The No Adversarial AI Act would require the Federal Acquisition Security Council to create and maintain a public list of artificial intelligence products and services that are produced or developed by a foreign adversary. The list must be published within 180 days of enactment and updated at least every 180 days. A vendor may seek removal from the list by certifying that the AI is not foreign-adversary-produced and providing supporting information for review and certification by the Council.
The bill would also direct executive agencies to review, and generally exclude or remove, AI from covered foreign adversary entities from federal acquisition and use, unless an exception is approved. Agencies would be required to use existing procurement-risk authorities to mitigate the use of such AI. Exceptions could be granted for scientifically valid research, evaluation/training/testing/analysis, counterterrorism or counterintelligence activities, or when necessary to avoid jeopardizing mission-critical functions. The bill defines key terms such as artificial intelligence, executive agency, foreign adversary, and foreign adversary entity by reference to existing federal law.
Impact
If enacted, the bill would add a new federal procurement and cybersecurity screening regime focused specifically on AI tied to foreign adversaries. It would affect federal acquisition practices by requiring agencies to identify, review, and potentially bar certain AI products and services from government use, while creating a public-facing list and a formal process for delisting. The measure would primarily affect federal agencies, contractors, and AI vendors with ownership, control, or organizational ties to designated foreign adversaries, and it would interact with existing procurement and national security authorities under title 41 and related statutes.
Sentiment
The available legislative history shows an early-stage bill with no recorded votes or committee debate in the provided materials. The bill’s introduction and referral to the Senate Committee on Homeland Security and Governmental Affairs suggest a national security framing, and the text itself reflects a strong precautionary approach toward foreign-linked AI. Based on the bill’s structure, the general sentiment appears to favor restricting perceived security risks while preserving limited exceptions for research and mission needs.
Contention
The main point of contention is likely to be how broadly the bill defines and identifies a “foreign adversary entity” and whether the resulting exclusions could sweep in legitimate commercial AI products or create burdens for agencies and vendors. Another likely issue is the balance between security and operational flexibility, since the bill allows exceptions for research, testing, counterterrorism, and mission-critical functions but still requires agency-level determinations and congressional notice. Critics may also question the feasibility of maintaining an accurate public list and the potential for diplomatic, trade, or supply-chain consequences, while supporters are likely to emphasize supply-chain security and protection against foreign influence.