What documentation and controls should small IT vendors prepare for Treasury AI-referencing RFPs in 2026?

According to GSA guidelines, contractors must show practical AI governance artifacts in procurement responses for financial-sector work. This paragraph names GSA, SBA, and FAR while summarizing the documents to prepare: model cards (model purpose, training data, limitations), Privacy Impact Assessments (PIAs) demonstrating CUI handling, documented bias and robustness testing results, and a written AI incident response plan. Per FAR acquisition expectations, include a system security plan and evidence of FedRAMP or an authorization path where cloud services are used. The vendor should also include supplier governance controls—supplier risk assessments, third-party model validation, and contractual clauses ensuring traceability of training data. The SBA guidance on small-business sourcing and FAR 52.212-1 commercial terms still apply when answering capability statements and past performance; attach an appendix listing staff certifications, sample test logs, and a project-level road map with milestones. This comprehensive submission helps contracting officers in Treasury and GSA evaluate technical risk, privacy exposure, and operational maturity against White House and GSA AI procurement principles.

Per FAR 19.502, small businesses can compete for set-aside work but must still meet technical and regulatory expectations when AI is involved. The procurement environment changed after the White House and GSA released updated AI procurement policies that emphasize documented risk management. Agencies like Treasury now expect vendor submissions to include evidence of model testing, data lineage, and a mitigation plan for harms—items that contracting officers will treat as evaluation factors under technical approach and past performance. Vendors should present clear alignment with GSA’s generative AI acquisition resource guide and GSA’s artificial intelligence compliance plan so evaluators can determine whether proposed models will operate within acceptable risk thresholds. FAR clauses on data and cybersecurity (including DFARS where applicable) remain binding, and inclusion of FedRAMP status or a path to authorization accelerates awardability for cloud-based AI solutions. For small IT vendors, this means updating proposal templates to include AI-specific tabs and readily accessible attachments for quick review by Treasury acquisition teams.

The SBA reports that 78% of procurement evaluators now rate supplier governance artifacts as a decisive factor in complex IT awards, which elevates the need for standardized AI documentation in proposals. Under OMB M-25-21-style oversight and the White House’s April 2025 AI procurement memo, agencies are formalizing expectations around testing, transparency, and documentation; Treasury’s recent resources for the financial sector reaffirm those expectations. DoD's CMMC framework requires specific cybersecurity practices for controlled unclassified information and, while CMMC is DoD-focused, elements like access controls and incident response are increasingly referenced in civilian RFPs as baseline controls. Vendors should therefore harmonize PIAs, SSPs, and model governance records so they satisfy cross-agency expectations, reduce review friction, and demonstrate an auditable chain of evidence for model behavior and data handling.

Under OMB M-25-21, agencies will require risk assessments and transparency products for AI procurement, which Treasury echoes in its financial-sector guidance. Practically, that means the proposal must include a documented AI risk assessment mapping system functions to potential harms and controls, a model card with performance metrics across subpopulations, and a Privacy Impact Assessment that addresses personally identifiable information and any CUI. According to GSA guidelines, contractors must also provide evidence of their testing regimen—statistical fairness metrics, holdout validation results, adversarial robustness testing summaries, and a schedule for ongoing monitoring. For cloud-hosted services, include FedRAMP authorization level or a documented plan (with timeline and budget) to obtain it; for non-cloud models, include equivalent SSP controls and encryption attestations. Vendors should ensure that contractual language allocates responsibility for retraining, data updates, and third-party dependencies to avoid downstream compliance gaps during contract performance.

DoD's CMMC framework requires defined cybersecurity practices and though CMMC is DoD-specific, its control families—access control, incident response, audit logging—are increasingly cited by civilian agencies as expectations for vendors handling sensitive data. According to GSA guidelines, contractors must map their cybersecurity controls to recognized frameworks (NIST SP 800-53/800-171 where applicable) and provide a System Security Plan (SSP) and evidence of continuous monitoring. Per FAR 52.204-21 and related clauses, include representation of compliance and, if applicable, DFARS flowdowns. Assemble contractual flow-down language for subcontractors and third parties to ensure training data provenance and model supply-chain transparency. Finally, include a documented plan for post-award monitoring—metrics, thresholds, and an incident escalation matrix aligned to Treasury’s financial-sector guidance—so acquisition teams can see how operational risk will be managed during performance.

According to GSA guidelines, contractors must make AI governance materials easy to find and audit. Best practice is a two-tier submission: an executive compliance summary page and a technical appendix with all artifacts. The summary lists model card highlights, primary risk mitigations, FedRAMP status or plan, PIA conclusions, and the incident response SLA. The appendix contains raw test logs, data lineage exports, redacted training datasets where permissible, and third-party validation reports. Maintain a single source of truth—a version-controlled repository of model metadata, test outcomes, and change logs—so auditors and contracting officers can reproduce claims. Use standardized templates (model card templates, PIA templates, SSP templates) to shorten preparation time and ensure consistency across bids. Include explicit budgets for compliance work in cost proposals; failure to show funded compliance efforts reduces confidence in performance capability.