Skip to content
GovernmentRisk Manager

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

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

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 Risk Manager'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 Risk Manager

Risk Managers identify, assess, and prioritise organisational risks. They build risk registers, conduct risk assessments, define risk appetite, and ensure that compliance frameworks address the most material threats to the organisation.

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

1

Conducting enterprise risk assessments and maintaining the risk register

2

Defining risk appetite and tolerance levels with executive leadership

3

Mapping compliance controls to identified risks for coverage analysis

4

Monitoring key risk indicators (KRIs) and escalating emerging threats

5

Integrating compliance, operational, and strategic risk management

Where Risk Managers 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 Risk Managers 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

Quantifying cyber risk in financial terms that resonate with executives

Challenge 2

Identifying gaps between compliance control coverage and actual risk exposure

Challenge 3

Integrating risk data from siloed tools and departments

Challenge 4

Keeping risk assessments current as the threat landscape evolves

Challenge 5

Prioritising remediation when resources are limited

A working order for a Risk Manager 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 Risk Managers 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 Risk Managers ask about US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI)

What does a Risk Manager need to know about US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI)?
As a Risk Manager, your key responsibilities under US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI) include conducting enterprise risk assessments and maintaining the risk register and defining risk appetite and tolerance levels with executive leadership. 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 Risk Manager role?
US OMB AI Memoranda M-25-21 and M-25-22 (Federal Use and Acquisition of AI) directly impacts Risk Managers through conducting enterprise risk assessments and maintaining the risk register, defining risk appetite and tolerance levels with executive leadership, mapping compliance controls to identified risks for coverage analysis. The framework provides structure that helps Risk Managers 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 Risk Managers?
Common challenges include quantifying cyber risk in financial terms that resonate with executives; identifying gaps between compliance control coverage and actual risk exposure; integrating risk data from siloed tools and departments. Using cross-framework mapping tools and automated evidence collection can significantly reduce these pain points.
How should a Risk Manager 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 mapping compliance controls to identified risks for coverage analysis and monitoring key risk indicators (kris) and escalating emerging threats. 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 Risk Managers 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 Risk Managers identify overlapping requirements and reduce duplicate compliance effort.

Risk Manager: 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 .