“America’s AI Action Plan for Global Technological Dominance,” released by the White House in July 2025, marks the next significant step in the federal government’s approach to artificial intelligence. The plan is designed to secure U.S. leadership in AI by accelerating innovation, building robust infrastructure, and asserting international influence. For American businesses, especially those that use, rather than develop or deploy, AI technologies, this new policy landscape brings both new opportunities and new compliance considerations. Below, we provide a narrative overview of the most relevant aspects of the AI Action Plan and what they mean for your organization.

A New Era of Deregulation and Pro-Innovation Policy

The federal government is taking decisive steps to reduce regulatory barriers that could slow AI adoption. By rescinding previous executive orders and rolling back what it views as burdensome oversight, the Trump Administration is signaling a more permissive environment for AI use. This is particularly relevant for businesses that rely on AI tools in their operations, as the risk of sudden, restrictive federal regulation is lower. The AI Action Plan also incorporates elements of the previously proposed AI moratorium, a measure that was recently introduced as part of the budget reconciliation bill and was ultimately defeated in the Senate.

The AI Action Plan makes it clear that federal funding for AI-related initiatives may be limited in states that enact their own restrictive AI laws. This measure alone does not, however, mean that existing or emerging state laws that apply to AI models will disappear. While the president advocates for a federal standard that supersedes the patchwork of state regulation, we can expect to see a lot of activity in the state regulatory space in the coming years. As such, businesses operating across multiple states should pay close attention to both federal and state regulatory developments, as state-level rules could significantly impact access to resources as well as the overall regulatory burden.

Workforce Development and AI Literacy

Recognizing the transformative impact of AI on the workforce, the AI Action Plan places a strong emphasis on education and upskilling. Federal agencies are directed to prioritize AI skills in workforce programs, including career and technical education, apprenticeships, and rapid retraining to quickly acquire new skills or update existing ones, for workers whose roles may be affected by AI. For employers, this creates new opportunities to access federal support for employee training and upskilling. The plan also clarifies that many AI training programs may qualify for tax-free education assistance, making it easier for businesses to offer tax-advantaged reimbursement for AI-related learning.

Accelerated AI Adoption and Industry Standards

The plan calls for the creation of regulatory sandboxes and AI centers of excellence that will allow businesses to test and deploy AI tools in controlled environments with regulatory support. In addition, the government is working to develop national standards for AI use in key industries such as health care, energy, and agriculture. For businesses in these sectors, it will be important to monitor the development of the standards and ensure that their AI use aligns with emerging best practices and compliance requirements.

Security Initiatives

The plan also emphasizes the importance of cybersecurity, particularly for critical infrastructure. The government is promoting the adoption of AI-enabled cybersecurity tools and establishing an AI Information Sharing and Analysis Center (AI-ISAC) to facilitate threat-intelligence sharing. Businesses should expect new guidance on AI vulnerability management and will need to update their incident response protocols to address AI-specific risks.

International AI Diplomacy and Export Controls

On the global stage, the United States is seeking to set international standards for AI and tighten export controls on advanced AI technologies. While most users will not be directly affected by export controls, businesses with international operations or supply chains should be aware of potential changes in the availability of AI hardware and software, as well as evolving compliance requirements for cross-border data and technology flows.

Legal System and Synthetic Media

The AI Action Plan addresses the growing challenge of synthetic media, such as deepfakes, by supporting the development of new standards and forensic benchmarks for authenticating digital evidence. Businesses should be prepared for new requirements related to the use and verification of digital content, particularly in regulated industries or in the context of litigation.

Ongoing Monitoring and Compliance

The federal government will continuously evaluate the impact of AI on the labor market, national security, and critical infrastructure. This means that compliance requirements and best practices will continue to evolve. Businesses should establish processes to stay informed about regulatory changes and emerging standards, particularly in industries where AI use is subject to heightened scrutiny.

Intellectual Property Considerations

While the AI Action Plan strongly encourages the acceleration of AI innovation and infrastructure, it offers minimal guidance on intellectual property issues, copyright in particular, when it comes to training AI models. At the same time, the AI Action Plan and related federal commentary highlight the importance of access to large, high-quality datasets for AI research and model training. There is a clear recognition that data is a foundational input for AI competitiveness.

President Trump's remarks at the White House's AI Summit in July 2025 shed further light on the administration’s position. The president made clear that he views requiring AI companies to pay for every copyrighted work used in training as impractical and a barrier to American competitiveness. He likened AI learning from books and articles to how people learn, being able to access knowledge without needing to compensate every content creator. At the same time, he drew a distinction between learning from an article and plagiarizing it. The president also argued that countries such as China – referenced throughout the AI Action Plan as the United States’ adversary in the race toward global AI dominance – do not enforce stringent copyright restrictions.

The guidance from the U.S. Copyright Office, released in May 2025 in a "pre-publication version," cast doubt on whether training AI models on copyrighted works is protected by the fair use doctrine. Yet, the termination of the Register of Copyrights immediately after the release of this guidance suggests that a revised guidance is likely forthcoming. In the meantime, the determination of whether training AI models on content protected by copyright constitutes fair use is up to the courts, and there are dozens of court matters related to these issues presently pending. In the recent decisions in Bartz v. Anthropic and Kadrey v. Meta, the courts sided with AI developers but the cautious and fact-specific analysis signaled that this area of the law is still very much in flux. 

Data Security and Privacy Considerations

The Action Plan acknowledges the importance of privacy and confidentiality protections, and spends significant time discussing the need to combat the emerging security risks. At the same time, the AI Action Plan highlights the intent of the federal government to discourage or restrict current and emerging state laws impacting AI while federal standards around privacy and confidentiality related to AI are not yet available.

In addition, the AI Action Plan’s push for rapid AI innovation opens the door for AI to play a bigger role in daily life, including in health care, smart home technology, education, and employment. The expansion of AI into these industries will require careful attention as to how consumer information is handled. Large-scale processing by AI models carries the risk of profiling and data-driven surveillance systems, leading to potential data privacy harms and misuse of personal or sensitive data. 

Some states are likely to continue advancing their own AI and data protection laws, even in the face of pressure from new federal funding requirements, while others may choose to scale back their efforts. Ongoing concerns about AI-related data privacy risks are expected to fuel private litigation, which will play a significant role in shaping the evolving landscape of U.S. privacy and AI governance.

In this shifting landscape, it is essential for businesses to remain vigilant – closely monitoring state-level legislative developments, potential amendments, enforcement trends, and the broader impact of federal initiatives such as the AI Action Plan. Proactive engagement and adaptability will be critical for organizations seeking to navigate the complex and rapidly changing intersection of AI, data privacy, and regulatory compliance.

Impacts on the Insurance Industry 

The AI Action Plan is likely to have an impact on the insurance industry by accelerating the development and adoption of AI technologies. By pushing federal agencies to reduce regulatory barriers and support innovation, the AI Action Plan potentially creates opportunities for insurers to implement AI more easily in areas such as underwriting, claims processing, and fraud detection. The AI Action Plan also promotes the development of regulatory sandboxes and federal AI centers of excellence, which could give insurers more guidance to test and deploy emerging technologies. These efforts align with the broader goal of the AI Action Plan of fostering faster, safer AI integration into industries where compliance has traditionally been a limiting factor. These developments could lead to more efficient operations, improved risk modeling, and other innovations that can help to benefit the insurance industry.

At the same time, the AI Action Plan’s emphasis on rapid AI development, deployment, and deregulation introduces risks that are directly relevant to the insurers and their clients. As businesses adopt AI tools more widely, and potentially with less regulatory oversight, there may be a rise in claims related to system failures or unintended consequences from automated decision making. The AI Action Plan also highlights growing concerns around AI misuse and cybersecurity vulnerabilities, which could lead to new types of losses and coverage disputes or questions. Insurers will need to stay ahead of these developments by reassessing policy language, adjusting underwriting standards, and developing products that address the changing risk outlook raised by artificial intelligence. Overall, while the AI Action Plan creates meaningful opportunities for innovation, it also reinforces the importance of proactive risk management by insurers and their clients as AI becomes more deeply immersed in industry operations.

Conclusion

America’s AI Action Plan signals a clear federal commitment to fostering AI innovation. For most businesses, the immediate impact will be a more supportive environment for AI adoption, new opportunities for tax-advantaged workforce development, and a need to monitor the federal and state regulatory landscapes. As the government continues to refine its approach and develop industry-specific standards, it will be essential for businesses to stay engaged, ensure compliance, and leverage new resources for training and infrastructure.

The authors acknowledge the contributions made by Wilson Elser Law Graduate Wisaal Jahangir and Summer Associate Zachary Schulman.