On July 23, 2025, President Donald Trump released America’s AI Action Plan (the Action Plan), a policy document setting forth the administration’s AI priorities. The Action Plan outlines a wide range of recommended agency actions organized around three pillars: (1) Accelerate AI Innovation; (2) Build American AI Infrastructure; and (3) Lead in International AI Diplomacy and Security. On the same day, President Trump signed three related executive orders: (1) “Preventing Woke AI in the Federal Government,” (2) “Accelerating Federal Permitting of Data Center Infrastructure,” and (3) “Promoting the Export of the American AI Technology Stack.” Below are key takeaways from the Action Plan and EOs highlighting areas for companies to assess how they may be affected by federal AI compliance requirements, investments in AI infrastructure, and export of AI technology.
AI Action Plan
Accelerate AI Innovation
Under the first pillar, the Action Plan declares that the federal government must “create the conditions where private-sector-led innovation can flourish,” including in the following ways:
- Deregulation: At the center of the Action Plan is a sweeping effort to deregulate in order to accelerate AI innovation and adoption. Among other recommended policy actions, Trump proposes an initiative led by the Office of Science and Technology Policy (OSTP) to launch a Request for Information to work with business and the general public to identify federal regulations that may be impeding AI innovation and to work with relevant federal agencies to take “appropriate action.” Other recommended actions include directing the OMB to work with federal agencies to consider a state’s AI regulatory regime when making decisions about whether to allocate discretionary funds and directing the FTC to review all investigations undertaken by the previous administration to ensure they do not advance theories of liability that unduly burden AI innovation.
- Protection of Free Speech and “American Values”: The Action Plan also emphasizes the importance of embedding principles of free speech into AI systems from the moment they are first developed and ensuring AI “reflects truth rather than social engineering agendas.” As such, recommended policy actions include updating federal guidelines to ensure that the federal government only contracts with frontier large language model (LLM) developers who are “free from top-down ideological bias” and revising the National Institute of Standards and Technology (NIST) AI Risk Management Framework (RMF) to eliminate references to misinformation, DEI, and climate change.
- Support of Open Source AI: At the same time, the Action Plan encourages open-weights AI models, noting their “unique value” for innovation because of their flexibility and broad availability to companies of all sizes, including startups, as well as governments and academic researchers. Recommended policy actions include fostering corporate partnerships to increase researchers’ access to private sector resources and convening other stakeholders to help drive adoption.
Build American AI Infrastructure
Under the second pillar, the Action Plan emphasizes the need for more robust American infrastructure and energy generation to support “America’s path to AI dominance,” including in the following ways:
- Grid Modernization: The Action Plan notes that domestic AI development will require massive increases in reliable energy and digital infrastructure by stabilizing the grid, better safeguarding and optimizing existing assets, and prioritizing the interconnection of “reliable, dispatchable power sources,” including nuclear and geothermal.
- Critical Infrastructure and Cyber Resilience: The Action Plan highlights the dual role of AI in both strengthening critical infrastructure and exposing it to new cybersecurity risks. As such, the Action Plan directs federal agencies to collaborate with the private sector and issue guidance to ensure AI in critical infrastructure is secure-by-design and has robust capabilities for monitoring potential adversarial attacks. Other key proposals include various information sharing initiatives, including an AI Information Sharing and Analysis Center (AI-ISAC).
Lead in International AI Diplomacy and Security
The third and final pillar makes policy recommendations geared toward maintaining America’s position as the global leader in AI by not only promoting AI within the US but also driving adoption of American AI systems globally and “preventing adversaries from free-riding on [US] innovation and investment.”
- National Security and AI Risk Evaluation: The Action Plan directs the National Institute of Standards and Technology’s (NIST) Center for AI Standards and Innovation (CAISI), within the Department of Commerce (DOC), to evaluate Frontier AI systems for national security risks in partnership with relevant agencies. An evolving AI evaluation capability will be built for national security risks of frontier models, including cyberattacks and development of chemical, biological, radiological, nuclear, or explosives weapons.
- Export Controls and Semiconductor Supply Chain Safeguards: The Action Plan commits to closing gaps in export controls by ordering DOC to implement new export controls on semiconductor manufacturing subsystems and continue CHIPS program funding, simplifying administrative processes. DOC, OSTP, and the National Security Council will work with industry to track AI chip locations for compliance.
Executive Orders
President Trump also signed three Executive Orders that echo and implement the policy directives laid out in the Action Plan:
The Executive Order on “Preventing Woke AI in the Federal Government”
- Summary: This executive order requires federal agencies to procure only large language models (LLMs) developed based on two principles: “truth-seeking” and “ideological neutrality,” concepts the order further defines. The executive order directs OMB to issue implementing guidance within 120 days and federal agencies must revise contracts and procurement procedures for LLMs in accordance with this executive order.
- Key considerations for companies: For companies offering AI-related products or services, plan for how to document successful bias and factuality evaluations, considering options like standard benchmark tests or third-party audits. Additionally, if your AI compliance program is built on the NIST RMF, be on the lookout for changes to provisions concerning bias, misinformation, and climate change, and consult with counsel on how this will impact your AI governance.
The Executive Order on “Accelerating Federal Permitting of Data Center Infrastructure”
- Summary: This executive order aims to fast-track the development of AI data centers and energy infrastructure. To do so, the executive order directs several federal initiatives. First, it outlines financial incentives for large-scale AI data centers as well as other projects for energy systems, semiconductors, networking equipment, and data storage. To qualify for financial support, these projects must involve at least $500 million in capital investment, 100 megawatts or more of power, focus on protecting national security, or otherwise be designated by federal agencies as qualifying for financial support. Federal agencies are directed to streamline environmental reviews, expedite permitting processes, and make available federal lands for projects. The executive order also revokes a Biden-era executive order outlining rules for developing AI infrastructure.
- Key considerations for companies: Consult with counsel to ensure your project qualifies and maintain documentation to clearly demonstrate eligibility for incentives and expedited treatment.
The Executive Order on “Promoting the Export of the American AI Technology Stack”
- Summary: This executive order creates a national strategy for promoting abroad “full-stack American AI technology packages.” It is intended to support American-led AI with US allies and reduce dependence on AI from US adversaries. The executive order directs the Commerce Department to create an “American AI Exports Program” to review public proposals for AI projects. Federal agencies will provide selected proposals with various forms of support–technical, financial, and diplomatic–to export the AI technology, particularly to countries allied with the US.
- Key considerations for companies: Continue analyzing export opportunities and strategies in conjunction with government releases, and consult counsel on increasing export control compliance expectations.
Conclusion
The Action Plan reflects a deregulatory and industry-aligned approach to AI governance. By prioritizing deregulation, critical infrastructure, and international competition, the Action Plan sets the stage for significant agency activity with direct implications for funding, enforcement, and compliance.
Stakeholders across sectors, from energy and telecoms to cloud computing and advanced manufacturing, should monitor implementation closely. The Action Plan’s regulatory review components, discretionary funding criteria, and export control updates could all shape the legal and operational environment for AI development in the US and abroad.
