Public Sector AI Compliance: OMB M-24-10, NIST AI RMF, and the State AI Laws That Apply to Agencies
OMB Memorandum M-24-10, issued March 28, 2024, set the AI governance baseline for federal civilian agencies including risk management for rights-impacting and safety-impacting AI, a Chief AI Officer designation, and public inventories of AI use cases. The Office of Personnel Management AI guidance, the Department of Homeland Security AI framework, and DOD Responsible AI Strategy add agency-specific obligations. The NIST AI Risk Management Framework provides the technical baseline. State-level laws including Colorado SB 24-205, Connecticut SB 2, and California AB 2930 add overlays on state-agency and state-contractor AI. The architecture that supports the OMB-required risk management has the same shape as private-sector high-risk AI compliance.
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