OMB Memorandum M-26-04: Increasing Public Trust in AI Through Unbiased AI Principles
Issued by
U.S. Office of Management and Budget
- September 30, 2026 · Correction — Rewrote the entry: M-26-04 sets truth-seeking and ideological neutrality terms for federal LLM contracts, not bias testing as previously described. (Cody Maxwell)
- September 30, 2026 · Correction — Rewrote FAQ answers that invented a 1 January 2026 date, public disclosures and a Chief AI Officer attestation; linked the official memo (fact-check finding). (Cody Maxwell)
- October 1, 2026 · Correction — Rewrote the practical steps, newsletter hook, search description, and audience fields to match the entry's corrected content. (Cody Maxwell)
OMB Memorandum M-26-04, issued on 11 December 2025, implements Executive Order 14319. It requires federal agencies buying large language models to contract for two Unbiased AI Principles: truth-seeking and ideological neutrality. Vendors that fail to meet them can have contracts terminated.
Applies To
Overview
The Office of Management and Budget issued M-26-04 on 11 December 2025 to implement Executive Order 14319. It applies to federal agencies that procure large language models (LLMs). Agencies must write two principles into LLM contracts. Truth-seeking means models answer factual questions truthfully, favor historical accuracy and scientific inquiry, and acknowledge uncertainty. Ideological neutrality means models do not manipulate answers toward ideological positions, and developers do not build in partisan judgments the user did not ask for. New LLM procurements must include these requirements, and agencies had to update their procurement policies by 11 March 2026. Vendors must disclose information that lets agencies assess compliance. Non-compliance can be grounds for contract termination. Neither the order nor the memo sets a test for measuring neutrality. The memo expires two years after issue unless OMB extends it.
Key Requirements
- •Agencies must include the truth-seeking and ideological neutrality principles in contracts for large language models.
- •Agency procurement policies had to be updated by 11 March 2026.
- •Vendors must provide information that lets agencies assess whether models meet the principles.
- •Failure to comply can lead to contract termination.
- •The memo applies to federal procurement only; it creates no duties for private use of AI.
What Your Organization Must Do
- →Check whether your company sells large language models to US federal agencies after 11 December 2025.
- →Prepare contract language showing models seek truth and avoid built-in ideological positions.
- →Assemble vendor disclosure packs, including acceptable use policies and model or data cards.
- →Set up a feedback channel so agency staff can report outputs breaking the principles.
- →Brief sales and legal teams that non-compliance can be grounds for contract termination.
- →Note the memo expires two years after issue unless OMB extends it.
Playbook Guidance
Step-by-step implementation guidance for compliance teams.
Frequently Asked Questions
- Which federal agencies are required to comply with OMB M-26-04?
- It applies to executive departments, military departments, independent establishments, and wholly owned government corporations. National security systems are exempt. Its duties attach to buying large language models, and agencies may extend them to other AI models.
- Does M-26-04 impose penalties on agencies that fail to comply?
- No. M-26-04 does not establish independent enforcement penalties. Compliance is monitored through agency self-reporting and OMB oversight. However, as binding OMB guidance on executive branch entities, non-compliance can carry administrative and reputational consequences within the federal oversight process.
- What role does the Chief AI Officer play under M-26-04?
- The memo gives the Chief AI Officer no specific role or attestation duty. Agencies had to update procurement policies by 11 March 2026, including a way for staff to report outputs that break the principles.
- What must federal agencies include in AI procurement contracts under M-26-04?
- Any solicitation or order for a large language model issued after 11 December 2025 must require compliance with the Unbiased AI Principles. Vendors must also supply documents such as acceptable use policies, model or data cards, and a feedback mechanism.
- How does M-26-04 compare to OMB M-24-10 on AI governance?
- M-24-10 no longer applied, because M-25-21 replaced it on 3 April 2025. M-26-04 implements Executive Order 14319 and complements M-25-22 on AI acquisition. Its subject is truth-seeking and ideological neutrality in purchased language models.
- When must agencies publish public-facing disclosures about AI use under M-26-04?
- M-26-04 has no public disclosure requirement and no 1 January 2026 date. Its transparency rules cover documents vendors give agencies, and agencies may ask for more on public-facing models.