Skip to content
GovernmentCISO

US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI) for CISOs

What does US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI) require of a CISO?

The OMB memoranda that govern how US federal agencies adopt, govern, buy and oversee AI: agency AI strategies, Chief AI Officers and governance boards, compliance plans and inventories, the high-impact AI risk management practices, the AI acquisition lifecycle with its IP, privacy, lock-in and evaluation terms, the Unbiased AI Principles requirements for procured LLMs, and the principles agencies apply when regulating private sector AI. Under US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI), which defines 23 controls, a CISO's work is deciding which controls you own outright, which you share and which belong to another team, then holding the evidence for the first group.

Which US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI) controls land on the CISO

CISOs own the organisation's information security strategy, budget, and risk posture. They translate compliance requirements into security programmes, report to the board, and balance security investment against business objectives.

US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI) defines 23 controls across 6 domains that directly affect the CISO role. Understanding which controls fall within your ownership, which are shared, and which are owned by other teams is the foundation of effective compliance management.

What a CISO is accountable for under US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI)

1

Defining and executing the information security strategy aligned to business goals

2

Presenting cyber risk posture and compliance status to the board and executive team

3

Allocating security budget across people, process, and technology investments

4

Managing the security organisation and building a security-aware culture

5

Overseeing incident response capability and crisis management readiness

Where CISOs lose time on US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI)

These are the most common obstacles CISOs face when managing US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI) compliance, and how to address them:

Challenge 1

Justifying security investment to the board with clear business metrics

Challenge 2

Managing compliance across multiple frameworks without duplicating effort

Challenge 3

Hiring and retaining qualified security professionals in a competitive market

Challenge 4

Keeping pace with evolving threats while maintaining compliance baselines

Challenge 5

Balancing security controls with business agility and user experience

A working order for a CISO starting on US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI)

1. Readiness Assessment

Take a 5-minute readiness assessment to identify your organisation's current gap profile against US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI). Get a prioritised action plan tailored to your specific situation.

2. Cross-Framework Mapping

Use our platform to map US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI) controls against other frameworks you already comply with. Identify overlapping controls to reduce duplicate effort.

3. Build Your Toolkit

Equip yourself with US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI) toolkits, self-assessments, and implementation guides from our store. Resources designed specifically for CISOs managing compliance programmes.

4. Continuous Monitoring

Establish ongoing compliance monitoring using our platform's gap analysis tools. Track your maturity over time and demonstrate progress to stakeholders.

US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI) in your sector

Who else owns part of US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI)

Questions CISOs ask about US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI)

What does a CISO need to know about US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI)?
As a CISO, your key responsibilities under US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI) include defining and executing the information security strategy aligned to business goals and presenting cyber risk posture and compliance status to the board and executive team. The framework contains 23 controls that fall within your area of responsibility. Understanding which controls you own versus which are shared with other teams is critical for effective implementation.
How does US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI) affect the CISO role?
US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI) directly impacts CISOs through defining and executing the information security strategy aligned to business goals, presenting cyber risk posture and compliance status to the board and executive team, allocating security budget across people, process, and technology investments. The framework provides structure that helps CISOs demonstrate due diligence and report compliance status to stakeholders.
What are the biggest US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI) challenges for CISOs?
Common challenges include justifying security investment to the board with clear business metrics; managing compliance across multiple frameworks without duplicating effort; hiring and retaining qualified security professionals in a competitive market. Using cross-framework mapping tools and automated evidence collection can significantly reduce these pain points.
How should a CISO prepare for a US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI) audit?
Start by conducting a readiness assessment to identify gaps. Then focus on allocating security budget across people, process, and technology investments and managing the security organisation and building a security-aware culture. Maintain a current evidence repository and ensure all control owners have documented their processes. Our readiness reports provide a prioritised action plan specific to your gap profile.
What tools help CISOs manage US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI) compliance?
Effective US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI) compliance management requires tools for gap analysis, control mapping, evidence collection, and reporting. Our compliance platform provides AI-powered gap analysis across 1,248 frameworks with 315K+ verified control-to-control mappings, helping CISOs identify overlapping requirements and reduce duplicate compliance effort.

CISO: How ready is your organisation for US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI)?

Answer 25 questions and get a professional readiness report with gap analysis, maturity scores, and prioritised action items. Results in 5 minutes.

Written and maintained by Gerard Blokdyk, The Art of Service.Last updated .