How Could America’s AI Action Plan Impact Organizations and Developers?
Key Takeaways and Initial Thoughts for AI Development and Strategy Implications
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août 05, 2025
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America’s AI Action Plan, released on July 23, 2025, marks a significant shift in the U.S. federal government’s approach to artificial intelligence.1 The plan strategically positions the United States in an AI development race, emphasizing the objective to have U.S.-based AI models be the default across the globe. To achieve this, the policy framework moves away from a cautious, risk-averse stance, prioritizing instead the removal of regulatory barriers, actively spurring innovation and supporting critical infrastructure growth. This comprehensive plan outlines more than 90 federal directives, all centered around three key pillars:
- Accelerating Innovation: “The United States needs to innovate faster and more comprehensively than our competitors in the development and distribution of new AI technology across every field and dismantle unnecessary regulatory barriers that hinder the private sector in doing so.”2
- Building Infrastructure: “We need to build and maintain vast AI infrastructure and the energy to power it.”3
- Leading in International Diplomacy and Security: “We need to establish American AI — from our advanced semiconductors to our models to our applications — as the gold standard for AI worldwide and ensure our allies are building on American technology.”4
The federal government’s accelerating AI agenda introduces new strategic, regulatory and financial considerations for CFOs, general counsel, private equity firms and boards of directors. These shifts will profoundly impact how organizations deploy, monitor and scale AI responsibly, from navigating compliance risks and data governance to evaluating investment strategies and oversight frameworks.
For long-term resilience and growth, understanding where to begin and how to adapt is paramount. Below are six key impacts the action plan could have on AI model development and their implications for corporate stakeholders.
Key Impact #1: Consideration of State AI Policies in Federal Funding Decisions
What the Plan Says: “Led by the OMB [Office of Management and Budget], work with Federal agencies that have AI-related discretionary funding programs to ensure, consistent with applicable law, that they consider a state’s AI regulatory climate when making funding decisions and limit funding if the state’s AI regulatory regimes may hinder the effectiveness of that funding or award.”5
What This Means for Stakeholders:
- Federal influence on state policy: Although there isn’t a comprehensive federal AI policy yet, the directive to the OMB is a mechanism for influencing decreased regulation at the state level.
- Deployment in a variable regulatory environment: While the AI Action Plan clearly aims for deregulation, states may adopt and enact legislation that creates a more complicated regulatory environment. Chief compliance officers and boards of directors should continue to monitor and have command of each of the different environments in which they operate.
Key Impact #2: Federal Directives on AI Objectivity and Bias
What the Plan Says: “Update 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.”6
What This Means for Stakeholders:
- Developer responsibility: Developers have additional considerations when deploying model training and fine-tuning methodologies to assess whether new models meet federal requirements for objectivity and the elimination of top-down bias.
- Navigating technical and ethical complexities: Developers face the complex task of carefully assessing the impact of code changes and navigating uncertain legal and ethical implications when altering models to meet these new bias requirements.
- Key areas of scrutiny for leadership: CFOs, general counsel and board members must be especially mindful of the three key areas of bias highlighted in the action plan: misinformation, diversity and inclusion, and climate change. These categories signal where federal scrutiny is likely to intensify.
Key Impact #3: Leveraging of Sandbox Environments for AI Innovation
What the Plan Says: “Establish regulatory sandboxes or AI Centers of Excellence around the country where researchers, startups and established enterprises can rapidly deploy and test AI tools while committing to open sharing of data and results.”7
What This Means for Stakeholders:
- Avenues for accelerated development: Developers should actively monitor the release of federal sandboxes and be in a position to leverage them during the development lifecycle if they create value beyond their current operating environment.
- Strategic imperatives for leadership: CFOs, general counsel and board members must carefully assess how participation in these regulatory sandbox environments impacts data sharing practices, model updates and the adoption of emerging technology. Leaders must skillfully balance the pursuit of innovation and rapid deployment with robust legal compliance, diligent financial oversight and overarching long-term strategic goals.
Key Impact #4: Harnessing of New Public Datasets for AI Advancement
What the Plan Says: “The United States must lead the creation of the world’s largest and highest quality AI-ready scientific datasets, while maintaining respect for individual rights and ensuring civil liberties, privacy and confidentiality protections.”8
What This Means for Stakeholders:
- Expanded training and accuracy for developers: Developers should actively monitor the release of reliable nationwide datasets, which could provide additional, high-quality training data to significantly enhance model development and accuracy, especially in AI applications requiring domain-specific data and deep industry insight.
- New standards for sector-specific AI: Stakeholders in industries where domain-specific data is paramount (e.g., healthcare, financial services, national security) must be particularly mindful of new data requirements and availability. These shifts are likely to establish new, industry-accepted development standards for AI models.
Key Impact #5: Evolving Federal Evaluation Frameworks
What the Plan Says: “Evaluations are how the AI industry assesses the performance and reliability of AI systems. Rigorous evaluations can be a critical tool in defining and measuring AI reliability and performance in regulated industries. Over time, regulators should explore the use of evaluations in their application of existing law to AI systems.”9
What This Means for Stakeholders:
- Evolving model evaluation standards: Boards of directors, chief compliance officers and developers should actively monitor and evaluate how federal evaluation standards continue to evolve and assess their alignment with existing evaluation strategy. As generally accepted practices mature, adoption of these federal standards, particularly in the public sector, will be critical in shaping compliance expectations and risk frameworks.
- New standards for targeted industry: Federal contractors must closely monitor the changing agency standards for model evaluation. Staying ahead of these requirements will position them to respond rapidly to new federal procurement opportunities and align with innovation initiatives driven by NIST, DOE and other key agencies.
Key Impact #6: Fostering a “Try-First” Approach to AI Adoption
What the Plan Says: “Many of America’s most critical sectors, such as healthcare, are especially slow to adopt due to a variety of factors, including distrust or lack of understanding of the technology, a complex regulatory landscape and a lack of clear governance and risk mitigation standards. A coordinated Federal effort would be beneficial in establishing a dynamic, ‘try-first’ culture for AI across American industry.”10
What This Means for Stakeholders:
- Encouraging rapid innovation: The plan encourages a regulatory environment where companies are empowered to deploy new technologies with reduced regulatory apprehension.
- Balancing innovation and risk: Companies and their chief risk officers must proactively evaluate their risk-benefit frameworks when deploying new AI models. It’s essential to strike the right balance between accelerating innovation and diligently mitigating potential negative outcomes.
Looking Ahead: Navigating the Evolving AI Landscape
America’s AI Action Plan sets ambitious goals, but its full implementation will unfold over time as federal agencies develop specific guidance and standards. In the interim, organization should proactively position themselves by:
- Monitoring Agency-Specific Guidance: Closely track the release of implementation guidance and specific requirements from individual federal agencies.
- Reviewing Evolving State Regulations: Remain vigilant regarding changes in state-level AI regulations, as these may shift in response to or in conjunction with evolving federal standards.
- Tracking Competitive and Market Dynamics: Monitor changes in competitors’ behavior and broader market shifts influenced by the evolving regulatory framework.
Organizations should start by identifying AI use cases that align with their strategic objectives and broader business goals to prepare effectively for upcoming regulatory changes. Conducting readiness assessments can help evaluate current infrastructure, governance frameworks and workforce capabilities. Leaders should also weigh build-versus-buy decisions when deploying AI technologies, ensuring the chosen path supports scalability and compliance.
It will also be important to establish or refine development frameworks that reflect evolving regulatory expectations and to assess internal data standards and governance models to enable responsible and effective AI deployment.
By taking these essential steps, your organization can effectively navigate the complexities of this new era and unlock significant opportunities for growth and innovation.
Footnotes:
1: Executive Office of the President, "America’s AI Action Plan." The White House, (July 2025).
2: Ibid at 1.
3. Ibid.
4. Ibid.
5: Ibid at 3.
6: Ibid at 4.
7. Ibid at 5.
8. Ibid at 8.
9. Ibid at 6.
10. Ibid at 10.
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Date
août 05, 2025
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