New OMB Memo Imposes Detailed New Disclosure Requirement on Government Contractors Utilizing LLMs - DataBreaches.Net

"Per a new memo from the Office of the Management of the Budget (OMB), when procuring LLM's, government agencies must require vendors to provide sufficient information for the agencies to be able to determine that the product complies with Unbiased A Principles and that it is not in violation of Executive Order 13960, "Promoting the Use of Trustworthy Artificial Intelligence in the Federal Government"."

"The goal of the memo is to ensure that purchased models do not run afoul of two Unbiased AI Principles, as per Executive Order 14319, "Preventing Woke Al in the Federal Government": (1) Truth-seeking: LLMs must be truthful in responding to user prompts seeking factual information or analysis, and must prioritize historical accuracy, scientific inquiry, and objectivity, and shall acknowledge uncertainty where reliable information is incomplete or contradictory."

"At minimum, agencies are requires to request from vendors: Acceptable Use Policy. A document typically drafted by the original LLM developer to characterize and differentiate appropriate and inappropriate use of their product offering. Model, System, and/or Data Cards. These materials from the LLM developer outline all essential information about the model, system, and/or data as it relates to the product offering, including summaries of the training process, identified risks and mitigations, and model evaluation scores on LLM benchmarks."

A new OMB memo requires federal agencies procuring LLMs to obtain sufficient vendor information to verify compliance with Unbiased AI Principles and Executive Order 13960. The memo enforces two principles: truth-seeking, mandating LLMs provide truthful, historically accurate, scientific, and objective responses while acknowledging uncertainty; and ideological neutrality, mandating nonpartisan outputs without intentionally encoded partisan judgments unless prompted or accessible to the user. Agencies must at minimum request an Acceptable Use Policy, Model/System/Data Cards detailing training summaries, risks, mitigations, and evaluation scores, and End User Resources to support responsible deployment.

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