Your AI use is now part of your federal compliance posture.
Contracting officers are starting to ask how AI is governed inside your delivery teams. If you cannot answer in the language of NIST SP 800-171 and OMB M-24-10, your past performance score is exposed. Programs are led by Helena Rush, aligned to NIST AI RMF, with AI readiness assessments built for federal contractors.
Regulations and federal guidance that already apply
Each item below is already in force or has a confirmed enforcement date. Sources are named so your compliance team can verify in minutes.
OMB Memorandum M-24-10
Requires federal agencies to designate Chief AI Officers, inventory AI use cases, and impose minimum risk-management practices on rights- and safety-impacting AI — including AI used by contractors on agency missions.
Source: Executive Office of the President, OMB M-24-10 (March 28, 2024)
NIST AI Risk Management Framework (AI RMF 1.0)
Voluntary framework increasingly cited in federal solicitations as the expected baseline for AI governance, mapping, measurement, and management.
Source: NIST AI 100-1 (January 26, 2023)
NIST SP 800-171 Rev. 3
Protecting CUI in nonfederal systems. AI tools that ingest CUI inherit these controls, including access control, audit, and configuration management.
Source: NIST SP 800-171 Rev. 3 (May 2024)
FAR 52.204-21
Basic safeguarding of covered contractor information systems — applies to any AI tool that touches federal contract information.
Source: Federal Acquisition Regulation, 48 CFR § 52.204-21
These dates are not theoretical
Two enforcement deadlines have already passed. The next major one — EU AI Act high-risk obligations — is live below.
The Regulatory Clock Is Running
Two EU AI Act deadlines have already passed. The next — August 2, 2026 — applies to High-Risk AI across healthcare, finance, HR, education, and insurance. Full enforcement begins that date.
Source: European Commission AI Act Service Desk
Next Enforcement Deadline
2 August 2026 — High-Risk AI Full Compliance
45
Days
00
Hours
18
Minutes
06
Seconds
2 February 2025
PassedProhibited AI practices banned + AI Literacy (Article 4) obligations began.
If you have not acted, you are already non-compliant.
2 August 2025
PassedGPAI model obligations + governance infrastructure required.
If you have not acted, you are already non-compliant.
2 August 2026
NextHigh-Risk AI systems (Annex III) must be fully compliant. Article 50 Transparency rules apply. Full enforcement begins.
2 August 2027
UpcomingHigh-Risk AI embedded in regulated products (medical devices, aviation).
March 28, 2024
OMB M-24-10 in effect
Agencies must follow minimum AI risk-management practices for rights- and safety-impacting uses. Contractor-provided AI is in scope.
Source: OMB M-24-10
December 1, 2024
Agency AI use-case inventories due
Agencies began publishing AI use-case inventories. Contractor-provided AI is increasingly named in these disclosures.
Source: OMB M-24-10, §5
August 2, 2026
EU AI Act high-risk obligations apply
If you sell to or operate in the EU through a federal customer or partner, high-risk AI obligations are enforceable.
Source: Regulation (EU) 2024/1689, Article 113
The cost of getting this wrong is no longer theoretical
Real cases. Named parties. Public records. These are the precedents your board, your auditors, and your insurer will reference.
False Claims Act exposure (DOJ Civil Cyber-Fraud Initiative)
Treble damages + $13,946–$27,894 per claim
DOJ has stated misrepresenting cybersecurity (and increasingly AI) controls in federal contracts can trigger FCA liability.
Source: DOJ Civil Cyber-Fraud Initiative (October 6, 2021); 28 CFR § 85.5 penalty table
Aerojet Rocketdyne
$9 million settlement
Settled FCA case for misrepresenting compliance with DoD cybersecurity requirements — the template DOJ is now extending to AI controls.
Source: DOJ press release, July 8, 2022
Comprehensive Health Services
$930,000 settlement
First DOJ Civil Cyber-Fraud Initiative settlement — failure to maintain controls promised in federal contract.
Source: DOJ press release, March 8, 2022
Mapped to the NIST AI Risk Management Framework
Every engagement is structured around the four NIST AI RMF Core functions. Your auditors and clients already recognize this language.
NIST AI RMF — Govern
Designate an AI accountable owner; document policy aligned to OMB M-24-10 and NIST SP 800-171.
NIST AI RMF — Map
Inventory AI use cases by contract, by CUI exposure, and by rights/safety impact.
NIST AI RMF — Measure
Implement testing, red-teaming, and bias/accuracy evaluation evidence per AI RMF.
NIST AI RMF — Manage
Operate human-in-the-loop, incident response, and continuous monitoring; produce CO-ready evidence packages.
AI Governance & Compliance Studio
Two ways to start. One clear path forward.
Whether you need a fast read on your exposure or a deeper conversation about your governance strategy, NeuralEdge gives you a structured next step — never a sales pitch.
Free AI Readiness Snapshot
A 5-minute interactive self-assessment scored against the NIST AI RMF Core. See your readiness level immediately.
Get Your Free AI Readiness Snapshot30-Minute Compliance Review
A working session with a NeuralEdge consultant. Bring your questions, leave with a clear action list.
Book a 30-Minute Compliance ReviewFrequently asked questions
Does OMB M-24-10 apply to contractors directly?
It binds agencies, but agencies are passing the obligations down through solicitations and contract clauses. If you provide AI used in a rights- or safety-impacting capacity, expect to demonstrate the same minimum practices.
Is the NIST AI RMF mandatory for federal contractors?
Not yet by statute. It is, however, the most widely cited framework in federal AI guidance and is appearing in solicitation language as the expected baseline. Adopting it now is a defensible position.
What happens if my AI tool processes CUI?
It inherits NIST SP 800-171 controls. That includes access control, audit logging, configuration management, and incident response — applied to the AI system, its training data, and its outputs.
How quickly can we be CO-review-ready?
A baseline AI governance package — inventory, policy, control mapping, evidence library — typically takes 4–6 weeks. We deliver it mapped to the frameworks your CO already recognizes.