GSA Issues First Federal AI Acquisition Clause; Contractors Warn of Chilling Effect on Government AI Adoption

GSA regulation 52.239-7001 establishes the federal government's first acquisition clause specifically addressing artificial intelligence systems. The nine-page clause applies to all AI use in contract performance, not just AI deliverables. Key provisions: government owns all output data, metadata, logs, and custom developments; contractors must disclose all AI systems used regardless of relevance; AI systems cannot refuse outputs based on provider policies. Industry raises three primary objections: government-unique requirements deviate from commercial terms, cascading liability forces prime contractors to monitor all subcontractor AI use, and the 60-day acceptance window with no phase-in creates conflicts with existing vendor agreements. GSA deferred implementation to Refresh 32 following industry feedback.