Labor & Employment Law Daily Wrap Up, REPORTS—GAO describes implementation, oversight of AI use in the federal government, (Sep 19, 2025)

By Patricia K. Ruiz, J.D.

The GAO identified 94 AI-related requirements that were government-wide or had government-wide implications.

Ten executive branch oversight groups have a role in the use of artificial intelligence by the federal government, according to a report by the Government Accountability Office (GAO). The report details the current AI-related requirements in law, executive orders, and guidance, as well as the roles and responsibilities of AI oversight and advisory groups.

Federal adoption of AI. Because of the rapid growth in capabilities and widespread adoption of AI, the federal government has taken action to counter risks posed by AI to individuals, groups, organizations, communities, society, and the environment. Federal laws, executive orders (EOs), and related guidance include various AI-related requirements to which federal offices and agencies must adhere. An October 2023 EO by President Biden (EO 14110) included more than 100 requirements for federal agencies. President Trump rescinded EO 14110 in January 2025; subsequently, the Office of Management and Budget (OMB) released two new memoranda to guide agencies in accelerating their adoption of AI.

Audit. To address its first objective—to describe federal agencies’ current AI-related requirements in laws, executive orders, and guidance—the GAO reviewed five AI-related laws, six EOs, and three guidance documents that included requirements for federal agencies. The requirements selected were current at the time of the GAO’s review and were government-wide in scope or had government-wide implications. To address its second objective—to describe the roles and responsibilities of AI oversight and advisory groups—the GAO reviewed laws, EOs, agency documentation, charters, and websites to identify and describe the roles and responsibilities of these oversight and advisory groups. The GAO conducted the audit from November 2024 to September 2025.

Findings. The GAO identified 94 AI-related requirements that were government-wide or had government-wide implications. For example, the General Services Administration is required to create an AI Center of Excellence, which affects the entire federal government. The report provides details regarding the 94 requirements, parties responsible for compliance, and frequency of the requirements. Additionally, the GAO found that ten executive branch oversight and advisory groups—such as the National AI Advisory Committee and the National AI Initiative Office—have a role in the implementation and oversight of AI in the federal government. The report details how each group was established, its position within the federal government, membership, and the responsibilities it has in the implementation of AI in the federal government.

News: Reports AgencyNews PublicEmployees AINews