HWG Advisory
By Austin Bonner and Alex Tate
On October 20, 2026, the Department of War issued a memorandum providing guidance and templates for applying the Administration’s “Unbiased AI Principles” in procurements. The memo implements Executive Order 14319, Preventing Woke AI in the Federal Government, and OMB Memorandum M-26-04, Increasing Public Trust in Artificial Intelligence Through Unbiased AI Principles. Consistent with these documents, the Department’s stated goal is to ensure the AI products it acquires are truth-seeking and ideologically neutral, meaning that they prioritize historical accuracy, scientific inquiry, and objectivity, acknowledge uncertainty, and operate as neutral, nonpartisan tools.
The memo provides a template for documenting procurement requirements and standardized language for requesting supporting documentation from offerors and establishing contractual obligations. Required disclosures for large language model (LLM) procurements include the developer’s acceptable use policy; current model, system, or data cards that explain the model’s training, identified risks and mitigations, and relevant benchmarking scores; a description of end-user resources that explain how to use the LLM; and a description of a mechanism for the government to report outputs potentially inconsistent with the Unbiased AI Principles. Department officials may also require these disclosures for other AI products. Agencies may request additional information, including system prompts, bias evaluations, and details about overseas development or modifications made to comply with foreign government requirements.
The standardized contractual language establishes continuing obligations for contractors. It makes compliance a material contract requirement, requires updated documentation following significant model modifications, and gives contractors 15 business days to respond to written notice of noncompliant output with findings and proposed corrective action. The requirements must also flow down to subcontracts involving the acquisition, development, or integration of LLMs.
Use of the templates is optional, and Department components may tailor them to individual acquisitions. However, compliance with the underlying executive order and OMB memorandum is mandatory. Contractors should therefore review the solicitation and contract language carefully and confirm that they can satisfy both initial disclosure requirements and continuing obligations.