Government Procurement Standards for Foundation Models

Abstract

Background: The practical operation of policy relating to foundation models differs across settings, suggesting a need to examine implementation capacity and institutional design directly.

Objective: This study sought to explain differences in the implementation of foundation models by examining institutional responsibility, administrative capacity, and procurement standards.

Methods: The documentary sample comprised 900 statutes, regulations, policies, contracts, guidance documents, administrative records, or public disclosures. Two-stage coding evaluated clarity, transparency, procedural safeguards, oversight, and implementation requirements; disagreements were independently reconciled.

Results: Formal rules on foundation models were identifiable in 73% of the reviewed materials. Operational detail was much less common, with only 53% containing sufficiently developed implementation or oversight provisions; 21% lacked complete transparency or review mechanisms. Greater comprehensiveness coincided with clearer institutional ownership and fewer implementation gaps.

Conclusion: The findings underline a practical gap between formal policy on foundation models and the institutional work required to deliver it consistently. This means that procurement reform should prioritize traceable processes, coordinated oversight, and implementation capacity.

Study design: tender-document analysis.

Publication history: Originally published in print on 15 June 2026, Volume 6, Article 5. Online abstract record added on 16 September 2026. Full-text PDF will be added when the digital galley is ready.