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OMB AI ACQUISITION EVIDENCE

What AI evidence should vendors preserve for federal acquisition review?

A procurement-focused evidence model informed by OMB 2025 AI governance and acquisition memoranda, including M-25-21 and M-25-22.

REVIEW FUNCTION

Turn framework language into a reviewer-readable evidence position.

The objective is not to reproduce a framework as a static list. It is to identify the current AI system, preserve the evidence supplied, record accepted support and limitations, and expose unresolved dependencies before a procurement or assurance decision.

01

Prepare evidence before the questionnaire arrives

Federal buyers may ask vendors to explain system purpose, ownership, data handling, testing, human oversight, security, change management, and material limitations. The evidence should describe the system being offered now, not a prior or generic environment.

02

Preserve acquisition-relevant artifacts

The strongest package organizes records around the buyer decision rather than around internal file locations.

  • AI system and use-case inventory record
  • Model and material dependency documentation
  • Testing, evaluation, and limitation records
  • Data handling and retention documentation
  • Human oversight and escalation procedures
  • Security, incident, and change-management evidence
03

Make reviewer reconstruction possible

A reviewer should be able to identify what was supplied, which requirement it supports, who accepted the relationship, what remains unresolved, and whether the package changed after issuance.

ATO READINESS BASELINE

Establish what the current evidence can support.

The $3,500 fixed-scope Baseline covers one defined AI system and one review context. No annual license is required.