LEGATESOLUTIONS
AI assurance · 2026-08-12

OMB M-25-22 and AI acquisition terms that stick

Data rights, lock-in, and CUI inference constraints belong in architecture—not only in the contract appendix.

Acquisition is architecture

M-25-22 pushes efficient acquisition of AI. The practical effect for technical teams is that data rights, model portability, and lock-in terms have to be designed into the system—not pasted into Section H after the architecture is frozen.

CUI and sensitive inference

Secure AI for controlled unclassified information usually means private networking, walled-garden or air-gapped inference, authorization-aligned control mapping, and clear model/data portability. Those are the same themes that show up in FedRAMP and ATO evidence packages.

What a good subcontractor delivers

A useful AI acquisition support package answers:

  • Where does training and inference data live?
  • Who can extract embeddings, prompts, and logs?
  • Can the agency exit the vendor without losing mission capability?
  • Which controls map to the authorization boundary before go-live?

Our related offering

Secure AI Architecture for CUI and Sensitive Data is the work package we use when a prime needs those answers as drawings and control narratives, not slideware.

Sources

Related work package

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