sets the acquisition framework. OMB Memorandum M-26-04, "Increasing Public Trust in Artificial Intelligence Through Unbiased AI Principles" (December 2025), implements the "Unbiased AI Principles" — the requirement that large language models (LLMs) procured by federal agencies produce truthful, objective, and ideologically neutral outputs.
M-26-04 implements Section 4 of Executive Order 14319, "Preventing Woke AI in the Federal Government" (July 2025). Together, these directives tell agencies to insert contract terms requiring vendor compliance with the Unbiased AI Principles.
The Energy Department has already implemented these requirements. Policy Flash PF 2026-45, issued May 8, 2026, directs contracting officers to incorporate the M-26-04 guidance into DOE acquisitions.
What this means for contractors: start auditing your AI use. Document every AI system involved in federal contract work. Map how you would notify the government of a model change. Review your data handling practices for compliance with the decommissioning requirements. The clause is still proposed, but the policy direction is clear. These requirements are coming.
Accuracy Review — Post 4
- Confirm GSAR clause number (552.239-7001) and exact title ("Basic Safeguarding of Artificial Intelligence Systems") — verify against GSA MAS Refresh 31/32 documentation
- Verify clause status: proposed, not final. Confirm comment deadline was April 3, 2026
- Verify OMB memo references: M-25-22 (April 2025) and M-26-04 (December 2025) — exact memo numbers and dates
- Confirm Executive Order 14319 title and date: "Preventing Woke AI in the Federal Government" (July 23, 2025)
- Verify DOE PF 2026-45 implementation status — is this a final policy flash or draft?
- Confirm decommissioning liability language appears in the proposed clause text