S 5345
A bill to provide for the delivery of artificial intelligence functional bills of materials, and for other purposes.
TL;DR
Senator Elissa Slotkin (D-MI) introduced this bill requiring AI vendors selling to the federal government (likely defense-focused given the Armed Services referral) to deliver an 'AI functional bill of materials' documenting what's inside their AI systems. Think of it as a nutrition label for AI: what data, models, and components went into building it. It's currently sitting in the Senate Armed Services Committee.
How This Might Impact Your Business
Defense contractors and federal AI vendors would need to document and disclose the components, training data sources, and dependencies of AI systems sold to the government
Companies selling AI to the Department of Defense should expect new procurement requirements similar to software bills of materials (SBOMs) already required under Executive Order 14028
AI model providers, including foundation model companies licensing tech to federal contractors, may face downstream disclosure obligations from their government-facing customers
Smaller AI startups pursuing federal contracts should prepare for documentation costs that larger primes like Palantir, Anduril, and Lockheed already handle
No specific penalties or deadlines are spelled out in the bill's current form; details will emerge in committee markup
Commercial-only AI vendors (no federal sales) are not directly affected, though standards set here often become industry norms
The Armed Services Committee referral signals this is aimed at national security AI use, not consumer or enterprise AI broadly
What Should You Do
If you sell AI or AI-enabled products to any federal agency, task your compliance team with building an inventory of model components, training data provenance, and third-party AI dependencies now
Ask your legal and government affairs teams to track Senate Armed Services Committee activity on S 5345 and flag any committee hearings or markup sessions
Review your existing software bill of materials (SBOM) processes and identify gaps for AI-specific disclosures (model weights, fine-tuning data, evaluation results)
If you license AI models from vendors like OpenAI, Anthropic, or open-source providers, review contracts for your ability to obtain component disclosures from them
Brief your sales team pursuing federal opportunities that documentation requirements are tightening and to price bids accordingly
Who It Affects
Sponsors
Status Timeline
committee
Read twice and referred to the Committee on Armed Services.
August 6, 2026