As of July 23, 2025, the White House has declared AI not just a strategic priority, but an industrial, informational, and cultural revolution the U.S. intends to lead.[1] The official Action Plan organizes this imperative around three mutually reinforcing pillars: (1) Accelerating AI Innovation, (2) Building American AI Infrastructure, and (3) Leading International AI Diplomacy and Security.[2] Here, we spotlight how emerging AI policy may reshape compliance, funding access, content authentication, and licensing deals around the globe.
Under Pillar I, the Administration signals an aggressive deregulatory posture.[3] Notable actions continue the Trump Administration’s policy restructuring that began with the revocation of 2023’s Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence Order.[4] The 2025 Action Plan directs both the Office of Science and Technology Policy (OSTP) and the Office of Management and Budget (OMB) to identify and eliminate rules that constrain AI development—conditioning federal AI funding on state regulatory environments.[5] Currently, the OMB is directed to assess and potentially deny federal AI funds to states with “burdensome” AI regulations.[6] Notably, what constitutes “burdensome” in this context remains undefined by the Administration.[7] The AI Risk Management Framework from the National Institute of Standards and Technology (NIST) will be revised to remove language on misinformation, diversity, equity and, inclusion (DEI), and climate considerations.[8] The Plan also promotes procurement preferences for “objective” [9] frontier models, supports open-weight development through the National Artificial Intelligence Research Resource (NAIRR)[10] expansion, and enables regulatory sandboxes in high-risk sectors.
Pillar II addresses AI’s physical infrastructure.[11] The Administration proposes categorical exclusions for the National Environmental Policy Act (NEPA)[12] and expands treatment under the Fixing America’s Surface Transportation Act (FAST-41)[13] to accelerate permitting for data centers and energy infrastructure.[14] It also opens federal lands “for data center construction and the construction of power generation infrastructure” and supports continued use of “critical power generation sources” and “extant backup power sources” in lieu of previous administrations’ movement away from legacy fossil-fuel infrastructure.[15] Parallel efforts include reinforcing cybersecurity supply chain integrity, expanding the Creating Helpful Incentives to Produce Semiconductors for America (CHIPS)[16] program, and developing secure data centers for national security applications.[17]
Pillar III elevates AI as a core instrument of foreign policy.[18] Proposals include packaging full-stack AI export deals through the Department of Commerce and the Economic Diplomacy Action Group,[19] tightening controls on advanced compute exports with location-verification features (to monitor end-use of models in adversarial countries), and closing sub-system loopholes in semiconductor manufacturing.[20] A major focus is placed on aligning allied export restrictions and establishing a global technology diplomacy plan.[21] Concurrently, the Center for AI Standards and Innovation[22] and national security agencies are jointly tasked with assessing frontier model risks, focusing on biosecurity, cyber threats, and foreign influence in critical infrastructure.[23]
Notably absent from the Action Plan is any meaningful treatment of copyright or intellectual property. While the Administration has indicated AI-developer-friendly positions on copyright in other forums,[24] the Action Plan leaves open critical questions around the extent of copyright protection in AI-generated works, and whether fair use permits the use of copyrighted material for AI-training or the generation of outputs. For now, those questions remain with the Copyright Office and the courts. Still, the Plan introduces several compliance and transactional inflection points. Content publishers and creators should anticipate forthcoming deepfake evidentiary regimes (such as NIST’s proposed Guardians of Forensic Evidence benchmarks) [25] to authenticate AI-generated media in litigation. AI model developers conducting technology transactions with government entities may anticipate new licensing agreements around open-weight and frontier model neutrality mandates.[26]
For cloud providers and AI developers, the Plan offers both opportunity and scrutiny: preferences for open-weight models, expanded NAIRR access, and federal procurement incentives may unlock new markets, while heightened export controls, location-verification mandates, and content authentication standards will require proactive compliance planning. Regulated entities should assess their exposure to forthcoming OMB-led regulatory repeals and federal requests for information (RFIs) that may affect grant eligibility. Further, any companies that license AI to the federal government, and potentially those seeking to participate in federal incentive programs, will need to ensure their systems are “objective and free from top-down ideological bias.”[27] The Action Plan stops short of mandating this standard across the private sector, but it signals a shift toward neutrality as a condition of access to federal funding, procurement, and export approval. Given that procurement rules will soon require documentation of neutrality safeguards in foundational models (including open-weight models), AI providers will need to build in compliance documentation and/or other guardrails that demonstrate that their systems are not designed or tuned to favor particular ideologies.
The Plan is both deregulatory and prescriptive, easing friction for favored AI development while centralizing federal control over funding, procurement, and export compliance. For AI-facing entities, now is the time to audit risk exposure, align internal governance, and anticipate shifting federal incentives across the innovation lifecycle. In this rapidly evolving environment, legal and policy teams should treat the Action Plan as a foundational signal—one that will inform federal scrutiny, commercial expectations, and strategic positioning for years to come.
FOOTNOTES
[1] America’s AI Action Plan
[2] Id.
[3] Id. at 3.
[4] Executive Order 14110—Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence, October 30, 2023.
[5] America’s supra note 1 at 3.
[6] Id.
[7] See Id.
[8] Id. at 4.
[9] Id.
[10] National Artificial Intelligence Research Resource
[11] Id at 14.
[12] NEPA | National Environmental Policy Act
[13] FAST-41 | Department of Energy
[14] America’s supra note 1 at 14.
[15] Id. at 15.
[16] H.R.4346 - 117th Congress (2021-2022): CHIPS and Science Act | Congress.gov | Library of Congress
[17] America’s supra note 1 at 14–16.
[18] Id. at 20.
[19] Federal Register: Establishment of the Economic Diplomacy Action Group and Delegation of Certain Functions and Authorities Under the Championing American Business Through Diplomacy Act of 2019
[20] America at 21.
[21] Id. at 22.
[22] Center for AI Standards and Innovation (CAISI) | NIST
[23] America’s supra note 1 at 22–23.
[24] Trump derides copyright and state rules in AI Action Plan launch - POLITICO
[25] America’s supra note 1at 12–13.
[26] See id. at 4–5.
[27] Id. at 4.