America's AI Action Plan

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America's AI Action Plan, officially titled Winning the Race: America's AI Action Plan, is the Trump administration's national AI strategy released by the White House Office of Science and Technology Policy (OSTP) on July 23, 2025. The plan was the deliverable required by Executive Order 14179, "Removing Barriers to American Leadership in Artificial Intelligence," signed by President Donald Trump on January 23, 2025, which directed the Assistant to the President for Science and Technology, the Special Advisor for AI and Crypto, and the Assistant to the President for National Security Affairs to produce an AI strategy within 180 days. The 28-page document lays out more than 90 federal policy actions across three pillars: accelerating AI innovation, building American AI infrastructure, and leading in international AI diplomacy and security [1][2][3].

The plan was authored by OSTP Director Michael Kratsios, Special Advisor for AI and Crypto David Sacks, and Senior White House Policy Advisor for AI Sriram Krishnan, with input from National Security Advisor Marco Rubio and over 10,000 public comments submitted in response to a February 2025 Request for Information. Released alongside three accompanying executive orders (EO 14318, EO 14319, and EO 14320), the plan represents a sharp reversal from the Biden administration's prior approach under the now-revoked Executive Order 14110, replacing oversight and risk mitigation with deregulation, federal procurement steering, infrastructure acceleration, and aggressive AI export promotion. Vice President JD Vance and President Trump jointly unveiled the plan at a "Winning the AI Race" summit in Washington, D.C., where Trump declared the United States would treat AI as "a national mission" and an "existential race with China" [3][4][5].

Reception has split along familiar lines. Industry groups, particularly large AI labs like OpenAI, Anthropic, Google DeepMind, and Microsoft, broadly welcomed the focus on infrastructure permitting and federal compute access while raising selective concerns about export controls and the anti-DEI procurement language. The AFL-CIO and civil rights groups including the ACLU criticized the plan as "a gift to Big Tech" that strips workers and consumers of basic protections. International responses ranged from the European Union's quieter pushback through its parallel "AI Continent" plan to China's "Global AI Governance Action Plan," published just three days later on July 26, 2025, which positioned itself as a multilateral counterweight to the American export push [6][7][8].

Why was America's AI Action Plan created?

Executive Order 14179 and the 180-day clock

The AI Action Plan exists because EO 14179 ordered it into existence. Trump signed the order on January 23, 2025, three days after revoking President Biden's Executive Order 14110. EO 14179 declared a new federal posture toward artificial intelligence: the United States would "sustain and enhance America's global AI dominance" for "human flourishing, economic competitiveness, and national security," and would "promote AI development free from ideological bias or social agendas" [1][9].

The order's most consequential operational provision was Section 4, which set the 180-day deadline. Three coordinators were named to draft the plan: the Assistant to the President for Science and Technology (filled by Michael Kratsios after Senate confirmation on March 25, 2025), the Special Advisor for AI and Crypto (David Sacks, named December 5, 2024), and the Assistant to the President for National Security Affairs (Mike Waltz initially, then Marco Rubio in an acting capacity beginning May 2025). The OMB Director, the Domestic Policy Council, and the Economic Policy Council were directed to coordinate. The deadline fell on July 22, 2025; the plan was published one day late, on July 23, alongside the announcement of three follow-on executive orders [2][9].

The personnel triangle

The Trump AI policy team is unusually concentrated. Three figures took the lead in drafting the plan, all of whom are publicly credited as authors:

  • Michael Kratsios served as OSTP Director and the President's Science Advisor. He had previously served as the United States Chief Technology Officer in the first Trump administration. The Senate confirmed him 74 to 25 on March 25, 2025, making him the youngest OSTP director in the office's history and the first without a PhD.
  • David Sacks served as Special Advisor for AI and Crypto, a newly created "czar" role designed to coordinate technology policy across the executive branch. Sacks held the position as a Special Government Employee, a designation that capped his service at 130 days per year. He stepped back from the AI czar title in March 2026 while continuing to co-chair the President's Council of Advisors on Science and Technology (PCAST).
  • Sriram Krishnan, a former general partner at Andreessen Horowitz, served as Senior White House Policy Advisor for AI inside OSTP. Unlike Sacks, his role was full-time White House staff. TIME named Krishnan to its 2025 Person of the Year list as one of the "Architects of Artificial Intelligence," citing his role in writing the plan [10][11][12].

Vice President JD Vance also became a public face of the administration's AI agenda, most notably at the Paris AI Action Summit in February 2025, where he previewed many of the plan's themes.

How does it differ from Biden's framework?

The AI Action Plan sits inside a broader rejection of the Biden-era approach. EO 14110, signed October 30, 2023, had used the Defense Production Act to compel reporting from developers of dual-use foundation models trained above 10^26 floating-point operations. It directed NIST to develop the AI Risk Management Framework, created the US AI Safety Institute, and required equity reviews and red-teaming for federally used AI systems. Trump's January 20, 2025 revocation called the Biden order "unpopular, inflationary, illegal, and radical," and the AI Action Plan was the affirmative substitute. Where Biden's order leaned on compelled disclosure, the plan leans on procurement leverage, NEPA streamlining, federal land use, and export promotion. Where Biden mandated equity audits, the plan directs OMB and NIST to strip references to "misinformation, Diversity, Equity, and Inclusion, and climate change" [4][13].

The public comment process

The OSTP Request for Information

On February 6, 2025, OSTP published a Request for Information (RFI) in the Federal Register seeking public input on the development of the plan. The RFI was unusually short and open-ended, asking respondents to identify the highest-priority federal actions needed "to sustain and enhance America's AI dominance." The original comment deadline was March 15, 2025. OSTP, the National Science Foundation, and the Networking and Information Technology Research and Development (NITRD) Program coordinated the process [14][15].

When the comment window closed, NITRD reported 10,068 responses determined to be responsive to the RFI. The White House announced the figure on April 24, 2025, with OSTP staff publicly thanking submitters and signaling that the plan was being drafted to reflect the public response. In practice, the influence of the comments on the final plan was uneven: detailed technical recommendations from major AI labs and trade associations are visible in the final document, while many of the labor, civil rights, and academic submissions are not [15][16].

Major submissions

SubmitterPosition summary
OpenAICalled federal AI use "unacceptably low"; proposed waiving compliance requirements for AI pilots; urged federal preemption of state AI laws via a voluntary framework; proposed government partnerships for national security models
AnthropicProposed adding 50 GW of AI-dedicated power capacity by 2027; called for streamlined transmission permitting; supported strong NIST and CAISI evaluation roles; advocated government-wide AI workflow audits
GoogleSupported infrastructure reform and federal AI R&D investment; flagged concern that broad export controls would harm allied markets
MicrosoftPushed for expansion of countries qualifying for Tier 1 status under the (then pending) AI diffusion rule
Center for Data InnovationSupported open-weight models and federal procurement modernization
Center for Democracy & TechnologyWarned against weakening civil rights protections; opposed broad preemption
Business RoundtableBacked workforce training, federal AI adoption, and procurement reform
Center for Security and Emerging Technology (CSET)Argued for strong export controls, talent retention, and evaluation infrastructure
Center for AI SafetyCautioned against open-weighting models with frontier dangerous capabilities
AFL-CIODemanded labor representation in AI deployment decisions; opposed deregulation
Public CitizenOpposed federal preemption; called for civil rights protections

The full set of responses remains publicly accessible through NITRD. Coverage from outlets like Just Security and Platformer noted that submissions converged on three themes: lagging federal AI adoption, the need for energy and data center capacity, and federal preemption of state AI laws. They diverged sharply on safety, civil rights, and worker protections [15][16][17].

What are the three pillars of the AI Action Plan?

The plan is organized as three pillars, each containing several thematic categories with specific recommended policy actions. White House announcements and outside legal analyses cite "more than 90" actions; some implementation trackers count 103 distinct directives, depending on how broadly subitems are parsed [3][5][18]. The pillars are summarized below.

PillarThemeLead agenciesSelected priorities
I. Accelerate AI InnovationDeregulation, open source, federal AI useOSTP, OMB, NIST, NSF, FTCRemove regulatory barriers; revise NIST AI RMF; promote open-weight models; enable federal AI adoption; "unbiased AI" procurement
II. Build American AI InfrastructureData centers, energy, semiconductors, cybersecurityDOE, DOI, DOC, DOD, DHSNEPA categorical exclusions; FAST-41 expansion; federal lands for compute; CHIPS Act streamlining; secure-by-design AI standards
III. Lead in International AI Diplomacy and SecurityExports, alliances, controlsDOC, State, Treasury, DefenseAmerican AI Exports Program; "AI Alliance" of partner countries; export controls on China; counter PRC influence in international standards

Three cross-cutting priorities are layered over the pillars: protecting and promoting American workers, ensuring AI systems are "trustworthy and free from ideological bias," and safeguarding AI from misuse, theft, and adversarial exploitation [3][5].

Pillar I: Accelerate AI Innovation

The first pillar is the most explicitly deregulatory. It is also the longest and contains the bulk of the procurement, R&D, and workforce provisions.

Deregulation and federal review

Every federal agency is directed to identify and propose for revision or repeal "regulations, rules, memoranda, administrative orders, guidance documents, policy statements, and interagency agreements that unnecessarily hinder AI development or deployment." OMB is to publish guidelines for this review. The Federal Trade Commission is directed to review and consider terminating consent decrees and ongoing investigations "that unduly burden AI innovation," a clear contrast with the active AI enforcement posture of the Lina Khan FTC [3][5].

The plan also instructs OMB to identify federal funding programs whose conditions are inconsistent with the new AI policy, with a view to limiting funds flowing to states with what the administration considers "burdensome" AI regulations. This carrot-and-stick approach foreshadows the December 11, 2025 preemption executive order [3][13].

NIST AI Risk Management Framework revision

NIST is directed to revise the AI Risk Management Framework to remove references to "misinformation, Diversity, Equity, and Inclusion, and climate change." The framework, originally released in January 2023, had become a widely-cited industry reference. The plan stops short of requiring private adoption but uses federal procurement and grant conditions to push commercial AI products toward the revised framework. Through 2025 and into 2026, NIST issued updated profiles, including the AI Cyber Profile and a critical-infrastructure trustworthiness profile released in concept-note form on April 7, 2026 [18][19].

Open-source and open-weight AI

The plan endorses open-source and open-weight AI as "crucial to American AI dominance." It directs the National Science Foundation to expand access to compute resources for academic researchers, startups, and government users, and calls for an active federal posture in supporting US-developed open-source AI standards globally. This was a particular victory for AI labs like Meta and Mistral, and was also broadly supported by Anthropic and OpenAI in their RFI submissions, though OpenAI's commercial strategy is less open-weight focused [3][17].

The plan also provides for federal funding to support "frontier evaluation" of open-weight models, including evaluations of models with safety guardrails removed for adversarial testing, a workstream that was later operationalized through the Center for AI Standards and Innovation (CAISI) testing agreements signed with Google DeepMind, Microsoft, and xAI in May 2026 [20].

Federal AI adoption

A significant cluster of recommendations targets federal use of AI. The plan formalizes the Chief Artificial Intelligence Officer Council (CAIOC) as the primary venue for interagency coordination on federal AI adoption. This is notable because it preserves a structure that was originally created under Biden's EO 14110 even as the rest of Biden's framework was dismantled. The plan also creates a federal talent-exchange program to detail AI specialists across agencies, directs the General Services Administration to streamline AI procurement, and instructs the Department of Defense to integrate AI into operational workflows including planning, logistics, and intelligence [3][5].

At the Department of Defense, specific directives include refining the Responsible AI Strategy and Generative AI Roadmap, building high-security data centers for intelligence community use, and cooperating with NIST on technical standards. The plan does not assign specific funding for these tasks; the Pentagon's existing AI budgets are expected to absorb the work [3][18].

Workforce and education

The plan directs the Department of Education and the Department of Labor to expand AI-related apprenticeship pathways, support career and technical education programs that include AI skills, and authorize tax-free employer reimbursement for AI training (the latter requires legislation that has not yet passed). It calls for the establishment of an AI Workforce Research Hub to study labor-market impacts and tasks the Bureau of Labor Statistics with new AI occupational data collection. These workforce provisions were operationalized in part through Executive Order 14277 ("Advancing Artificial Intelligence Education for American Youth," signed April 23, 2025), which created the White House Task Force on AI Education chaired by the OSTP Director [3][21].

"Unbiased AI" procurement

One of the more contentious provisions: the federal government is to procure only large language models that comply with two "Unbiased AI Principles":

  1. Truth-seeking. LLMs must be "truthful in responding to user queries about factual information or analysis," prioritizing "historical accuracy, scientific inquiry, and objectivity."
  2. Ideological neutrality. LLMs must function as "neutral, nonpartisan tools that do not manipulate responses in favor of ideological dogmas such as DEI."

These principles were operationalized through Executive Order 14319 on the same day the plan was released. OMB was directed to issue implementation guidance within 120 days, which it did in late 2025 with a memorandum specifying contract clauses, vendor self-certification requirements, and waiver procedures. The provision generated substantial debate over whether it amounts to government compelled speech and whether commercial models like Claude Opus 4.7 and GPT-5 can plausibly be tuned to satisfy both criteria simultaneously [3][22][23].

Pillar II: Build American AI Infrastructure

The second pillar is where the plan's most concrete operational requirements live. It treats AI as a power-and-physics problem first and a policy problem second.

Data centers and federal lands

The plan directs the creation of new categorical exclusions under the National Environmental Policy Act for AI-related data centers and supporting infrastructure, dramatically shortening environmental review for qualifying projects. It expands the FAST-41 process for federal infrastructure permitting to cover AI projects, and instructs the Department of the Interior, the Department of Energy, and the Department of Defense to identify federal sites suitable for compute facilities. EO 14318, signed the same day, defines a "Data Center Project" as a facility requiring more than 100 megawatts of new load dedicated to AI and creates the legal framework for the new exclusions [3][24][25].

DOE moved fastest. On July 24, 2025, the day after the plan's release, the Department announced four initial federal sites for data center development: Idaho National Laboratory, the Oak Ridge Reservation in Tennessee, the Paducah Gaseous Diffusion Plant in Kentucky, and the Savannah River Site in South Carolina. In October 2025, the US Air Force solicited proposals to develop "underutilized" lands at Arnold AFB, Edwards AFB, Joint Base McGuire-Dix-Lakehurst, Davis-Monthan AFB, and Robins AFB for data center use [25][26].

Grid capacity and energy

The plan acknowledges that "American energy capacity has stagnated since the 1970s while China rapidly built out their grid" and calls for grid expansion sufficient to power the projected AI buildout. It encourages "frontier energy sources": enhanced geothermal, advanced nuclear fission, and nuclear fusion. It directs DOE to coordinate with utilities and the Federal Energy Regulatory Commission on transmission siting, and to establish technical assistance programs for state-level permitting reform. The plan also incorporates the prior Executive Order 14156 on declaring a National Energy Emergency, which Trump signed on inauguration day and renewed for another year on January 14, 2026 [3][27].

Semiconductor manufacturing

Despite Trump campaign criticism of the CHIPS and Science Act, the plan does not call for repeal. It directs the Department of Commerce to remove "extraneous policy requirements" from CHIPS Act funding, including diversity-related conditions Biden had attached to grants, while preserving the underlying domestic semiconductor manufacturing program. The plan calls for accelerated funding for advanced packaging, semiconductor equipment, and emerging technologies including photonic and neuromorphic chips [3][18].

Cybersecurity and AI-specific risk

The plan instructs the Cybersecurity and Infrastructure Security Agency (CISA) to integrate AI threats into the Cybersecurity Performance Goals, and directs NIST to develop voluntary AI-specific cybersecurity benchmarks including red-teaming guidance and incident response protocols. It calls for an AI Information Sharing and Analysis Center (AI-ISAC) to be established under DHS leadership for cross-sector threat sharing, and it instructs the Department of Defense to develop AI-tailored incident response protocols and "secure-by-design" technical standards for high-security data centers [3][5][24].

Pillar III: Lead in International AI Diplomacy and Security

The third pillar mobilizes the State Department, Commerce, and Treasury on AI exports, alliances, and controls.

The American AI Exports Program

The plan directs the Secretary of Commerce to establish the American AI Exports Program, soliciting industry-submitted "full-stack AI technology packages": hardware, models, software, applications, and standards. The program was given a launch deadline of October 21, 2025. Selected packages are designated "priority AI export packages" eligible for federal financing through the Export-Import Bank, the US International Development Finance Corporation, and similar agencies. The legal foundation is Executive Order 14320, signed on the same day as the plan [3][28][29].

The administration has framed the program as the centerpiece of an "AI Alliance": a coalition of countries committed to the US technology stack, framed in opposition to Chinese AI exports and the open-source DeepSeek lineage that emerged in early 2025. Initial reporting suggests the program has attracted submissions from major US hyperscalers and chip vendors and that the State Department has begun bilateral discussions with the Gulf states, India, Japan, South Korea, and several European countries on adoption commitments [29][30].

Export controls

The plan calls for tightening export controls on advanced compute and semiconductor manufacturing equipment, particularly with respect to China, while warning against overly broad controls that would push allied countries toward Chinese alternatives. It directs the Department of Commerce to use "location verification" and other tools to prevent diversion of chips through third countries. In May 2025, the Trump administration rescinded the Biden-era "AI diffusion rule," the tiered chip export framework that would have classified countries into three categories with different license requirements, on the basis that it was insufficiently surgical. New, narrower export rules have rolled out incrementally through 2025 and 2026 [3][31].

International standards and counter-PRC engagement

The plan directs the United States to engage "more actively" in international AI governance bodies including the International Organization for Standardization and the OECD, with a goal of countering Chinese influence in AI standardization. It does not embrace the AI Safety Summit series originating with the Bletchley Declaration of November 2023 or the Seoul Declaration of May 2024. Instead it endorses bilateral and minilateral engagement, particularly through the Quad and the G7, and through CAISI's bilateral relationship with the UK AI Security Institute (the renamed AI Safety Institute) [3][32].

Which executive orders accompanied the plan?

On July 23, 2025, Trump signed three executive orders alongside the plan. All three were published in the Federal Register on July 28, 2025. Their numbering and titles are listed below.

EO NumberTitleDate SignedFederal RegisterCore Effect
14318Accelerating Federal Permitting of Data Center InfrastructureJuly 23, 202590 FR 35379Defines AI Data Center Project; new NEPA categorical exclusions; FAST-41 expansion; federal land use; financing
14319Preventing Woke AI in the Federal GovernmentJuly 23, 202590 FR 35385Establishes "Unbiased AI Principles" for federal LLM procurement; OMB implementation guidance within 120 days
14320Promoting the Export of the American AI Technology StackJuly 23, 202590 FR 35393Establishes American AI Exports Program; designates priority packages; aligns federal financing

A fourth executive order with strong AI relevance, signed earlier in 2025, also forms part of the operative framework: EO 14277, "Advancing Artificial Intelligence Education for American Youth" (April 23, 2025), which created the White House Task Force on AI Education chaired by the OSTP Director [21].

A fifth, signed later, extended the framework to state preemption: the December 11, 2025 executive order, "Ensuring a National Policy Framework for Artificial Intelligence" (also referred to as "Eliminating State Law Obstruction of National Artificial Intelligence Policy"), which created the DOJ AI Litigation Task Force, directed FTC preemption analysis, and conditioned BEAD broadband funding on states avoiding "onerous" AI laws. The December order is structurally a follow-up to the AI Action Plan's directive to use federal funding leverage against state AI regulation [13][33].

Agency deliverables

The plan distributes more than 90 actions across the executive branch. Outside trackers, including the Center for Security and Emerging Technology and the Conference Board, have published detailed implementation matrices. The most extensive mandates fall on Commerce (especially NIST and CAISI) and the Department of Defense. The table below summarizes major agency deliverables and known status as of mid-2026.

AgencySelected deliverablesStatus
OSTPCoordinate plan implementation; chair AI Education Task Force; coordinate with NSCOn track
DOC / NIST / CAISIRevise AI RMF; lead AI Exports Program; develop AI Agent Standards Initiative; pre-deployment frontier model testingRMF revision underway; Exports Program launched October 21, 2025; AI Agent Standards Initiative announced February 2026; CAISI testing agreements with Google DeepMind, Microsoft, xAI signed May 2026
DOEIdentify federal sites for data centers; release AI Strategy and Compliance Plan; accelerate frontier energy permittingFour sites identified July 24, 2025; AI Strategy and Compliance Plan released October 2, 2025
DODRefine Responsible AI Strategy and Generative AI Roadmap; build high-security data centers; collaborate with NISTUpdated guidance released through 2025; high-security data center program ongoing
DHS / CISAEstablish AI-ISAC; integrate AI into Cybersecurity Performance Goals; AI incident responseAI-ISAC announced 2025; Cybersecurity Performance Goals updated
DOIAuthorize data center construction on federal landsInitial sites authorized 2025
NSFExpand compute access for academic researchers; AI education research; AI Workforce Research HubCompute expansion underway; some NSF programs cut concurrently due to broader budget reductions, drawing criticism
Department of Education / Department of LaborAI literacy curriculum; AI apprenticeshipsImplemented through EO 14277
OMBFederal procurement guidance within 120 days; revise M-24-10 and M-24-18Revisions issued in late 2025
FTCIssue policy statement on FTC Act preemption (per December 11, 2025 EO)Statement deadline March 2026
USPTOIssue guidance on AI inventorship and copyrightGuidance under development
GSAFirst three AI Prioritization FedRAMP 20x Low authorizationsOn track for January 2026 completion
Air ForceDevelop "underutilized" lands at five bases for data centersSolicitation issued October 2025

What was removed or de-emphasized from earlier drafts?

Reporting in July and August 2025 noted several items present in earlier drafts that were absent or substantially weakened in the final document. According to coverage in Politico, Axios, and Lawfare, the most significant changes were:

  • Limited civil rights provisions. Earlier drafts reportedly included specific algorithmic discrimination guardrails for hiring, lending, and criminal justice. The final plan does not include enforceable bias protections for these contexts, leaving them to existing statutes like Title VII and the Equal Credit Opportunity Act.
  • No DPA reporting. Where Biden's EO 14110 used the Defense Production Act to compel disclosure of frontier model training, the final plan relies on voluntary CAISI testing. Some early staff recommendations to retain a slimmer DPA-based reporting regime were dropped.
  • No explicit copyright framework. The plan punts copyright questions to USPTO and the Copyright Office for further study, despite extensive industry comments urging a definitive position on training data and fair use.
  • Workplace discrimination protections. FedScoop and labor advocates noted that the plan includes pro-worker rhetoric but does not direct EEOC or OFCCP to issue AI-specific anti-discrimination guidance for employer use.
  • Watered-down state preemption. The plan signals federal preemption ambitions through funding leverage but does not impose a categorical ban on state AI laws. The administration ultimately moved that fight to a separate December 11, 2025 executive order [22][34].

It is worth noting that some of these omissions reflect deliberate policy choices by the drafters rather than draft erosion. Both Sacks and Krishnan have argued publicly that bias mandates and disclosure regimes would slow innovation and invite legal challenges; the plan's final shape is consistent with their stated views.

How was the AI Action Plan received?

Industry

Industry response was generally favorable on infrastructure and procurement, mixed on procurement bias rules, and concerned about export controls. The Frontier Model Forum, an industry consortium of Anthropic, Google DeepMind, Microsoft, and OpenAI, released a measured statement welcoming infrastructure permitting reform and federal compute investment. Trade groups including the Information Technology Industry Council (ITI), the Business Roundtable, and the Chamber of Commerce praised the plan's deregulatory approach. The Semiconductor Industry Association applauded the export and CHIPS Act provisions [5][20][35].

Individual lab responses tracked with their RFI submissions:

  • OpenAI publicly supported the plan and its emphasis on faster procurement and federal AI use.
  • Anthropic welcomed the infrastructure pillar but signaled continued support for state-level frontier AI laws including California SB 53, creating an awkward divergence from the administration's preemption agenda. Tensions escalated through 2026 as Anthropic published a responsible scaling policy update emphasizing third-party evaluation and transparency, prompting administration officials to push back on what they saw as freelance regulatory positioning.
  • Google quietly supported the export and infrastructure provisions while expressing concerns through industry groups about overly broad chip controls.
  • Microsoft publicly endorsed the plan; CEO Satya Nadella attended the July 23 event.
  • xAI publicly endorsed the plan and the anti-DEI procurement language [16][17][20].

Labor

The AFL-CIO issued a statement on July 23 titled "Trump AI Action Plan Is 'A Gift to Big Tech.'" President Liz Shuler called the plan a vehicle to "flood U.S. markets with untested, unchecked artificial intelligence (AI) that threatens good jobs and workers' civil rights" and warned that conditioning federal funding on state AI deregulation would "strip workers of basic protections." In October 2025, the AFL-CIO launched the "Workers First Initiative on AI," a counter-blueprint for state and federal policy emphasizing collective bargaining, worker representation in AI deployment decisions, and disclosure of workplace AI use [6][36].

Academic labor groups, including the American Association of University Professors, joined civil society organizations in highlighting the absence of workplace discrimination provisions and the gutting of EEOC enforcement under the broader administration. FedScoop coverage of a labor-coalition letter to the White House noted that the plan "contains a good bit of pro-labor messaging" but "was light on details" [37].

Civil society and civil rights

Civil rights organizations have been broadly critical. The American Civil Liberties Union (ACLU), the Lawyers' Committee for Civil Rights Under Law, the Center for Democracy & Technology, the Leadership Conference on Civil and Human Rights, and Public Citizen all issued statements opposing core provisions of the plan, particularly the federal preemption pressure and the absence of algorithmic-discrimination protections [7][38][39].

The ACLU's senior policy counsel Cody Venzke called the procurement bias rules "government censorship masquerading as neutrality" and argued that "President Trump's attempt to restrict state AI regulations is not only harmful, it raises serious legal questions as the president is acting beyond any statute passed by Congress." The Center for AI and Digital Policy filed a complaint with OSTP arguing that the RFI process was inadequate and that key submissions on civil liberties were ignored. Public Citizen published a legal analysis arguing that the December 2025 follow-on preemption order rests on an unconstitutional theory of federal power [7][39][40].

Academic

Academic reception was more nuanced. Stanford HAI called the plan "an ambitious blueprint that defines AI as an existential national priority" and noted positive elements (open-source support, NSF compute, frontier evaluation) alongside concerns about safety implementation, civil liberties, and academic research funding. The Atlantic Council called the plan "a deliberative and thorough plan," citing its concrete infrastructure deliverables and "AI Alliance" framework. Brookings published a series of takes, including a critical piece by Mark MacCarthy noting that the plan undermines its own goals by "gutting the National Science Foundation through grant cancellations and staff terminations" while simultaneously asking NSF to expand AI compute access. The Center for Security and Emerging Technology (CSET) at Georgetown released a tracker of plan deliverables and noted that approximately one-third of the actions do not identify a lead agency, and no implementation timelines are given for many tasks [41][42][43][44].

The Center for AI Safety newsletter took a more sanguine view on safety, noting that while the plan is not safety-focused, it does not actively encourage release of open-weight models with frontier dangerous capabilities, and includes positive provisions like a DARPA project on interpretability and AI control, plus chemical, biological, radiological, nuclear, and explosives (CBRNE) risk research [45].

International

International reactions were dominated by the simultaneous release of competing strategies.

  • European Union. The European Commission had released its "AI Continent Action Plan" on April 9, 2025, three months before the US plan. The EU plan emphasizes AI factories, innovation hubs, talent retention, and harmonization of the EU AI Act implementation. EU officials publicly avoided direct criticism of the US plan but privately expressed concern about export-control reach into European supply chains. Through late 2025 and 2026, EU lawmakers including MEP Brando Benifei warned the Commission against "watering down" the AI Act "to appease Trump and US tech companies."
  • China. On July 26, 2025, three days after the US plan, the Chinese Ministry of Foreign Affairs released the "Global AI Governance Action Plan" at the World Artificial Intelligence Conference in Shanghai. The 13-point Chinese plan defines AI as "a global public good," calls for UN-aligned safety standards within 12 months, and proposes Shanghai as a global AI governance hub. Foreign Minister Wang Yi explicitly framed the plan as a multilateral counterweight to American "techno-unilateralism."
  • United Kingdom. The UK's separate "AI Opportunities Action Plan," published earlier in 2025, was launched in cooperation with the Trump administration's pro-innovation stance. UK Technology Secretary Peter Kyle's February 14, 2025 announcement at the Munich Security Conference renaming the UK AI Safety Institute to the AI Security Institute mirrored the US CAISI rebrand. The UK and US institutes signed an interoperability agreement in April 2025.
  • India, Japan, Korea, Gulf states. All publicly welcomed the export and alliance provisions and have engaged in bilateral discussions on the AI Alliance framework [8][32][46][47].

Implementation status as of May 2026

Nearly two years on from EO 14179 and ten months from the plan's release, implementation is partial and uneven.

Shipped and operational:

  • Three accompanying executive orders (14318, 14319, 14320) signed and published in Federal Register July 28, 2025
  • December 11, 2025 preemption executive order signed
  • DOE four federal sites identified (Idaho, Oak Ridge, Paducah, Savannah River)
  • Air Force five-base data center solicitation issued October 2025
  • American AI Exports Program launched October 21, 2025
  • DOE AI Strategy and Compliance Plan released October 2, 2025
  • OMB procurement guidance issued late 2025
  • CAISI rebrand from US AI Safety Institute (June 2025) and renegotiated testing agreements with Anthropic, OpenAI
  • CAISI testing agreements with Google DeepMind, Microsoft, and xAI (May 2026)
  • NIST AI Agent Standards Initiative announced February 2026
  • White House Task Force on AI Education established under EO 14277
  • DOJ AI Litigation Task Force established (per December EO)

In progress or partial:

  • NIST AI Risk Management Framework revision: ongoing through addenda and profiles; final revised version not yet released
  • AI Workforce Research Hub: framework released, full operations pending appropriations
  • Federal land data center construction: permits in review; major construction not yet begun
  • AI Information Sharing and Analysis Center: stood up, operational scope expanding
  • AI Alliance country commitments: bilateral discussions ongoing, no formal multi-country charter

Slipped or unfunded:

  • Many provisions lack identified lead agencies or appropriations; CSET trackers note approximately one-third of the actions are agency-anonymous
  • Tax-free employer reimbursement for AI training requires legislation that has not passed
  • Specific FERC permitting reform requires regulatory action that has been incremental
  • USPTO copyright and inventorship guidance: study phase
  • Stargate Project, the $500 billion private buildout announced January 21, 2025 by Trump alongside Sam Altman, Larry Ellison, and Masayoshi Son, has reportedly faced significant delays due to commercial disputes among partners, though OpenAI announced in 2026 that combined planned capacity across announced sites had reached nearly 7 gigawatts. Stargate is not formally part of the AI Action Plan but is treated by the administration as the private-sector counterpart to the plan's infrastructure pillar [48][49].

Connection to other policies

The plan does not stand alone. It sits at the center of an interconnected federal AI framework:

  • EO 14179 (January 23, 2025) is the legal foundation; the plan is its required deliverable.
  • EO 14156 (January 20, 2025) declared a national energy emergency and provides cover for fast-track power infrastructure.
  • The Stargate Project announcement of January 21, 2025 ($500 billion private commitment from OpenAI, SoftBank, Oracle, and MGX) functions as the private-sector counterpart.
  • EO 14277 (April 23, 2025) implements the workforce and education provisions.
  • EOs 14318, 14319, 14320 (July 23, 2025) operationalize specific plan provisions on permitting, procurement, and exports.
  • The CAISI rebrand (June 2025) effectively reorients NIST's AI evaluation work toward the plan's competitiveness frame, even though the rebrand itself preceded the plan.
  • EO of December 11, 2025 ("Ensuring a National Policy Framework for AI") extends the plan's federal-preemption logic into active legal challenge of state AI laws.
  • California SB 53 and other state laws operate in tension with the federal framework; the federal preemption push is a direct response to state-level California SB 53 and similar legislation.
  • CHIPS and Science Act funding continues but is being reshaped by the plan's directive to remove "extraneous" conditions.

The plan also affects parallel international institutions. The Bletchley Declaration and Seoul Declaration frameworks for international AI safety cooperation were de-emphasized by JD Vance's February 2025 Paris speech, and the plan's international pillar largely bypasses the Summit framework in favor of bilateral and minilateral engagement. Voluntary commitments through the Frontier Model Forum and lab-specific responsible scaling policies continue to operate alongside the federal framework, with US labs in some cases aligning more closely with the EU AI Act's transparency requirements than with the plan's procurement standards [4][13][32].

How does the AI Action Plan compare with Biden's EO 14110?

The gap between the plan and the Biden-era framework can be summarized as follows.

DimensionEO 14110 (Biden, October 2023, revoked January 2025)AI Action Plan and EO 14179 framework
Core postureRisk mitigation, oversight, equityInnovation, dominance, deregulation
Authority usedDefense Production Act for compelled reportingProcurement, NEPA, federal lands, exports
Industry reportingMandatory above 10^26 FLOPsVoluntary CAISI testing
Federal procurementRisk-based with equity reviewsTwo "unbiased AI principles"
Lead institutionsUS AI Safety Institute, CAIOs, AI Bill of RightsCAISI, Chief AI Officer Council, AI Litigation Task Force
State law posturePermissiveActive preemption push
Energy and infrastructureLimited focusCentral pillar; energy emergency declaration; NEPA exclusions
Watermarking and content authenticationRequired guidanceDeprioritized
ImmigrationStreamline AI talent visasRolled back
International coordinationBletchley/Seoul summit series, UK AISI partnershipParis communique declined; bilateral CAISI-AISI cooperation continues
Number of directivesMore than 100 specific actionsMore than 90 federal policy actions
Legal durabilityRevoked by next administrationSame risk; durability depends on continued executive support

See also

References

  1. The White House. "Removing Barriers to American Leadership in Artificial Intelligence." January 23, 2025. https://www.whitehouse.gov/presidential-actions/2025/01/removing-barriers-to-american-leadership-in-artificial-intelligence/
  2. Federal Register. "Removing Barriers to American Leadership in Artificial Intelligence." January 31, 2025. https://www.federalregister.gov/documents/2025/01/31/2025-02172/removing-barriers-to-american-leadership-in-artificial-intelligence
  3. The White House. "Winning the Race: America's AI Action Plan." July 23, 2025. https://www.whitehouse.gov/wp-content/uploads/2025/07/Americas-AI-Action-Plan.pdf
  4. The White House. "White House Unveils America's AI Action Plan." July 23, 2025. https://www.whitehouse.gov/releases/2025/07/white-house-unveils-americas-ai-action-plan/
  5. Skadden, Arps, Slate, Meagher & Flom LLP. "White House Releases AI Action Plan: Key Legal and Strategic Takeaways for Industry." July 2025. https://www.skadden.com/insights/publications/2025/07/the-white-house-releases-ai-action-plan
  6. AFL-CIO. "AFL-CIO: Trump AI Action Plan Is 'A Gift to Big Tech.'" July 23, 2025. https://aflcio.org/press/releases/afl-cio-trump-ai-action-plan-gift-big-tech
  7. American Civil Liberties Union. "ACLU Comment on Trump Administration's AI Action Plan." July 23, 2025. https://www.aclu.org/press-releases/aclu-comment-on-trump-administrations-ai-action-plan
  8. Atlantic Council. "Reading between the lines of the dueling US and Chinese AI action plans." 2025. https://www.atlanticcouncil.org/blogs/new-atlanticist/reading-between-the-lines-of-the-dueling-us-and-chinese-ai-action-plans/
  9. American Presidency Project. "Executive Order 14179: Removing Barriers to American Leadership in Artificial Intelligence." January 23, 2025. https://www.presidency.ucsb.edu/documents/executive-order-14179-removing-barriers-american-leadership-artificial-intelligence
  10. The White House. "Michael Kratsios Overwhelmingly Confirmed as 13th OSTP Director." March 25, 2025. https://www.whitehouse.gov/articles/2025/03/ostp-press-release/
  11. CNBC. "David Sacks says his time as Trump's crypto and AI czar has ended." March 26, 2026. https://www.cnbc.com/2026/03/26/david-sacks-trump-crypto-ai-czar.html
  12. TIME. "Person of the Year 2025: Architects of Artificial Intelligence." 2025. https://time.com/persons-of-the-year-2025-ai-architects/
  13. The White House. "Ensuring a National Policy Framework for Artificial Intelligence." December 11, 2025. https://www.whitehouse.gov/presidential-actions/2025/12/eliminating-state-law-obstruction-of-national-artificial-intelligence-policy/
  14. Federal Register. "Request for Information on the Development of an Artificial Intelligence (AI) Action Plan." February 6, 2025. https://www.federalregister.gov/documents/2025/02/06/2025-02305/request-for-information-on-the-development-of-an-artificial-intelligence-ai-action-plan
  15. The White House. "American Public Submits Over 10,000 Comments on White House's AI Action Plan." April 24, 2025. https://www.whitehouse.gov/releases/2025/04/american-public-submits-over-10000-comments-on-white-houses-ai-action-plan/
  16. Just Security. "Shaping the AI Action Plan: Responses to the White House's Request for Information." 2025. https://www.justsecurity.org/109203/us-ai-action-plan/
  17. Fortune. "What OpenAI, Google, Microsoft, and Anthropic Want From the U.S. AI Action Plan." March 17, 2025. https://fortune.com/2025/03/17/us-ai-action-plan-proposals-openai-anthropic-google-microsoft/
  18. Center for Security and Emerging Technology. "Promises and Progress: What Became of the AI Education and Workforce Executive Orders?" 2025-2026. https://cset.georgetown.edu/article/promises-and-progress/
  19. NIST. "AI Risk Management Framework." https://www.nist.gov/itl/ai-risk-management-framework
  20. Tom's Hardware. "Google, Microsoft, and xAI agree to let US government test AI models before public release." May 2026. https://www.tomshardware.com/tech-industry/artificial-intelligence/google-microsoft-and-xai-agree-to-let-us-govenment-test-ai-models-before-public-release
  21. The White House. "Advancing Artificial Intelligence Education for American Youth." April 23, 2025. https://www.whitehouse.gov/presidential-actions/2025/04/advancing-artificial-intelligence-education-for-american-youth/
  22. Paul Hastings LLP. "President Trump Signs Three Executive Orders Relating to Artificial Intelligence." July 2025. https://www.paulhastings.com/insights/client-alerts/president-trump-signs-three-executive-orders-relating-to-artificial
  23. Federal Register. "Preventing Woke AI in the Federal Government." July 28, 2025. https://www.federalregister.gov/documents/2025/07/28/2025-14217/preventing-woke-ai-in-the-federal-government
  24. Federal Register. "Accelerating Federal Permitting of Data Center Infrastructure." July 28, 2025. https://www.federalregister.gov/documents/2025/07/28/2025-14212/accelerating-federal-permitting-of-data-center-infrastructure
  25. White & Case LLP. "Trump administration issues executive order to streamline data center development." July 2025. https://www.whitecase.com/insight-alert/trump-administration-issues-executive-order-streamline-data-center-development
  26. Davis Graham. "The Trump Administration's Progress to Site Data Centers on Federal Lands." 2025. https://davisgraham.com/news-events/the-trump-administrations-progress-to-site-data-centers-on-federal-lands-initial-steps-but-work-remains/
  27. American Presidency Project. "Executive Order 14156: Declaring a National Energy Emergency." January 20, 2025. https://www.presidency.ucsb.edu/documents/executive-order-14156-declaring-national-energy-emergency
  28. Federal Register. "Promoting the Export of the American AI Technology Stack." July 28, 2025. https://www.federalregister.gov/documents/2025/07/28/2025-14218/promoting-the-export-of-the-american-ai-technology-stack
  29. The White House. "Fact Sheet: President Donald J. Trump Promotes the Export of American AI Technologies." July 23, 2025. https://www.whitehouse.gov/fact-sheets/2025/07/fact-sheet-president-donald-j-trump-promotes-the-export-of-american-ai-technologies/
  30. Torres Trade Law. "U.S. Executive Order Propels American AI Exports." 2025. https://www.torrestradelaw.com/posts/U.S.-Executive-Order-Propels-American-AI-Exports/417
  31. CNBC. "Trump administration set to end Biden's U.S. chip export restrictions." May 7, 2025. https://www.cnbc.com/2025/05/07/trump-chips-exports-nvidia.html
  32. Ministry of Foreign Affairs of the People's Republic of China. "Global AI Governance Action Plan." July 26, 2025. https://www.fmprc.gov.cn/eng/xw/zyxw/202507/t20250729_11679232.html
  33. Sidley Austin LLP. "Unpacking the December 11, 2025 Executive Order: Ensuring a National Policy Framework for Artificial Intelligence." December 23, 2025. https://www.sidley.com/en/insights/newsupdates/2025/12/unpacking-the-december-11-2025-executive-order
  34. Holland & Knight. "America's AI Action Plan: What's In, What's Out, What's Next." July 2025. https://www.hklaw.com/en/insights/publications/2025/07/americas-ai-action-plan-whats-in-whats-out-whats-next
  35. Information Technology Industry Council. "ITI Welcomes New U.S. Center for AI Standards and Innovation." 2025. https://www.itic.org/news-events/news-releases/iti-welcomes-new-u-s-center-for-ai-standards-and-innovation
  36. AFL-CIO. "AFL-CIO Launches 'Workers First Initiative on AI.'" October 2025. https://aflcio.org/press/releases/afl-cio-launches-workers-first-initiative-ai-put-american-workers-future-artificial
  37. FedScoop. "Federal AI policy needs labor-centric approach, lawmakers tell White House." 2025. https://fedscoop.com/federal-ai-policy-labor-workforce-afl-cio-white-house-letter/
  38. Lawyers' Committee for Civil Rights Under Law. "Leading Civil Rights Organizations Respond to Executive Order Seeking to Bar States from Addressing Harms Caused by Artificial Intelligence." December 2025. https://www.lawyerscommittee.org/leading-civil-rights-organizations-respond-to-executive-order-seeking-to-bar-states-from-addressing-harms-caused-by-artificial-intelligence/
  39. Public Citizen. "Legal Analysis of Leaked Draft AI Preemption Executive Order." 2025. https://www.citizen.org/article/legal-analysis-of-leaked-draft-ai-preemption-executive-order/
  40. Center for AI and Digital Policy. "AI Action Plan (OSTP 2025)." https://www.caidp.org/public-voice/ai-action-plan-ostp-2025/
  41. Stanford HAI. "Inside Trump's Ambitious AI Action Plan." 2025. https://hai.stanford.edu/news/inside-trumps-ambitious-ai-action-plan
  42. Brookings. "What to make of the Trump administration's AI Action Plan." 2025. https://www.brookings.edu/articles/what-to-make-of-the-trump-administrations-ai-action-plan/
  43. Conference Board. "Policy Backgrounder: Administration Releases AI Action Plan." 2025. https://www.conference-board.org/research/ced-policy-backgrounders/administration-releases-ai-action-plan
  44. ExecutiveGov. "White House AI Action Plan: Policy Changes Since July." 2026. https://www.executivegov.com/articles/white-house-ai-plan-policy-update
  45. Center for AI Safety. "AI Safety Newsletter #60: The AI Action Plan." 2025. https://newsletter.safe.ai/p/ai-safety-newsletter-60-the-ai-action
  46. CSIS. "The EU AI Continent Action Plan." 2025. https://www.csis.org/analysis/eu-ai-continent-action-plan
  47. Atlantic Council. "What drives the divide in transatlantic AI strategy?" 2026. https://www.atlanticcouncil.org/in-depth-research-reports/issue-brief/what-drives-the-divide-in-transatlantic-ai-strategy/
  48. OpenAI. "Announcing The Stargate Project." January 21, 2025. https://openai.com/index/announcing-the-stargate-project/
  49. OpenAI. "OpenAI, Oracle, and SoftBank expand Stargate with five new AI data center sites." 2025. https://openai.com/index/five-new-stargate-sites/

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