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.

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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.

Photo of Edwin O. Childs Edwin O. Childs

As a leader of the firm’s Defense, National Security and Government Contracting industry team, Ned Childs is a government contract and investigations and enforcement attorney who represents companies across a wide range of sectors, including the defense, services, technology, and aerospace industries. His…

As a leader of the firm’s Defense, National Security and Government Contracting industry team, Ned Childs is a government contract and investigations and enforcement attorney who represents companies across a wide range of sectors, including the defense, services, technology, and aerospace industries. His practice, spanning more than a decade in Washington, encompasses a broad array of legal services, including government contract investigations, disclosures, and regulatory enforcement actions; bid protests and government contract disputes; government contract counseling; export licensing and enforcement; prime contractor-subcontractor disputes; corporate ownership and acquisition issues; and election law investigations and enforcement matters.

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. As chair of the firm’s data privacy and security team, Andrew leads a nationally recognized team of professionals dedicated to protecting clients’…

Andrew’s practice is singularly focused on protecting clients’ businesses and data, anticipating disputes, and strengthening their competitive position in the marketplace. As chair of the firm’s data privacy and security team, Andrew leads a nationally recognized team of professionals dedicated to protecting clients’ systems, networks and data, managing information, and responding to cyber incidents.

Photo of Abram J. Pafford Abram J. Pafford

Abe focuses his practice on protecting the rights and interests of companies and individuals who face disputes or conflicts with the federal government in its role as purchaser, prosecutor, and chief regulator. For more than twenty years, Abe has represented government contractors, participants…

Abe focuses his practice on protecting the rights and interests of companies and individuals who face disputes or conflicts with the federal government in its role as purchaser, prosecutor, and chief regulator. For more than twenty years, Abe has represented government contractors, participants in regulated industries, and companies and individuals targeted for federal investigation or prosecution, consistently achieving successful results for clients confronting difficult odds.

Photo of John Sullivan John Sullivan

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

Photo of Sophie Marsh Sophie Marsh

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