- GSA has approved revised LLM acquisition terms
- LLM data clause takes effect Oct. 19
- The 2026 FedCiv Summit will explore AI, IT modernization and more
The General Services Administration has added provisions to its acquisition regulation that require contractors and subcontractors to protect government data processed by large language models, or LLMs, Nextgov/FCW reported Thursday.
As GSA moves to strengthen protections for government data handled by contractor AI systems, federal civilian technology priorities remain in focus across government and industry. The Potomac Officers Club’s 2026 FedCiv Summit on Oct. 29 will feature discussions on powering AI across government, IT modernization, federal shared services, data and cloud infrastructure, cybersecurity and workforce enablement. Reserve your spot now to gain firsthand insights from leaders shaping the future of federal civilian technology.
The provisions appear in a memo signed by GSA Senior Procurement Executive Jeffrey Koses that approves a set of class deviations to the GSA Acquisition Regulation in support of a 2025 executive order on federal acquisition reform. The memo was first issued in January and states that GSA approved the LLM acquisition section in July, with the requirements taking effect on Oct. 19.
What Data Protections Does the GSA Memo Require?
According to Nextgov/FCW, a section of the memo titled “Basic Safeguarding of Data within Large Language Model Artificial Intelligence Systems” lists the data protections that contractors and subcontractors must have in place when their LLMs process government data.
The provisions prohibit contractors from using government data to train LLMs, to inform advertising or to sell to third parties. Contractors must also set up data handling procedures, including encrypted data transmission and audit logging systems.
Nextgov/FCW also reported that the memo exempts LLMs that contractors use internally for business purposes, as well as products in which LLM functionality is incidental to the product’s primary purpose.
What Led to GSA’s LLM Data Safeguarding Provisions?
In March, GSA’s Federal Acquisition Service released draft contract terms for AI systems acquired through federal procurement channels. The proposal would require contractors to grant the government an irrevocable license to use AI systems for any lawful government purpose, disclose model training methods and system limitations, and refrain from using federal data for model training without authorization.
In June, GSA sought public input on a revised draft clause focused on protecting government data within LLMs. The proposed clause addresses data protection, intellectual property and ethical AI development concerns and may be used in governmentwide contracts, including the Federal Supply Schedule and OASIS+ vehicles.
