This is part of an ongoing series of Covington blogs on the AI policies, executive orders, and other actions of the Trump Administration. This blog describes AI actions taken by the Trump Administration in July 2025, and prior articles in this series are available here.
White House Issues AI Action Plan
On July 23, the White House released its 28-page AI Action Plan, which outlines dozens of AI policy priorities for “near-term execution by the Federal government” in order to “achieve the President’s vision of global AI dominance.” The AI Action Plan, titled “Winning the Race: America’s AI Action Plan,” follows the submission of over 10,000 public comments in response to the White House’s February 6 Request for Information and fulfills the core requirement of President Trump’s January 23 Executive Order 14179 on “Removing Barriers to American Leadership in Artificial Intelligence,” which directed White House officials to submit an action plan for achieving the Executive Order’s policy of “sustaining and enhancing America’s global AI dominance.” As we discussed in a prior blog post, that Request for Information contained very little detail about the specifics of the administration’s plan and instead only listed broad categories of areas for public input. This Action Plan now provides detail on the administration’s proposed approach.
The AI Action Plan organizes its 103 AI policy recommendations under the three pillars of (1) accelerating AI innovation, (2) building American AI infrastructure, and (3) leading in international AI diplomacy and security. As detailed in our blog post, the AI Action Plan’s recommendations address a wide range of AI policy goals, including withholding federal AI-related funding from states with burdensome AI regulations, revising the NIST AI Risk Management Framework to “eliminate references to misinformation, Diversity, Equity, and Inclusion, and climate change,” establishing regulatory sandboxes and public-private partnerships to promote AI adoption in healthcare and other critical sectors, permitting reforms to support the development of AI infrastructure, and various initiatives to encourage AI-related manufacturing.
Notably, the AI Action Plan continues to emphasize the role of federal AI procurement as a core component of the Trump Administration’s AI agenda. In order to “deliver the highly responsive government the American people expect and deserve,” the AI Action Plan calls on the federal government to accelerate federal AI adoption and use by:
- Formalizing the role of the Chief AI Officer Council as the primary entity for interagency coordination and collaboration on AI adoption;
- Creating a talent-exchange program to enable agencies to share personnel with AI expertise, such as data scientists and software engineers;
- Creating an “AI procurement toolbox” to be spearheaded by the General Services Administration (“GSA”) to facilitate uniformity in federal adoption of AI models, and to allow federal agencies to choose among multiple models while complying with privacy, data governance, and transparency laws;
- Implementing an “Advanced Technology Transfer and Capability Sharing Program” within GSA to facilitate the rapid transfer of advanced AI capabilities and use cases across agencies;
- Requiring federal agencies to ensure that employees whose work could benefit from access to “frontier language models” are trained and able to use such models; and
- Convening “agencies with High Impact Service Providers” to pilot uses of AI for improving the delivery of public services, under the auspices of the Office of Management and Budget (“OMB”).
In parallel, the AI Action Plan notes the potential of AI to “transform both the warfighting and back-office operations” of the Department of Defense (“DOD”). To “aggressively adopt AI within its Armed Forces,” the AI Action Plan calls on DOD to (1) establish a DOD talent development program to meet the DOD’s AI workforce requirements; (2) establish an “AI & Autonomous Systems Virtual Proving Ground” within the DOD; (3) transition DOD “priority workflows” to AI-based automation; (4) prioritize DOD agreements with private entities that provide the DOD with priority access to computing resources in the event of a national emergency; and (5) developing an AI-specific curriculum and AI R&D initiatives in U.S. Senior Military Colleges.
At the same time, and consistent with President Trump’s Executive Order on “Preventing Woke AI in the Federal Government” described below, the AI Action Plan recommends updating federal procurement guidelines to ensure that the government only contracts with frontier large language model (“LLM”) developers who “ensure that their systems are objective and free from top-down ideological bias.”
President Trump Signs Series of AI Executive Orders
On July 23, President Trump signed three AI executive orders to implement the AI Action Plan’s recommendations related to AI infrastructure, “woke AI” and government procurement, and AI exports.
AI Infrastructure. Executive Order 14318 on “Accelerating Federal Permitting of Data Center Infrastructure” directs federal agencies to take various steps to accelerate the development of “qualifying projects,” i.e., data centers requiring more than 100 megawatts for AI inference, training, simulation, or synthetic data generation, and data center components, including energy infrastructure, dispatchable baseload energy sources, semiconductors and semiconductor materials, networking equipment, and data storage. Executive Order 14318 directs the Department of Commerce to launch an initiative to provide financial support for qualifying projects; directs federal agencies to establish permitting exclusions, nationwide permits, and environmental waivers for qualifying projects; and directs the Departments of Interior, Energy, and Defense to identify federal sites for the construction of qualifying projects. Additionally, Executive Order 14318 revokes the Biden Administration’s January 2025 Executive Order on “Advancing United States Leadership in Artificial Intelligence Infrastructure,” while retaining a similar emphasis on expediting permits and leasing federal lands for AI infrastructure development.
Woke AI and Government Procurement. While noting that the federal government “should be hesitant to regulate the functionality of AI models in the private marketplace,” Executive Order 14319 on “Preventing Woke AI in the Federal Government” declares that the U.S. Government “has the obligation not to procure models that sacrifice truthfulness and accuracy to ideological agendas.” Consistent with the AI Action Plan’s call to ensure that procured LLMs are “objective and free from top-down ideological bias,” Executive Order 14319 directs federal agencies to only procure LLMs that are developed in accordance with two “Unbiased AI Principles”:
- Truth-seeking. LLMs must respond truthfully to requests for factual information or analysis; prioritize historical accuracy, scientific inquiry, and objectivity; and acknowledge uncertainty.
- Ideological Neutrality. LLMs must be neutral and nonpartisan tools that do not “manipulate responses in favor of ideological dogmas such as [diversity, equity, and inclusion]” or generate outputs intentionally encoded with “partisan or ideological judgments,” unless the judgments are prompted by the end-user.
Executive Order 14319 requires OMB to issue guidance to federal agencies on implementing the Unbiased AI Principles within 120 days, i.e., by November 20, 2025. This OMB guidance must (1) account for “technical limitations” in complying with the Unbiased AI Principles, (2) permit vendors to comply with the “Ideological Neutrality” principle by disclosing LLM system prompts, specifications, evaluations, or other relevant documentation without disclosing model weights or sensitive technical data, (3) afford vendors “latitude” to comply with the Unbiased AI Principles and “take different approaches to innovation,” (4) specify the factors agencies should consider in assessing whether the Unbiased AI Principles should apply to LLMs developed by agencies or to AI models other than LLMs, and (5) provide exceptions for the use of LLMs in national security systems, as appropriate.
Upon the issuance of the OMB guidance, federal agencies will be required to include, in any new or existing federal contracts for LLMs, terms that require the procured LLM to comply with the Unbiased AI Principles and to impose “decommissioning costs” on LLM vendors that fail to comply with the Unbiased AI Principles. Federal agencies will also have 90 days after the issuance of the OMB guidance to adopt “procedures” to ensure that procured LLMs comply with the Unbiased AI Principles.
AI Exports. Executive Order 14320 on “Promoting the Export of the American AI Technology Stack” establishes the U.S. policy of preserving and extending American leadership in AI and decreasing global dependence on AI technologies developed by U.S. adversaries through the global export of “full-stack American AI technology packages,” i.e., AI hardware and networking, data pipelines and labeling systems, AI models and systems, security and cybersecurity measures, and use case-specific AI applications.
To these ends, Executive Order 14320 establishes an “American AI Exports Program” within the Department of Commerce to solicit and identify proposals for “priority AI export packages” submitted by an “industry-led consortia.” Executive Order 14320 directs the Economic Diplomacy Action Group to support priority AI export packages selected through the American AI Exports Program through the “mobilization of Federal financing tools,” including direct loans and loan guarantees, equity investments, co-financing, political risk insurance, and credit guarantees, and technical assistance and feasibility studies. Finally, Executive Order 14320 directs the Secretary of State to develop a national strategy for U.S. AI exports and identify technical and regulatory barriers that may impede U.S. AI competitiveness in partner countries, among other responsibilities.