The Trump administration’s long-anticipated “AI Action Plan” is expected to be publicly released next week. In response to a Request for Information issued by the White House’s Office of Science and Technology Policy, stakeholders submitted over 10,000 public comments laying out their views on what should—and should not—be included. That volume of feedback underscores the level of public interest in the administration’s approach to AI and the far-reaching consequences of U.S. government policy on this front.
These six overarching questions will be critical to understanding the significance of the plan, and accompanying materials such as one or more expected executive orders, once those are released:
1. What is the scope of the AI Action Plan?
There are many dimensions to AI strategy and policy, from U.S. government procurement and use of AI to supply chain resilience, export controls, and domestic and global norms about AI practices. The AI Action Plan is therefore likely to be broad in scope, providing insight into where the administration is heading on AI. That said, the Action Plan’s precise scope remains uncertain; and, the more that the Action Plan ends up covering, the harder it may prove to offer a single strategic vision that resolves tensions among aspects of multidimensional AI policy, such as fostering continued U.S. private sector leadership while keeping the most sensitive U.S.-produced technologies from reaching the hands of foreign adversaries and rivals.
2. What does the plan say about AI infrastructure and power?
AI’s rapid development requires significant investments in land and energy resources, among other inputs. The AI Action Plan will likely cover the ways to increase the availability of these raw inputs to the U.S. private sector, both domestically and abroad. So far, the Trump administration has, for example, continued to drive implementation of an initiative kicked off by the Biden administration making available federal land for the types of data centers essential to AI model training and operation. The Action Plan can build on that effort by outlining a strategic vision for making sustainable investments in the raw requirements for AI infrastructure.
3. What does the plan say about the human costs of AI development?
AI’s emergence brings enormous opportunities for innovation, efficiency, and more, yet even its most enthusiastic proponents acknowledge that there are also costs. Those include costs for the people whose jobs will be eliminated or at least dramatically overhauled by increasingly sophisticated AI models and greater reliance on those models in workplaces across a range of sectors. It will therefore be key to understand how the Action Plan imagines preparing the American workforce to evolve with major AI breakthroughs and prepare for potentially significant upheavals.
4. Where does the plan land on export controls?
So far, there has been a lively debate between those who want to keep the most cutting-edge AI technology developed by the U.S. private sector out of the hands of the country’s global rivals and those who want to see that private sector’s reach extend as far and wide as possible—in part to try to crowd U.S. rivals out of the market. The Trump administration’s previous revocation of the “AI Diffusion Rule,” paired with big AI deals announced with Saudi Arabia and the United Arab Emirates during the president’s May trip to the Middle East, marked notable wins for the latter camp. So, too, did the recent news that the Commerce Department will reverse course and now permit certain high-end chips to be sold to Chinese purchasers. The Action Plan is the next key data point in understanding which side of this debate is prevailing within the administration.
5. Where does the United States fit in globally on AI?
The U.S. private sector may be at the forefront of AI development, but AI maturation is a global phenomenon. And other countries have increasingly strong views of their own on AI strategy and policy, as demonstrated by the European Union’s complex AI Act and recently-announced code of practice. The Action Plan is a chance for the administration to explain how its approach fits in globally and might be pursued through international forums such as the G7—or not.
6. Will the plan take a position on hot-button legal and legislative issues?
The expectation is that the Action Plan will cover a range of AI-related strategy and policy topics. But it is worth looking to see if it expresses a view on behalf of the administration on certain hot-button legislative and even legal issues. With respect to the former, the recent push in Congress to create a ten-year (then five-year) AI state law moratorium via federal preemption gained traction remarkably quickly, almost becoming federal law. Already, efforts are underway to revive the proposal for a future legislative vehicle that might see it pass. The Action Plan offers the administration a chance to weigh in on similar legislation going forward.
When it comes to legal issues, in recent weeks federal district courts have issued three landmark decisions grappling with whether training AI models on copyrighted materials is protected as fair use under intellectual property laws. In short, two judges said yes and one said no. But there was a lot more nuance to what each judge said; and, regardless, the issues are almost certain to be considered by appellate courts in coming months, making the recent rulings important but far from the final word on these critical intellectual property issues. While these have largely been legal fights among private parties, the Trump administration fired the country’s top copyright official days after her office released a report suggesting that AI model training might not be protected as fair use. If the administration wants to air its legal views on this issue and others such as whether AI chatbots’ output qualifies as First Amendment-protected speech, the Action Plan could offer an opportunity to do so.
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There is no set formula for writing, coordinating, and releasing national strategies or action plans. What makes it in—and what does not—can be just as consequential, and just as revealing, as the content itself. Just as importantly, how something is said can signal as much about the path ahead as what is said. Given the stakes for AI development, deployment, and use, the forthcoming AI Action Plan warrants close scrutiny along all these dimensions. Where the U.S. government takes AI strategy and policy will have far-reaching consequences—for Americans’ jobs, their lives, and their place in the world.
