Map the product’s actual use, data and geography before assigning obligations. A small fine-tuning project can still process regulated information or support a consequential decision; conversely, ordinary document formatting is not automatically covered by every AI-specific rule.
This is a dated procurement briefing, not a legal determination or exhaustive 50-state survey. Ask qualified counsel to confirm scope, exemptions, litigation and any developments after 26 October 2026. Keep enacted law, final regulation, proposals and voluntary guidance separate in your compliance register.