White House Issues Long-Awaited AI Action Plan and Accompanying Executive Orders

Key Points

• On July 23, 2025, the Trump Administration released its long-awaited AI Action Plan to establish U.S. leadership in AI, outlining over 100 policy directives issued to a broad swath of Federal agencies.
• The Action Plan follows President Trump’s January executive order (EO) revoking several Biden-era directives. It was accompanied by the issuance of three executive orders: (1) an order requiring all federal agencies to procure only LLMs that prioritize accuracy, objectivity and ideological neutrality; (2) an order fast-tracking the development of AI data centers; and (3) an order establishing the American AI Exports Program to promote global deployment of U.S.-developed full-stack AI technologies.
• White House officials expect the Action Plan’s policies to be implemented over the next six to twelve months.

Background

On July 23, 2025, the Trump Administration released its long-anticipated AI Action Plan, outlining a federal roadmap to maintain U.S. global leadership in artificial intelligence (AI). The plan serves as a guiding policy framework for AI development and reflects the Administration’s view that the United States is in a global race to set AI standards and secure military, economic and technological advantages.

The blueprint follows President Trump’s January 2025 Executive Order 14179, Removing Barriers to American Leadership in Artificial Intelligence, which revoked several Biden-era directives and directed the development of a national strategy to advance U.S. AI dominance.

The Action Plan is notably accompanied by the issuance of three executive orders:

• The first order requires all federal agencies to procure only large language models (LLMs) that prioritize accuracy, objectivity and ideological neutrality. Within 120 days, the Office of Management and Budget (OMB), in coordination with relevant federal offices, must issue implementation guidance. Agencies must then adopt compliance procedures within 90 days of receiving that guidance.
• The second order accelerates the buildout of AI data centers and supporting infrastructure by easing federal permitting, streamlining environmental reviews and expanding access to federally owned land for development. It revokes Executive Order 14141, Advancing United States Leadership in Artificial Intelligence Infrastructure, and directs the Commerce Department to launch a financial support initiative for Qualifying Projects, including loans, loan guarantees, grants, tax incentives and offtake agreements. Within 10 days, all relevant agencies must identify existing categorical exclusions under the National Environmental Policy Act (NEPA), and within 180 days, the Environmental Protection Agency (EPA) must issue guidance to expedite reuse of Brownfield and Superfund Sites and review relevant permitting regulations. The Department of the Army must review permitting under the Clean Water Act and Rivers and Harbors Act within 180 days. The Federal Permitting Improvement Steering Council (FPISC) Executive Director has 30 days to designate transparency projects for expedited review under the Fixing America’s Surface Transportation Act (FAST-41). The U.S. Department of the Interior (DOI), U.S. Department of Energy (DOE) and U.S. Department of Defense (DoD) are instructed to make available federal and military land for Qualifying Projects.
• The third order directs the Commerce Department to establish the American AI Exports Program within 90 days to promote global deployment of U.S.-developed full-stack AI technology packages and reinforce American leadership in AI standards and infrastructure. The program will be developed in consultation with the U.S. Department of State and the Office of Science and Technology Policy (OSTP), with selected industry-led proposals receiving priority designation and access to federal support. The Economic Diplomacy Action Group (EDAG), chaired by the Secretary of State, will coordinate financing tools such as loans, loan guarantees and risk insurance. The DoD, DOE, Small Business Administration (SBA) and OSTP will support review, investment coordination and export promotion. Proposals must comply with U.S. export laws and be submitted within 90 days of the public call.

The Action Plan is structured around three core pillars: (1) innovation, (2) infrastructure, and (3) international diplomacy and security. It aims to remove “bureaucratic red tape” hindering AI development, based on input from the private sector, academia and civil society. Key initiatives include streamlining permits for data centers, semiconductor manufacturing and energy infrastructure. The government will also partner with U.S. tech firms to provide “full stack AI export packages” (models, hardware, software) to allied countries, promoting U.S. technology as the global AI standard. Michael Krastios, Director of the White House’s Office of Science and Technology (OSTP), indicated that he expects the Action Plan’s policies to be executed in the next six to twelve months.

A full summary of the Action Plan’s policy directives to each agency is outlined below.

Action Plan Summary

Pillar I: Accelerate AI Innovation

The Action Plan’s first pillar aims to ensure the United States leads in the development and application of powerful AI systems by removing regulatory barriers, promoting open models, expanding access to compute, accelerating adoption and empowering American workers.

Office of Science and Technology Policy (OSTP)

• Removing Red Tape: Launch a request for information (RFI) to identify current federal regulations that hinder AI innovation and adoption.
• Encouraging Open-Source and Open-Weight AI:
  • Publish an updated National AI Research and Development (R&D) Strategic Plan to guide federal research investments and promote breakthrough innovation, including investment in theoretical, computational and experimental research, as well as a focus on AI interpretability.
  • Collaborate with the National Science Foundation (NSF) and the National Artificial Intelligence Research Resource (NAIRR) to develop a financial market for computing and improve access for startups and researchers.
• Enabling AI Adoption: Work with the U.S. Department of Energy (DOE), the Center for AI Standards and Innovation (CAISI) and the National Security Council (NSC) to assess the national security implications of foreign frontier AI projects.
• Building Scientific Datasets:
  • Direct the National Science and Technology Council (NSTC) Machine Learning and AI Subcommittee to make recommendations on minimum data quality standards for the use of biological, materials science, chemical, physical and other scientific data modalities in AI model training.
  • Explore creating a whole-genome sequencing program for life on Federal lands, led by NSTC and multiple agencies, to generate data for training biological foundation models.

Office of Management and Budget (OMB)

• Removing Red Tape: Identify, revise or repeal rules, guidance documents and interagency agreements that hinder AI development. Coordinate with agencies to consider state AI regulatory climates in funding decisions.
• Enabling AI Adoption: Create an AI procurement toolbox in coordination with the General Services Administration (GSA) to streamline access to frontier AI tools across agencies.
• Building Scientific Datasets: Promulgate OMB regulations required in the Confidential Information Protection and Statistical Efficiency Act to improve secure access to federal data.
• Accelerating AI Adoption in Government:
  • Update procurement guidelines to ensure the government contracts only with developers of large language models (LLMs) whose models are objective and free from ideological bias.
  • Formalize the Chief Artificial Intelligence Officer Council (CAIOC) as the main platform for interagency AI coordination.
  • Create a talent-exchange program to quickly detail Federal AI experts (e.g., data scientists, engineers) to agencies in need, with Office of Personnel Management (OPM) input.
  • Develop an AI procurement toolbox managed by GSA to enable uniform, customizable and compliant AI model selection across agencies, with visibility into other agencies’ AI uses.
  • Launch an Advanced Technology Transfer and Capability Sharing Program via GSA to expedite AI capability sharing between agencies.
  • Require Federal agencies to provide employees access and training for frontier language models where beneficial.
  • Establish a pilot cohort of agencies with High Impact Service Providers to expand AI use for improved public service delivery.

Federal Communications Commission (FCC)

• Removing Red Tape: Evaluate whether state AI regulations interfere with the agency’s ability to carry out its obligations and authority under the Communications Act of 1934.

Federal Trade Commission (FTC)

• Removing Red Tape:
  • Review all FTC investigations commenced under the Biden-Harris Administration to ensure that they do not advance theories of liability that unduly burden AI innovation.
  • Review all FTC final orders, consent decrees and injunctions, and, where appropriate, seek to modify or set aside any that unduly burden AI innovation.

U.S. Department of Commerce

• Ensuring Protection of Free Speech and American Values:
  • Revise the National Institute of Standards and Technology (NIST) AI Risk Management Framework to remove references to diversity, equity, and inclusion (DEI); misinformation; and climate change.
  • Through CAISI, evaluate frontier models from China for alignment with Chinese Communist Party (CCP) censorship and talking points.
• Encouraging Open-Source and Open-Weight AI:
  • Lead the NAIRR pilot efforts to give startups and researchers better access to compute, data and software in coordination with NIST, OSTP and the National Science Foundation (NSF).
  • Through the National Telecommunications and Information Administration (NTIA), convene stakeholders to drive adoption of open-source and open-weight models by small and medium-sized businesses.
• Strengthening AI Evaluation and Standards:
  • Launch an AI evaluation ecosystem with guidelines and tools via NIST and CAISI.
  • Convene biannual CAISI meetings to share AI evaluation best practices.
  • Coordinate the NIST AI Consortium to define scalable and interoperable AI measurement standards.
• Enabling AI Adoption:
  • Through NIST, launch domain-specific initiatives, develop national AI standards and measure productivity gains.
  • Through CAISI, prioritize, collect and distribute intelligence on foreign frontier AI projects with national security implications, in collaboration with DOE, the NSC, the Intelligence Community (IC) and OSTP.
• Empowering American Workers:
  • Prioritize AI skill development as a key goal of education and workforce funding, with integration into programs like career and technical education, workforce training, apprenticeships and other federally supported initiatives.
  • Through the Census Bureau and the Bureau of Economic Analysis (BEA) and in collaboration with the Bureau of Labor Statistics (BLS), use existing data to study AI’s impact on the labor market, including trends in adoption, job creation, displacement and wage effects.
• Supporting Next-Generation Manufacturing:
  • Use existing federal programs and authorities to invest in and scale foundational and translational manufacturing technologies.
  • Convene industry and government stakeholders to identify supply chain challenges to American robotics and drone manufacturing.
• Investing in AI-Enabled Science:
  • Through NIST, invest in automated, cloud-enabled labs across various scientific fields through collaboration among the private sector, federal agencies, research institutions and DOE National Laboratories.
  • Use long-term agreements to support Focused Research Organizations or other similar entities using AI and other emerging technologies.
  • Encourage public release of high-quality datasets by factoring past data contributions into grant reviews, and require federally funded researchers to disclose non-proprietary, non-sensitive datasets used in AI research.
• Building an AI Evaluation Ecosystem:
  • Through NIST, publish guidelines and resources for Federal agencies to conduct their own evaluations of AI systems.
  • Further measurement and evaluation of AI models, in collaboration with the Commerce Department, DOE, NSF and other science agencies.
  • Hold biannual CAISI-led meetings for federal agencies and researchers to share AI evaluation best practices.
  • Convene the NIST AI Consortium to develop scalable, interoperable measurement techniques and metrics that advance AI development.
• Combating Synthetic Media:
  • Consider developing NIST’s Guardians of Forensic Evidence deepfake evaluation program into a formal guideline and a companion voluntary forensic benchmark.

U.S. Department of Defense (DoD)

• Enabling AI Adoption: Regularly update joint assessments comparing AI adoption levels across the U.S., its competitors and adversaries’ national security sectors and adapt AI strategies based on new findings.
• Supporting Next-Generation Manufacturing: Use existing federal programs and authorities to invest in and scale foundational and translational manufacturing technologies.
• Investing in AI Interpretability, Control and Robustness:
  • Through the Defense Advanced Research Projects Agency (DARPA), launch a technology development program to advance AI interpretability, AI control systems and adversarial robustness.
  • Coordinate an AI hackathon initiative.
• Driving Adoption of AI Within DoD:
  • Identify DoD workforce AI skill needs and implement talent development programs to support AI adoption.
  • Establish an AI & Autonomous Systems Virtual Proving Ground by defining its technical, geographic, security and resource requirements.
  • Create a streamlined process to classify, evaluate and prioritize workflows for AI automation, transitioning successful workflows to AI quickly.
  • Secure priority access agreements with cloud providers and infrastructure operators for use during national emergencies.
  • Develop Senior Military Colleges as AI research and talent hubs.
• Protecting Commercial and Government Innovations: Along with the U.S. Department of Homeland Security (DHS), CAISI and the IC, partner with American AI developers to protect AI innovations from cyber and insider threats.

U.S. Department of Justice (DOJ)

• Combating Synthetic Media:
  • Issue guidance encouraging agencies handling adjudications to consider adopting a deepfake standard like the proposed Federal Rules of Evidence Rule 901(c).
  • File formal comments on any proposed deepfake-related additions to the Federal Rules of Evidence.

U.S. Food and Drug Administration (FDA)/Securities and Exchange Commission (SEC)

• Enabling AI Adoption: Consider establishing regulatory sandboxes or AI Centers of Excellence for researchers, startups and enterprises to rapidly deploy and test AI tools.

U.S. Department of the Treasury

• Empowering American Workers: Clarify that AI literacy and skill development programs can qualify as tax-free educational assistance under Section 132 of the Internal Revenue Code.

U.S. Department of Labor (DOL)

• Empowering American Workers:
  • Prioritize AI skill development as a key goal of education and workforce funding, with integration into programs like career and technical education, workforce training, apprenticeships and other federally supported initiatives.
  • Create an AI Workforce Research Hub to lead ongoing federal research on AI’s impact on the labor market.
  • Use discretionary funding to support rapid retraining for workers displaced by AI, issue guidance to help states identify affected workers and use Rapid Response funds to upskill those at risk of future displacement.
  • Pilot new workforce strategies to address AI-driven challenges, like worker displacement and changing skill needs, using existing authorities.

U.S. Department of Education

• Empowering American Workers: Prioritize AI skill development as a key goal of education and workforce funding, with integration into programs like career and technical education, workforce training, apprenticeships and other federally supported initiatives.

U.S. Department of Energy (DOE)

• Supporting Next-Generation Manufacturing: Use existing federal programs and authorities to invest in and scale foundational and translational manufacturing technologies.
• Investing in AI-Enabled Science: Invest in automated, cloud-enabled labs across various scientific fields through collaboration among the private sector, federal agencies, research institutions and DOE National Laboratories.
• Building Scientific Datasets: Establish secure compute environments to enable secure AI use-cases for controlled access to restricted Federal data.
• Building an AI Evaluations Ecosystem: Invest in AI testbeds for secure, real-world prototyping and market translation of AI systems.

National Science Foundation (NSF)

• Investing in AI-Enabled Science: Invest in automated, cloud-enabled labs across various scientific fields through collaboration among the private sector, federal agencies, research institutions and DOE National Laboratories.
• Building Scientific Datasets:
  • Establish secure compute environments to enable secure AI use-cases for controlled access to restricted Federal data.
  • Create an online portal for NSF’s National Secure Data Service to provide controlled access to restricted federal data for AI use cases.
• Building an AI Evaluations Ecosystem: Invest in AI testbeds for secure, real-world prototyping and market translation of AI systems.

Pillar II: Build American AI Infrastructure

The Action Plan’s second pillar focuses on building the physical and digital backbone required to sustain long-term U.S. leadership in AI. Proposals range from modernizing the grid and expanding domestic chip production to accelerating federal permitting and securing high-performance data environments.

U.S. Department of Commerce

• Streamlining AI Infrastructure Development:
  • Lead reviews of CHIPS-funded projects to eliminate non-essential requirements and ensure strong returns for taxpayers.
  • Coordinate with DOL and NSF to identify and prioritize occupations essential to AI infrastructure; integrate training models into federal investments.
• Aligning the Workforce: Coordinate with DOL to identify and prioritize occupations essential to AI infrastructure; integrate training models into federal investments.
•  Developing Technical Standards and Safeguards:
  • Develop technical standards for high-security AI data centers through NIST and CAISI, in collaboration with DoD and NSC.
  • Through NIST and CAISI, lead AI incident response planning, set assurance standards and partner with cybersecurity stakeholders to define detection and response protocols.
  • Contribute to the creation of an AI Information Sharing and Analysis Center (AI-ISAC) to support AI-specific threat intelligence across critical infrastructure sectors.

U.S. Department of Energy (DOE)

• Streamlining Permitting and Environmental Review:
  • Streamline permitting for data centers and semiconductor facilities by expanding Categorical Exclusions under the National Environmental Policy Act (NEPA) and leveraging FAST-41 for eligible infrastructure.
  • Lead environmental review modernization through AI applications, including Permit AI and expand agency participation.
  • Stabilize the existing power grid, prevent premature decommissioning of capacity and optimize grid efficiency with advanced management tools.
  • Prioritize interconnection of dispatchable power sources (e.g., enhanced geothermal, nuclear fission and fusion).
  • Coordinate hands-on training at national laboratories to prepare students and transition workers for AI infrastructure roles.
• Training a Skilled Workforce: Support industry-driven workforce training models in collaboration with the DOL, the Education Department, NSF and the Commerce Department.

U.S. Department of Labor (DOL)

• Training a Skilled Workforce:
  • Lead national initiative to define skills frameworks for high-priority AI infrastructure occupations.
  • Expand use of Registered Apprenticeships and pre-apprenticeship programs for priority occupations.
  • Coordinate with education stakeholders to promote early exposure to AI infrastructure careers and align workforce investments.

U.S. Department of Education

• Assimilating AI with Education:
  • Through the Office of Career, Technical and Adult Education (OCTAE), update state and local career and technical education programs to align with AI infrastructure needs.
  • Collaborate with DOL, DOE, NSF and the Commerce Department to support employer-led training and dual-enrollment options for AI infrastructure career paths.

U.S. Department of Defense (DoD)

• Strengthening Defense AI Standards and Cyber Preparedness:
  • Lead the creation of new technical standards for secure AI data centers for defense and intelligence applications.
  • Collaborate with NIST and the Office of the Director of National Intelligence (ODNI) on the development of responsible AI frameworks and incident response standards.
  • Coordinate with DHS and ODNI to integrate AI-specific threats and vulnerabilities into federal cyber defense planning.

Office of Science and Technology Policy (OSTP)

• Promoting Secure AI Deployment: Coordinate with NSC, OMB and cybersecurity agencies to promote secure AI deployment, vulnerability sharing and incident response preparedness.

Office of Management and Budget (OMB)

• Integrating AI Into National Security Strategy: Support reforms to integrate AI into national security and cyber response strategies, including updates to agency playbooks and funding alignment.

Pillar III: Lead in International AI Diplomacy and Security

The Action Plan’s third pillar aims to drive adoption of American AI systems, computing hardware standards throughout the world.

U.S. Department of Commerce

• Exporting American AI to Allies: Create a program to gather industry proposals for AI export packages and coordinate with key agencies to facilitate secure, U.S.-approved deals. Coordinating agencies include the Economic Diplomacy Action Group, the U.S. Trade and Development Agency, the Export-Import Bank, the U.S. International Development Finance Corporation and the U.S. Department of State.
• Strengthening AI Compute Export Control Enforcement:
  • Along with OSTP and the NSC, and in collaboration with industry, explore using location verification features on advanced AI chips to prevent their use in countries of concern.
  • Launch an effort with the IC to strengthen global chip export control enforcement by monitoring AI tech developments and expanding end-use checks in high-risk regions lacking Bureau of Industry and Security (BIS) officers.
• Closing Loopholes in Semiconductor Manufacturing Export Controls: Develop new export controls on semiconductor manufacturing sub-systems.
• Evaluating National Security Risks in Frontier Models:
  • Through CAISI, evaluate national security risks posed by frontier AI systems, in partnership with frontier AI developers and agencies with Chemical, Biological, Radiological, Nuclear and high-yield Explosives (CBRNE) and cyber expertise.
  • Through CAISI, assess security vulnerabilities and foreign influence risks from adversary AI systems used in U.S. critical infrastructure and the broader economy. The Action Plan specifies that evaluations should assess U.S. and adversary AI capabilities, foreign AI adoption and global AI competition.
  • Through NIST/CAISI, and along with DOE, DoD and the IC, prioritize hiring top AI researchers to support advanced AI evaluations and analysis.
  • Through collaboration between CAISI, national security agencies and research institutions, build and regularly update AI evaluations focused on national security.
• Aligning Protection Measures Globally:
  • Develop and share technology protection measures, including in research and education, to reduce risks from strategic adversaries. Expand initiatives for plurilateral AI tech controls, reducing reliance on multilateral treaties and aligning current and future U.S. and allied regulations.
  • Coordinate with allies to adopt U.S. export controls, develop new ones jointly and block adversaries from accessing or investing in defense suppliers.
• Investing in Biosecurity: Through CAISI, and in collaboration with national security agencies and relevant research institutions, build, maintain and update national security-related AI evaluations.

U.S. Department of State

• Countering Chinese Influence in International Governance: Along with the Commerce Department, leverage the U.S. position in international diplomatic and standard-setting bodies to promote AI governance approaches that reflect American values.
• Aligning Protection Measures Globally:
  • Create a technology diplomacy strategy for an AI global alliance to align policies and encourage allies to adopt complementary AI protections and export controls.
  • Develop and share technology protection measures, including in research and education, to reduce risks from strategic adversaries.

U.S. Department of Defense (DoD)

• Aligning Protection Measures Globally: Coordinate with allies to adopt U.S. export controls, develop new ones jointly and block adversaries from accessing or investing in defense suppliers.

Office of Science and Technology Policy (OSTP)

• Investing in Biosecurity:
  • Convene government and industry to create a data-sharing system for nucleic acid synthesis providers to identify fraudulent or malicious customers.
  • The Action Plan also proposes mandating federally funded research institutions to use nucleic acid synthesis providers with strong sequence screening and customer verification, backed by enforcement mechanisms.

Conclusion

Akin’s lobbying & public policy team continues to advise clients on navigating the evolving AI regulatory landscape and will closely track implementation of the Action Plan’s directives and the resulting opportunities for industry engagement, as well as parallel Congressional efforts to regulate AI, and keep clients apprised of key developments.