GSA is proposing a new GSAR clause (552.239-7001) governing basic safeguarding of Government Data within Large Language Model AI systems used in federal contracts. The clause applies whenever an LLM processes Government Data, with exceptions for embedded commercial products or incidental LLM functionality. It defines key roles in the LLM supply chain (Developer, System Operator, System Integrator, Service Provider) and requires the flowdown of relevant obligations to subcontractors who fill these roles.
Key requirements include Government ownership of all data and custom developments, prohibitions on using Government Data for model training or commercial purposes, strict data handling and access-restriction safeguards, 72-hour incident notification, foreign-control risk mitigation, data portability, advance notice of material changes, and adherence to “Unbiased AI Principles” requiring truthfulness and political neutrality, with Government evaluation and remediation rights.
Comments are due August 3, 2026, with a public listening session July 14, 2026, at GW Law School. This revised draft responds to industry feedback on the January 2026 version, narrowing scope and clarifying definitions and flowdown mechanics.