/>iThe long-awaited White House Artificial Intelligence (AI) Action Plan (“AI Action Plan”) is here, setting forth the Trump administration’s policy recommendations to achieve the goal of “global AI dominance.”
The White House released the AI Action Plan on July 23, 2025, and delivered remarks on the plan during an AI summit. The same day, the president signed three AI-related Executive Orders to further the AI Action Plan, relating to: 1) “Accelerating Federal Permitting of Data Center Infrastructure”; 2) “Promoting the Export of the American AI Technology Stack”; and 3) “Preventing Woke AI in the Federal Government.” Yet it remains to be seen whether and how successfully the AI Action Plan will unfold—particularly with respect to impacts on incongruous state regulatory action.
Likening the global AI race to the space race during the Cold War, the introduction to the 28-page AI Action Plan emphasizes the need “to innovate faster and more comprehensively than our competitors in the development and distribution of new AI technology across every field and dismantle unnecessary regulatory barriers that hinder the private sector in doing so.”
To achieve these goals, the AI Action Plan establishes three pillars:
- Accelerating AI innovation;
- Building American AI infrastructure; and
- Leadership in international AI diplomacy and security.
The AI Action Plan proposes more than 90 federal policy actions across the three pillars and is guided by three core principles:
- ensuring that American workers benefit from the opportunities created by AI—creating higher-paying jobs for American workers—and increasing the standard of living brought about by breakthroughs in medicine, manufacturing, and many other fields;
- ensuring that AI systems are free from “ideological bias and [] designed to pursue objective truth rather than social engineering agendas when users seek factual information or analysis”; and
- preventing America’s advanced technologies from being misused or stolen by malicious actors, as well as monitoring risk.
As we noted in our July 18 and July 22 posts, the AI Action Plan stems from Executive Order 14179, “Removing Barriers to American Leadership in Artificial Intelligence” (“E.O. 14179”), issued by the president on January 23, 2025. White House Office of Science and Technology Policy Director Michael Kratsios, AI and Crypto Czar David Sacks, and Secretary of State and Acting National Security Advisor Marco Rubio had primary responsibility for developing the AI Action Plan.
Pillar One: Accelerating AI Innovation
Perhaps most notably, the AI Action Plan seeks to quash “burdensome” state regulation of AI. This policy stance comes at the heels of the unsuccessful attempt to include a statutory moratorium on state regulation of AI which was proposed as part of the One Big Beautiful Bill Act (HB 1) (“OBBBA”) legislative process.
While the proposed moratorium did not survive that process, the AI Action Plan takes a proverbial “second bite at the apple.” The plan discourages AI-related federal funding from being directed towards states with burdensome AI regulations, while simultaneously directing the federal government to avoid interfering with states’ rights to pass “prudent laws that are not unduly restrictive to innovation.” The plan calls for the identification, revision, or repeal of regulations, rules, guidance, and the like, that “unnecessarily hinder AI development or deployment” and calls for federal agencies to consider a state’s AI regulatory climate when making funding decisions. It also calls for the Federal Communications Commission to determine whether state AI regulations interfere with its work under the Communications Act of 1934.
Touting a model of “free speech and American values,” the AI Action Plan also calls for the rejection of “social engineering agendas”—by ordering the revision of the National Institute of Standards and Technology (NIST) AI Risk Management Framework to “eliminate references to misinformation, Diversity, Equity, and Inclusion, and climate change.” Large language model (LLM) developers who contract with the government must ensure that systems are “objective and free from top-down ideological bias.”
To that end, the new Executive Order, “Preventing Woke AI in the Federal Government,” mandates that agencies shall only procure LLMs that are both truthful and ideologically neutral. The Office of Management and Budget (OMB), in consultation with others, is directed to issue guidance to agencies regarding “unbiased AI principles” within 90 days.
To spur AI innovation, the AI Action Plan pushes for the investment in: (1) the development and sharing of open-source and open-weight AI models; (2) building world-class, high quality training datasets; (3) investing in scientific breakthroughs related to AI interpretability, control and robustness; and (4) establishing an ecosystem to support scientific progress in evaluating AI system performance and reliability. This will likely be the most immediate boon for AI developers and the investment community focused on AI-driven companies and assets.
Also notably, the AI Action Plan calls for the establishment of “regulatory sandboxes”—known as AI Centers of Excellence—where researchers, startups, and established enterprises can test AI tools freely, something we covered in a previous post.
In the areas of health care, energy, and agriculture, NIST will lead efforts to convene stakeholders from the public and private sectors as well as academia to accelerate the development and adoption of national standards for AI systems and to measure productivity.
Pillar II: Building American Infrastructure
The AI Action Plan advocates for the development of American infrastructure—including factories, data centers, and alternative energy sources—by expediting projects under environmental, transportation, and related legislation that might otherwise impede progress. Among other things, the AI Action Plan directs federal lands to be made available for data center construction; the upgrading of the U.S. electric grid to support data centers; the restoration of American semiconductor manufacturing; high-security data centers for military and intelligence community usage; training the U.S. workforce for AI infrastructure; and measures to bolster critical infrastructure cybersecurity.
The new Executive Order on “Accelerating Federal Permitting of Data Center Infrastructure” revokes Executive Order 14141 of January 14, 2025, “Advancing United States Leadership in Artificial Intelligence Infrastructure.” The administration announced a policy of “bold, large scale industrial plans” for AI data and infrastructure through the necessary transmission lines and equipment; the ease of regulatory burdens that could hinder this expansion; and the use of federally owned land and resources for the development of data centers. The Secretary of Commerce is directed to launch an initiative to provide financial support for qualifying projects, which could include loans, grants, tax incentives, and offtake agreements, while other respective agencies are directed to take actions to expedite environmental reviews and authorize federal lands for the purpose.
Pillar III. Leading in International AI Diplomacy and Security
The AI Action Plan promotes exporting American AI to meet global demand and criticizes China's role in setting international standards. It seeks to deny foreign adversaries access to “AI Compute” (resources needed to train AI models) by imposing export controls and assessing the national security risks in American frontier models.
Meanwhile, the new Executive Order, “Promoting the Export of the American AI Technology Stack,” calls for the establishment of an American AI Exports Program to support the development and deployment of U.S. full-stack AI export packages, within 90 days. The Secretary of Commerce is directed to issue a public call for proposals from industry-led consortia, with requirements as outlined in the order, also to be submitted within 90 days. The Executive Order also directs actions to mobilize federal financing tools.
Key Takeaways
Consistent with the policy expressed in EO 14179, and the revocation of former President Biden’s Executive Order 14110 entitled “Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence” (revoked by EO 14148), the AI Action Plan outlines a new approach to AI policy focused on reducing regulatory barriers, promoting innovation, and accelerating private-sector adoption of AI tools.
With regard to federal funding to states, particularly in light of the AI Action Plan’s goal of building data centers and semiconductor facilities, it remains unclear whether current state AI-related consumer protection, disclosure, and privacy laws will be deemed “prudent” or “burdensome”—and whether the determination will turn on the law’s text, or on how aggressively a state elects to enforce its law.
The White House is also clearly intent on outpacing other countries in the AI race so that the U.S. benefits from any gains provided by AI.
The impacts on the American workforce, however, remain to be seen. Under the first pillar, the AI Action Plan includes six recommended policy actions centered around the empowerment of American workers in the age of AI. These recommendations include promoting the integration of AI skill development into training programs, funding the retraining of individuals impacted by AI-related job displacement, and studying the impacts of AI on the American workforce. The AI Action Plan also aims to enable AI adoption throughout many industries, which will allow more workers to utilize AI in their day-to-day activities. Relatedly, under the second pillar, the AI Action Plan seeks to train a skilled workforce that will be tasked with developing the national AI infrastructure.
The AI Action Plan, however, noticeably steps back from the Biden administration’s attempts to identify and mitigate potential risks and pitfalls of the incorporation of AI into the workplace. With the failure of the OBBBA to institute a moratorium on state and local legislation of AI, whether the private sector must continue to engage in the exercise of identifying and mitigating such risks will now largely depend on what happens at the state and local level.
The AI Action Plan marks a decisive pivot toward deregulation as the key driver for rapid innovation in pursuit of global AI leadership, centered on national infrastructure investment, diplomatic assertiveness, and a vision of AI systems aligned with “American values.” Yet, its long-term impact hinges on uncertain state-federal dynamics and the practical outcomes of policies that prioritize speed over safeguards.
We will continue to keep you posted.
Epstein Becker Green Staff Attorney Ann W. Parks contributed to the preparation of this post.
