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Empowering US federal AI initiatives: How Elastic helps agencies comply with M-25-21 and M-25-22

Skip to main contentA practical guide for chief AI officers and technology leaders implementing federal AI governanceThe US Office of Management and Budget's recent memoranda — M-25-21, "Accelerating Federal Use of AI through Innovation, Governance, and Public Trust," and M-25-22, "Driving Efficient Acquisition of Artificial Intelligence in Government" — establish comprehensive frameworks for federal agencies that implement AI systems while maintaining appropriate safeguards.For chief AI officers (CAIOs) and technology leaders across federal agencies, these directives create both strategic opportunities and implementation challenges. This analysis explores how Elastic's Search AI Platform addresses key M-25-21 and M-25-22 requirements with actionable solutions.Maximizing data value while protecting privacy and rightsElastic's data mesh architecture directly addresses M-25-21's mandate to redefine "AI governance as an enabler of effective and safe innovation" by providing a unified yet distributed layer that standardizes data operations. This approach enables agencies to establish the "clear expectations for their workforce on appropriate AI use" required by the memorandum, particularly when supporting consequential decision-making. By implementing Elastic as a unified data mesh, agencies can maintain centralized governance controls while delegating "responsibilities and accountability for risk acceptance to appropriate officials throughout the agency" as specified in M-25-21, “ensuring that swift action is possible with sufficient guardrails in place.”Elastic delivers these capabilities through:Vector search: Elastic's vector search capabilities go beyond semantic search to transform unstructured data into meaningful embeddings that capture context and meaning. This enables similarity-based search that fulfills M-25-21's mandate to "develop adequate infrastructure and capacity to sufficiently share, curate, and govern agency data for use in training, testing, and operating AI" by making agency-specific information discoverable and usable by AI systems, regardless of exact keyword matches. Vector search allows agencies to index and query diverse data types, including internal documentation, runbooks, GitHub issues, and even non-textual data like images and diagrams — creating a rich context base for AI systems while still maintaining strict security parameters.Cross-cluster search (CCS): Elastic's CCS capability allows seamless querying across multiple Elasticsearch clusters regardless of physical location — on-premises, cloud, hybrid, or multi-cloud environments. Supporting M-25-21's mandate for cross-organizational data access with appropriate security controls, CCS allows agencies to connect and search remote clusters globally. This unified approach enforces consistent governance policies without duplicating data or creating bottlenecks.Secure data exchange: Elastic's role-based access controls and document-level security ensure that data sharing complies with M-25-21's requirement for agencies to "reuse resources that enable AI adoption, such as agency data, models, code, and assessments of AI performance" while simultaneously implementing appropriate safeguards. The security architecture allows agencies to define and enforce organization-specific data governance policies, ensuring that data sharing complies with M-25-22's guidance to "take steps to ensure that their contracts retain sufficient rights to Federal Government data and retain any improvements to that data" without compromising on M-25-21’s requirement for AI functionality to have an "appropriate fail-safe that minimizes the risk of significant harm."Privacy-centered architecture: Elastic's transparent approach to data security supports M-25-21's requirement to "consider and mitigate, as appropriate, risks to privacy, civil liberties, and civil rights" throughout the AI lifecycle. By providing comprehensive audit trails and monitoring capabilities, Elastic helps agencies implement the accountability frameworks necessary for responsible AI governance while still enabling innovation.By combining powerful vector search with cross-cluster capabilities and robust security controls, Elastic enables agencies to maximize the value of their data assets while maintaining strict privacy protections. This balanced approach allows federal organizations to build comprehensive (and easily discoverable!) knowledge repositories that enhance AI effectiveness while ensuring compliance with M-25-22's requirements for data protection, appropriate use limitations, and safeguards for civil rights and liberties.Enabling open and transparent AI governanceM-25-21 explicitly states that “agencies must identify a Chief AI Officer (CAIO) to champion their agency's AI goals by advising on how to make these improvements.” Furthermore, it requires CAIOs to “establish a process for determining and documenting AI use cases as high-impact” and maintain centralized tracking of these use cases.Elastic equips CAIOs with the means to support this governance framework through:Unified AI visibility: Elastic Observability, built on the Search AI Platform, provides comprehensive visibility across agency AI systems, enabling CAIOs to maintain the required inventory of AI use cases and their risk classifications. This includes robust LLM observability tools that provide transparency into LLM prompts and responses. It enables your team to protect against data leaks of sensitive information, harmful or undesirable content, and ethical issues, while also addressing factual errors, biases, and hallucinations.Robust model documentation: Both memoranda emphasize transparency requirements, with M-25-21 explicitly requiring agencies to "prioritize obtaining documentation that facilitates transparency and explainability." Elastic's document store and search capabilities enable agencies to meet this requirement by efficiently indexing, retrieving, and managing AI model documentation. This solution helps CAIOs fulfill their M-25-21 obligation to "establish a process for determining and documenting AI use cases as high-impact" by maintaining searchable, comprehensive records of model development decisions, training datasets, and risk assessments that demonstrate compliance with federal AI governance requirements.Vendor-neutral architecture: Aligning with M-25-22's focus on preventing vendor lock-in, Elastic's AI Assistant and generative AI capabilities support multiple LLM providers through connectors for locally hosted LLMs, OpenAI, Amazon Bedrock, Google Gemini, and others. This flexible and open ecosystem allows procurement teams to:Evaluate and compare capabilities across providers using common metricsDefine performance and interoperability standards in their vendor solicitationsAdapt their vendor requirements as the market evolves, ensuring that contractual terms remain competitive and aligned with technological advancesIn short, by maintaining a vendor-neutral posture, Elastic ensures agencies are positioned to articulate precise performance needs, avoid undue dependencies, and ultimately fulfill M-25-22's requirement to "communicate clear and specific requirements that make it easy for vendors to offer state-of-the-art AI capabilities."Standards-based compliance: Elastic also directly addresses M-25-22's focus on preventing vendor lock-in through its adherence to open standards and interoperability. The platform's extensive API integrations enable seamless connections with existing government systems while providing flexibility for future technology adoption. Elastic's contribution of the Elastic Common Schema (ECS) to OpenTelemetry demonstrates our commitment to standardized data formats that facilitate interoperability across the AI ecosystem. With native support for OpenTelemetry and cross-cluster search capabilities, Elastic enables agencies to implement the "adequate fail-safes" and "continuous monitoring" required by M-25-21 for high-impact AI systems. By offering a central platform for unified AI visibility, a commitment to open standards and interoperability, and a vendor-neutral architecture, Elastic empowers federal agencies to leverage AI's benefits efficiently and securely. The platform's maturity and extensive public sector experience position Elastic as a strategic partner for federal AI transformation initiatives mandated by M-25-21 and M-25-22.Implementing high-impact AI risk managementM-25-21 mandates that "within 365 days of the issuance of this memorandum, agencies must document implementation of the minimum practices for high-impact uses of AI." These practices include predeployment testing, impact assessments, ongoing monitoring, and human oversight.Elastic directly supports these requirements through:Comprehensive monitoring: Elastic Observability provides continuous monitoring of AI systems, enabling agencies “to detect unforeseen circumstances, changes to an AI system after deployment, or changes to the context of use or associated data” as required by M-25-21.Advanced alerting framework: Elastic's alerting capabilities enable agencies to “ensure human oversight, intervention, and accountability suitable for high-impact use cases” by automatically detecting anomalies and triggering appropriate human interventions.Performance analytics: Elastic visualizations enable agencies to track key performance metrics for AI systems, supporting the M-25-21 requirement to "establish processes to measure, monitor, and evaluate the ongoing performance and effectiveness of the agency's high-impact AI applications." This includes a wide range of prebuilt dashboards for visualizing observability data from a variety of sources, including ones that are loaded automatically as part of Elastic integrations.Through continuous monitoring, intelligent alerting, and comprehensive performance analytics, Elastic provides federal agencies with the tools necessary to implement the appropriate risk management practices required for high-impact AI. This integrated approach enables agencies to detect potential issues before they impact operations, implement appropriate human oversight mechanisms, and maintain detailed performance records that demonstrate compliance with M-25-21's risk management requirements.FedRAMP authorized and enterprise-readyAs agencies work to meet implementation deadlines in both memoranda, Elastic offers FedRAMP authorized SaaS, on-premises, air-gapped, and hybrid solutions deployable in any government environment. The platform's maturity and extensive public sector experience position Elastic as a strategic partner for federal AI transformation initiatives.Strategic next steps for federal AI leadershipFor agencies implementing M-25-21 and M-25-22 requirements:Begin with a free FedRAMP trial: Experience Elastic in a compliant GovCloud environment with our no-cost FedRAMP trial. Explore our platform's capabilities firsthand.Schedule an AI governance assessment: Meet with our public sector specialists to map your agency's AI use cases against M-25-21 requirements and develop a compliance roadmap.Request a high-impact AI monitoring demo: See Elastic Observability configured for AI systems, including LLM monitoring, performance tracking, and anomaly detection.Implement a proof-of-concept: Test Elastic AI Assistant with your agency's knowledge base in a controlled 30-day evaluation to experience context-specific AI assistance with appropriate security controls.By implementing Elastic's unified platform, federal agencies can accelerate compliance with M-25-21 and M-25-22 while delivering on their core objectives: leveraging AI to enhance citizen services while maintaining strong safeguards for privacy and civil rights.The release and timing of any features or functionality described in this post remain at Elastic's sole discretion. Any features or functionality not currently available may not be delivered on time or at all.In this blog post, we may have used or referred to third party generative AI tools, which are owned and operated by their respective owners. Elastic does not have any control over the third party tools and we have no responsibility or liability for their content, operation or use, nor for any loss or damage that may arise from your use of such tools. Please exercise caution when using AI tools with personal, sensitive or confidential information. Any data you submit may be used for AI training or other purposes. There is no guarantee that information you provide will be kept secure or confidential. You should familiarize yourself with the privacy practices and terms of use of any generative AI tools prior to use.Elastic, Elasticsearch, and associated marks are trademarks, logos or registered trademarks of Elasticsearch N.V. in the United States and other countries. All other company and product names are trademarks, logos or registered trademarks of their respective owners.



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