OMB M-25-22 makes portability a pre-award architecture decision

Define the portable unit before comparing platforms

The direct CIO answer is to make portability a workload requirement before the request for proposal or contract renewal. Start with the business service and identify what would have to move if the provider, model, region, commercial terms, or risk decision changed. That unit can include source data, embeddings, prompts and system instructions, evaluation sets, fine-tuning artifacts, model or adapter rights, agent definitions, tool schemas, workflow state, audit records, policy configurations, user entitlements, integration code, and operating documentation. Saying that data can be exported is not an exit plan when the application depends on proprietary orchestration or an undocumented retrieval pipeline.

Classify each item as organization-owned, licensed, provider-owned, derived, reproducible, or unavailable. Record its format, volume, update frequency, dependency, sensitivity, and target environment. Then separate interoperability from substitution. An API may let two systems exchange information while leaving the customer unable to reproduce behavior elsewhere. Conversely, a portable dataset may still require extensive engineering, testing, security review, and business revalidation before another service can use it safely. The architecture decision needs both views.

Test the exit path while competitive leverage still exists

M-25-22 places lock-in protections in solicitation and contract design, where they can shape vendor commitments. A CIO can adapt that timing by requiring a small exit exercise before award. Export a representative data slice, configuration, evaluation record, logs, and documentation; rebuild or read them in a neutral environment; and measure what is missing. Ask the proposed provider to explain identity mapping, encryption keys, deletion, residual backups, support access, derived data, model dependencies, and the point at which service functionality ends.

The test should include a changed version and a failed dependency, not only a clean export. Confirm whether evaluation scripts still run, whether citations and audit links remain resolvable, and whether administrators can identify every integration that must be disabled. Set acceptance criteria for completeness, format, time, cost, and independent readability. A contractual promise to provide reasonable assistance is weaker than an observed transfer with named artifacts, owners, and limits. Preserve the evidence against the exact product tier and configuration reviewed.

Put switching cost beside subscription cost

Pricing transparency is useful only when the economic model includes dependency. Compare license and usage charges with data egress, retraining, re-indexing, interface replacement, testing, parallel operation, security review, user migration, records retention, vendor support, and business interruption. Include minimum commitments, bundled discounts, proprietary feature dependencies, subcontractors, and the operating knowledge that would have to be rebuilt. A low unit price can be expensive if it makes the next architecture choice impractical.

Do not turn the analysis into a universal preference for open source or multiple vendors. A managed proprietary service may be the better fit when its capability, reliability, support, or time-to-value outweighs a measured switching exposure. The decision record should show the conditions under which that trade is acceptable, the concentration threshold, and the evidence that could reverse it. Finance, procurement, legal, security, data, and the workload owner need the same dependency map so cost, rights, operational risk, and service value are not evaluated in separate documents.

Maintain portability as the workload changes

A passing pre-award test decays when a team adds proprietary tools, changes a model, expands data, adopts a provider-specific agent runtime, or lets documentation fall behind. Put portability triggers into change control. Material releases should identify new dependencies, rights, formats, evaluation requirements, and exit effects. Re-run a representative export and restoration on a risk-based schedule and before a major renewal. Track unresolved gaps, accepted exceptions, expiration dates, and the executive authorized to accept a constrained exit.

The federal memorandum is valuable here as a procurement pattern, not as authority over a private enterprise. The CIO remains responsible for translating it to the organization's workload, strategy, regulatory context, commercial leverage, and recovery objectives. A portable architecture is not one that can theoretically move someday; it is one whose critical artifacts, rights, knowledge, and tests are known well enough that leadership can make a credible stay, renegotiate, restrict, retire, or transition decision.

Turn this source into a reviewable decision

For AI for CIOs, use this briefing as a dated decision record rather than a substitute for the source. Preserve U.S. Office of Management and Budget, the exact URL, the July 27, 2026 review date, the supported facts above, the editorial interpretation, the limitations, and any buyer-specific evidence. Link that record to the decisions most directly affected: Enterprise AI platform architecture; Data products and AI-ready information; AI portfolio economics; Operations and incident intelligence. State whether the source changes the scope, evidence requirement, control, sequence, or only the language used to describe the decision.

Before action, name the accountable owner, affected population and workflow, exact offering or configuration, source data and rights, human decision point, exception and appeal path, complete cost, expected benefit, failure and stop conditions, retained evidence, and next review date. Keep official facts, provider statements, buyer observations, representative tests, measured outcomes, editorial inferences, and unknowns visibly separate. Reopen the record when the source, offer, model, integration, data, policy, population, responsible person, or measured result changes.

Limitations and unknowns

OMB M-25-22 governs specified U.S. federal acquisition activity and reflects federal policy choices. Its portability and lock-in provisions do not bind private buyers, guarantee competition, eliminate switching cost, confer intellectual-property rights, or prove that an export is complete or usable. Private application requires review of the actual workload, contract, licenses, data rights, security requirements, architecture, operating evidence, and applicable law.