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On June 2, 2026, President Donald Trump issued a new Executive Order (the “EO”), Promoting Advanced Artificial Intelligence Innovation and Security, directing agencies to strengthen federal cybersecurity, expand use of AI-enabled defensive tools and vulnerability coordination, establish a voluntary coordination framework for secure frontier-model deployment, and prioritize enforcement against AI-enabled cybercrime. These directives are framed within the Administration’s broader policy of supporting innovation and collaborating with the private sector to modernize government and private-sector information systems, protect American intellectual property from adversarial exploitation and theft, and cultivate advanced AI-enabled capabilities.

The new directive builds on the Administration’s July 2025 AI Action Plan, which outlined more than 90 policy recommendations to promote American AI dominance. The EO extends the federal government’s AI security focus to the benchmarking, deployment, and defensive use of the most capable AI models, operationalizing key elements of the AI Action Plan’s emphasis on bolstering cybersecurity, securing the full AI technology stack, and deploying AI-enabled tools to defend critical infrastructure.

Companies that develop frontier AI models, provide cybersecurity services, or operate critical infrastructure will benefit from familiarizing themselves with the EO and considering its implications for government engagement, model deployment, and cybersecurity risk management.

Key Themes

Voluntary, Collaborative Engagement: The EO’s central mechanisms for engaging with the AI industry, including the AI cybersecurity clearinghouse and the frontier model deployment framework, are structured as voluntary collaborations that draw on industry expertise, rather than compulsory programs.

AI-Enabled Cyber Defense: The EO prioritizes the rapid deployment of AI-enabled defensive tools across the federal government, directing the expansion of federal programs and cybersecurity services and facilitating access to cybersecurity tools for federal agencies, state and local authorities, and critical infrastructure operators.

New “Covered Frontier Model” Designation: The EO establishes a classified benchmarking process to assess the advanced cyber capabilities of AI models and to determine the threshold at which a model becomes a “covered frontier model,” a designation used for purposes of the EO’s voluntary secure deployment framework.

Criminal Enforcement: The EO directs prioritized enforcement of existing federal criminal statutes against those who use AI to access or damage computer systems without authorization or to further other crimes.

Summary of Operative Sections

Below we summarize the operative provisions of the EO and their associated deadlines:

Sec. 2. Upgrading American Systems for Advanced AI: The EO mandates a rapid, government-wide hardening of federal information systems and expansion of AI-enabled cybersecurity services, with most actions due within 30 days.

  • The Committee on National Security Systems must prioritize the cyber defense of National Security Systems, and the Secretary of War must prioritize the cyber defense of Department of War information systems.
  • The Secretary of Homeland Security, through the Director of the Cybersecurity & Infrastructure Security Agency (“CISA”), must issue Binding Operational Directives and guidance to expedite federal cyber defense, establish or expand federal programs that enhance AI-enabled defensive tools, and facilitate access to cybersecurity tools and services for agencies, state and local authorities, and critical infrastructure operators.
  • The Treasury Secretary must form an “AI cybersecurity clearinghouse” with the AI industry and critical infrastructure operators to coordinate vulnerability scanning, validation, and remediation.
  • The Director of the Office of Management and Budget (“OMB”) must determine whether federal grant funding can support advanced AI vulnerability detection.
  • The Director of the Office of Personnel Management (“OPM”) must expand the United States Tech Force Information Cybersecurity Specialist hiring and placement pathways.

Sec. 3. Secure Frontier Model Deployment: The EO creates a new classified benchmarking process and voluntary engagement framework for frontier AI models, due within 60 days. The EO expressly provides that this section does not authorize the creation of mandatory licensing, preclearance, or permitting for new AI models, including frontier models.

  • The Secretaries of Treasury, War, and Homeland Security must develop a classified benchmarking process to assess AI models’ cyber capabilities and determine “covered frontier model” designations. Such a designation would ultimately be made by the Director of the National Security Agency (“NSA”), in consultation with other national security officials.
  • The Secretaries of Treasury, War, and Homeland Security must also design a voluntary framework through which developers would be able to determine whether models meet the “covered frontier model” designation and, if so, provide the federal government early access for up to 30 days before broader release. Such access would be subject to appropriate confidentiality, cybersecurity, insider-risk, and intellectual property protection, use, and nondisclosure requirements.

Sec. 4. Protection Against Criminal Actors: The EO directs the Attorney General to prioritize enforcement of existing federal criminal statutes against AI-enabled cybercrime.

  • The Attorney General must prioritize the enforcement of 18 U.S.C. §§ 1028, 1030, and 1343, as well as all other applicable federal criminal laws, against anyone who uses AI to illegally access or damage a computer without authorization, or who uses AI while engaged in such illegal access to further any other crime. This includes breaching any public or private information technology system, or employing AI agents to unlawfully access data subsequently used for a criminal or unlawful purpose.

Looking Ahead

Implementation of the EO will follow over the coming weeks and months. AI developers, cybersecurity leaders, and critical infrastructure operators in particular will likely benefit from watching for directives and guidance from CISA and the stand-up of the Treasury-led AI cybersecurity clearinghouse, both due within 30 days. The creation of the classified benchmarking process and the criteria for the “covered frontier model” designation, as well as the design of the voluntary early-access framework, will also be of particular interest for frontier model developers.

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