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GSA AI Procurement Rules Would Introduce New Disclosure and Use-Rights Requirements for Federal Contractors

By Jason M. Vespoli, Edwin O. Childs, Andrew Konia, Abram J. Pafford, John Sullivan & Sophie Marsh on April 14, 2026
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The General Services Administration Federal Acquisition Service has released draft contract terms and conditions related to AI-related procurements through a new proposed GSAR clause 552.239-7001, “Basic Safeguarding of Artificial Intelligence Systems” (February 2026), that would impose material new requirements on contractors and service providers supplying AI capabilities to the federal government. If adopted, the clause would be inserted into all solicitations and contracts for AI capabilities and would govern data rights, disclosure obligations, security protocols and performance standards for AI systems used in federal operations. Federal contractors, technology vendors, and their in-house operations and counsel teams should closely review the proposed terms, as they represent one of the most comprehensive efforts to date to regulate the procurement and use of AI systems across the federal enterprise.

The proposed clause would significantly alter the landscape for companies providing AI capabilities to the federal government. Read on to learn more about the proposed rule and its implications.

Photo of Jason M. Vespoli Jason M. Vespoli

Jason focuses his practice on federal and state procurement, government
technology, bid protests and government contract disputes, and regulatory
compliance. He utilizes experience in state government, government
technology, and complex procurement to solve problems in innovative and
efficient ways.…

Jason focuses his practice on federal and state procurement, government
technology, bid protests and government contract disputes, and regulatory
compliance. He utilizes experience in state government, government
technology, and complex procurement to solve problems in innovative and
efficient ways.

Read more about Jason M. Vespoli
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Photo of Edwin O. Childs Edwin O. Childs

As a government contracts attorney, Ned primarily represents companies in the defense, technology, and aerospace industries. His practice encompasses an array of legal services, including government contract counseling and assistance with regulatory enforcement actions, internal investigations, licensing, voluntary disclosures, regulatory compliance, and corporate…

As a government contracts attorney, Ned primarily represents companies in the defense, technology, and aerospace industries. His practice encompasses an array of legal services, including government contract counseling and assistance with regulatory enforcement actions, internal investigations, licensing, voluntary disclosures, regulatory compliance, and corporate ownership and acquisition issues.

Read more about Edwin O. Childs
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Photo of Andrew Konia Andrew Konia

Andrew’s practice is singularly focused on protecting clients’ businesses and data, anticipating disputes, and strengthening their competitive position in the marketplace.

Read more about Andrew Konia
Photo of Abram J. Pafford Abram J. Pafford

Abe is an experienced litigator who represents government contractors across the full spectrum of government contract matters, including litigation, appeals, administrative proceedings and investigations. As a member of the firm’s nationally recognized Government Investigations and White Collar department, Abe prosecutes claims arising under…

Abe is an experienced litigator who represents government contractors across the full spectrum of government contract matters, including litigation, appeals, administrative proceedings and investigations. As a member of the firm’s nationally recognized Government Investigations and White Collar department, Abe prosecutes claims arising under the Contract Disputes Act, defends against False Claims Act lawsuits initiated by the Department of Justice, and represents protestors and intervenors in pre-award and post-award bid protests before the United States Court of Federal Claims and the GAO.

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Photo of John Sullivan John Sullivan

John is an associate within the Government Investigations and White Collar Litigation group.

Read more about John Sullivan
Photo of Sophie Marsh Sophie Marsh

Sophie focuses her practice on government contracts and government investigations matters.

Read more about Sophie Marsh
  • Posted in:
    Privacy & Data Security
  • Blog:
    Password Protected
  • Organization:
    McGuireWoods LLP
  • Article: View Original Source

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