SEC AI Compliance Plan 2025

Overview

The OMB Memorandum M-25-21 Compliance Plan is the U.S. Securities and Exchange Commission's 2025 agency policy for addressing consistency with Office of Management and Budget guidance. The SEC presents it as the 2025 AI Compliance Plan among its public technology-governance resources. Its subject is the responsible use of artificial intelligence within SEC operations. The institutional setting connects technology adoption with the agency's mission of protecting investors, maintaining fair, orderly, and efficient markets, and facilitating capital formation.

The plan belongs to the SEC's internal administrative framework. It is distinct from an Act of Congress, a proposed bill, or an AI-specific securities regulation directed at investment advisers, broker-dealers, issuers, exchanges, or technology suppliers. Its publication gives the public access to an agency compliance policy, while the accompanying SEC resource webpage describes leadership responsibilities, coordination arrangements, and use-case inventories. These elements place the policy within agency management and responsible operational adoption rather than a new private-sector enforcement regime.

Definitions and Terminology

The SEC describes a use case as a specific scenario in which technology is designed, developed, procured, or used to advance an agency mission, deliver programs and services, enhance decision-making, or provide a public benefit. This definition encompasses more than deployment alone: development and procurement are also part of the lifecycle. It provides the organizing concept for the agency's public use-case repository and connects individual technology activities to the purposes they serve. The definition appears on the SEC's technology resource webpage.

OMB means the Office of Management and Budget, whose applicable guidance is the reference point for the agency's compliance planning. M-25-21 is the memorandum identified in the 2025 plan's official title. The SEC webpage uses the terminology 'super intelligence' and 'SI' for its current leadership and coordination arrangements, while retaining the document title '2025 AI Compliance Plan.' It identifies a Chief Super Intelligence Officer and an SI Task Force and also includes an August 2025 statement referring to an AI Task Force. These are the respective institutional and document labels used by the SEC.

Governance and Institutional Framework

The SEC resource webpage identifies Valerie Szczepanik as Chief Super Intelligence Officer. The role is responsible for promoting innovation, adoption, and governance in coordination with appropriate agency officials and for implementing applicable OMB guidance. This places responsibility for technology governance at a senior leadership level while connecting that responsibility to officials elsewhere in the agency. The leadership arrangement links operational innovation with oversight rather than treating adoption and compliance as separate organizational objectives.

The SEC describes an SI Task Force created in August 2025 to centralize agency efforts and support cross-agency and cross-disciplinary collaboration across the technology lifecycle. Its functions include removing barriers to progress, prioritizing beneficial applications, and maintaining governance. SEC divisions and offices also build enterprise capacity and implement mission-enhancing solutions. The resulting institutional model combines a central coordinating body with participation by the operational units that develop and use technology. The task force is an agency coordination mechanism, distinct from securities enforcement proceedings involving private firms.

Key Focus Areas

Governance and oversight are central to the SEC's public description of its AI program. Senior leadership coordinates responsible adoption, and the task force supports integration across divisions, offices, and disciplines. Operational innovation is another focus: the agency emphasizes augmenting staff capacity and improving efficiency and accuracy while advancing its statutory mission. These objectives frame AI as a tool for agency work and enterprise capability. The emphasis is on beneficial applications that support staff and institutional functions, alongside the maintenance of governance.

Transparency and accountability are reflected in publication of the compliance plan and the agency's use-case inventory resources. The SEC webpage links individual and consolidated inventories for 2025 and archives corresponding resources for 2024. Public access to these materials allows readers to distinguish the agency's stated governance approach from the documented scenarios in which technology is designed, developed, procured, or used. Policy publication, institutional responsibility, and use-case documentation are complementary components: they address the agency's approach, responsible actors, and recorded activities, respectively.

Implementation Framework

The SEC's public-facing implementation model combines senior leadership responsibility, centralized task-force support, and work by individual divisions and offices. The responsible senior officer implements applicable OMB guidance, while the 2025 compliance plan explains the agency's approach to consistency with that guidance. The task force promotes collaboration throughout the technology lifecycle and prioritizes beneficial applications. Divisions and offices contribute enterprise capacity and mission-enhancing solutions. Together, these roles support implementation across the agency rather than confining technology adoption to a single organizational unit.

For operational planning, the 2025 compliance plan, the applicable OMB instrument, and the agency's governance resources serve different functions. The plan addresses the SEC's compliance approach; the memorandum is its named reference instrument; and the public webpage describes organizational responsibilities and available inventory resources. An agency project can be considered in terms of its mission purpose, lifecycle stage, responsible office, and relationship to these governance arrangements. These considerations are practical organizing steps, not a separate set of legal obligations imposed on regulated financial institutions or technology suppliers.

Monitoring, Documentation, and Transparency

The public use-case repository is a visible documentation mechanism for the SEC's technology activities. The agency makes individual and consolidated 2025 inventory resources available through its official webpage, alongside archived 2024 materials. The use-case concept connects these records to specific scenarios and agency purposes. Individual and consolidated resources offer different levels of presentation within the same public documentation framework, while the archive preserves access to earlier annual resources.

The SEC's descriptions of responsible adoption and maintained governance place continuing oversight alongside innovation. The inventory resources document activities, and the compliance plan communicates the agency's approach to OMB guidance. These are distinct from one another: a policy explains an administrative framework, whereas an inventory organizes particular use cases. The webpage also carries a review-or-update date of October 6, 2026. That date identifies the maintenance of the webpage and belongs to the resource page's metadata, rather than serving as the plan's publication or effective date.

Scope, Accountability, and External Obligations

The plan's administrative subject is AI use within the SEC. Its connection to investor protection, market quality, and capital formation reflects the mission of the agency adopting the policy. That mission context is different from creating new duties for entities subject to securities regulation. The compliance plan should therefore be classified as an agency policy rather than an AI-specific securities rule. Senior leadership responsibility, task-force coordination, and documentation resources describe accountability within the agency's technology program.

Agency policy commitments, obligations originating in OMB guidance, securities-law requirements, and contractual terms are different categories of authority. A regulated firm or supplier should assess its responsibilities under the instruments that govern its own activities, rather than treating the existence of the SEC's internal plan as a new regulatory or contractual requirement. Likewise, the SEC's general securities enforcement responsibilities are separate from the administrative purpose of this compliance document. The implementation checklist below concerns the plan's scope, governance context, and public resources; it is not a schedule of fines, civil liability rules, or private-sector compliance duties.

Relationship to Other Instruments

The plan's clearest documentary relationship is to OMB Memorandum M-25-21, which appears in its official title. The SEC states that its compliance resources address consistency with applicable OMB guidance and are prepared in accordance with applicable law and guidance. The agency also archives the 2024 SEC Compliance Plan for OMB Memorandum M-24-10, identified as a September 2024 document. The two annual plans belong to the SEC's public compliance-planning resources and reference different OMB memoranda.

The Executive Order on Ensuring a National Policy Framework for Artificial Intelligence, dated December 11, 2025 and identified as Executive Order 14365, is a separate national policy instrument concerning AI policy and state-law issues. Its litigation task force, funding provisions, reporting proposals, and agency deadlines belong to that executive order. They are distinct from the SEC's operational compliance plan and are not presented here as SEC plan requirements. The executive order supplies broader domestic policy context, while the SEC document addresses the agency's own approach to OMB consistency.

Domestic Policy Alignment

The plan's alignment relationship is domestic and administrative: a U.S. federal agency describes its approach to consistency with guidance from the Office of Management and Budget. The SEC's institutional arrangements support that relationship through senior responsibility for applicable guidance, collaboration among agency units, and publication of compliance and inventory resources. The agency's mission supplies the operational context for adoption. This makes the plan an example of federal agency technology governance rather than a treaty, international recommendation, or cross-border market-access instrument.

For comparison with other AI instruments, the important distinction is between internal government operations and rules governing private developers or regulated markets. The SEC plan sits in the former category. The separate December 2025 executive order addresses U.S. AI leadership and a national policy framework, but those objectives remain attributes of that instrument. The SEC plan's principal topics are therefore governance and oversight, transparency and disclosure, and accountability and documentation.

Implementation Timeline

Implementation Checklist

Sources and References