How government buys AI products and services

Federal civilian buying paths

Five paths cover most federal AI buys. Each has its own rules for the vendor, so check them before the order, not after it.

• Micro-purchase: up to $15,000 under FAR 2.101, with no competition required and usually paid on a purchase card. Services under the Service Contract Labor Standards cap at $2,500, and one need may not be split to fit (FAR 13.003).
• Simplified acquisition: up to $350,000 with simplified procedures, and generally reserved for small businesses when two or more can compete (FAR 13.003). The vendor needs an active SAM.gov registration.
• GSA schedule order: an order on a Multiple Award Schedule contract under FAR subpart 8.4. The vendor must hold the schedule contract, and the schedule’s own ordering rules apply.
• Task order on a GWAC or IDIQ: an order under a contract the agency already uses, with fair opportunity among its holders (FAR 16.505). Only firms on the vehicle can be the prime.
• Blanket purchase agreement: a standing set of prices an office agrees with one or more vendors, often on a schedule, so repeat orders do not need a new competition each time. Each call is an order against it.
• Subcontract to a prime: the prime buys from you under its own contract and flows its clauses down to you. The agency has no contract with you directly.

The FAR is being rewritten part by part, so section numbers can move. acquisition.gov always carries the current text.

The federal rules written for AI

OMB memo M-25-22, issued April 3, 2025, sets how federal agencies acquire AI systems and services. It does not cover AI bought as a component of a national security system.

Its main asks of an agency buying AI:

• Market research and requirements written with the people who will use and oversee the system.
• Contract terms that track the system’s performance and manage its risks for the life of the contract.
• Protections against vendor lock-in, so data and models can move to another vendor.
• Clear rights to government data, and no training of public or commercial models on nonpublic agency data without consent.

Each agency also updates its own acquisition procedures to match the memo, so ask the contracting office which version applies to your buy.

GSA also runs OneGov agreements, which let agencies buy products from some large AI vendors at set government prices. Ask the contracting office which agreements are open.

Defense and research paths

Work that is still being proven often starts outside a standard FAR contract.

• Other transactions: prototype agreements outside the FAR. Defense uses 10 U.S.C. 4022, and NASA, DHS, DOE and others hold their own authorities.
• Commercial solutions openings: a defense path for innovative commercial products and services, competed by general solicitation under 10 U.S.C. 3458.
• SBIR and STTR: research and development awards for small businesses. Congress reauthorized both in April 2026 through September 30, 2031, after a lapse that began October 1, 2025; open topics are on SBIR.gov.

A prototype that succeeds can move to production through a follow-on agreement or a FAR contract, so plan the second step before the first one ends.

State, county, city and public safety

Each state and city sets its own purchasing thresholds and rules. Start with the buyer’s procurement code, not the FAR.

• Cooperative contracts: one lead state or agency competes a master agreement and others order from it. NASPO ValuePoint needs a participating addendum in each state, and Sourcewell serves local government and schools.
• Cloud security: some states require a GovRAMP authorization (formerly StateRAMP), or Texas’s TX-RAMP, before they buy a cloud service.
• Police and public safety: anyone with access to criminal justice information needs the fingerprint-based background check the CJIS Security Policy requires, and a vendor signs the CJIS Security Addendum.

Local buys under a city or county threshold can often go to a quote from one vendor. Above it, expect a formal solicitation or an order from a cooperative contract.

Ask the buyer which cooperative contracts it already orders from. Joining one it already uses is often faster than a new solicitation.

Where Ayla fits today

Ayla is a government hiring data and recruiting company. Its SAM.gov registration is in progress, it holds no contract vehicle, and it works as a subcontractor to registered primes.

A federal office can buy Ayla data seats on a purchase card under the micro-purchase threshold. Government AI covers the data and the AI talent, the AI contracts list shows open notices with incumbent hiring, and the primes page covers subcontracting.