Using AI to write a government proposal: what the rules say

For federal contracts, generally yes. As of October 2026 we know of no FAR or DFARS clause that bans using AI to write a proposal or requires you to say that you did. A search of the current FAR (FAC 2026-01) and DFARS parts that govern solicitations, proposals and contract clauses finds no mention of artificial intelligence, generative tools or language models.

The same is true of the FAR overhaul. Its new text is not final: eight of the twelve planned proposed rules were published on June 23 and September 18, 2026, and agencies apply the new text through class deviations. None of those rules mentions AI. The overhaul also renumbers the parts you know: the uniform contract format that defines Sections L and M moves from FAR 15.204-1 to 15.109, and the rule that proposals are scored only on the stated factors moves from FAR 15.305(a) to 15.202(a)(1) in the Part 15 text.

The AI language we found in the overhaul materials is advice to buyers in the non-regulatory FAR Companion. It says an oral presentation or demonstration "allows the government to discern actual capabilities of offerors (e.g., vice their use of proposal writers or artificial intelligence in proposal preparation)."

Any single solicitation can add its own AI terms, and those terms bind you on that bid. Look in the cover letter, Section L instructions, Section H special requirements, Section I clauses and every amendment. For a state or local bid, read the instructions to proposers and the terms and conditions. Some solicitations now ask offerors about AI use. When one asks, answer exactly what it asks, in the place it asks.

The AI rules agencies have issued so far are mostly about AI in the work you would deliver, not the proposal itself:

If a solicitation is silent on AI, there is nothing to disclose about how you drafted it. If it asks about AI in performance, answer for the work you propose. If it asks about AI in the proposal itself, answer that question too. When in doubt, send a question to the contracting officer during the Q&A period, as you would for any unclear instruction.

Using AI changes nothing about who is responsible for the proposal. A knowing and willful materially false statement in a matter within federal jurisdiction is a crime under 18 U.S.C. 1001. Under the False Claims Act, "knowingly" includes acting in "reckless disregard of the truth or falsity of the information" and needs "no proof of specific intent to defraud". Under FAR 52.203-2(b), "each signature on the offer is considered to be a certification by the signatory". A conviction or civil judgment for false statements is a cause for debarment under FAR 9.406-2.

Key personnel and past performance are where unchecked drafts do the most harm. GAO treats a proposal that "knowingly or negligently" relies on people the offeror had no reasonable basis to provide as a material misrepresentation (JANUS Research Group, B-423686.2, 2026). "Negligently" matters: an AI-drafted resume, staffing claim or past performance write-up that nobody checked is still your representation.

GAO has already dealt with AI-style errors, though in protest filings rather than proposals. It dismissed protests over citations to decisions that do not exist and warned of sanctions (B-423447, 2025; B-423649, 2025; B-424064, 2026). The problem GAO named was that the filer "did not take care to verify its research", not the use of AI. We found no GAO or court decision that rejects a proposal because AI wrote it.

Agencies "shall evaluate competitive proposals and then assess their relative qualities solely on the factors and subfactors specified in the solicitation" (FAR 15.305(a); 15.202(a)(1) in the overhaul text). So AI use is not graded unless the solicitation makes it a factor. We found no sign that agencies run AI detectors on contract proposals; the one detection statement we found is from NIH, about grant applications.

What evaluators do notice is generic writing: confident paragraphs that restate the requirement without a method, a named person, a number or a past result. That loses points under any Section M, and AI tools produce it easily when they are fed only the RFP. Feed the draft your own evidence and edit for specifics.

The government is also starting to use AI on its side. Law firms report a 2026 special operations solicitation saying the government may use AI to help analyze proposals, with decisions made only by government personnel, and a 2026 Court of Federal Claims ruling (TRAX International, No. 26-796) that AI evaluation reports an agency considered belong in the record (Burr & Forman; National Law Review). Write for a careful human reader and for a tool that checks your proposal against Section M.

The bigger day-to-day question is confidentiality. Sort the documents before anything goes into a tool, because what is in the file decides the rule:

For CUI on contractor systems, agencies "must use NIST SP 800-171" to set the safeguards (32 CFR 2002.14(h)(2)), and on defense contracts a cloud service that stores or processes covered defense information must meet security requirements equivalent to the FedRAMP Moderate baseline (DFARS 252.204-7012(b)(2)(ii)(D)). A CUI-marked attachment is still CUI before award. A proposed FAR provision, 52.240-6, would also bar offerors from using government-provided information for their own purposes and ask them to report CUI incidents within 72 hours; it is not final.

One more check on federal bids: under FAR 52.204-29, you represent, after a reasonable inquiry, that you will not provide or use a product covered by a FASCSA exclusion order in response to the solicitation. If an order ever names an AI product you use, ask the contracting officer how it applies to your bid.

• Grants are stricter than contracts. NIH will not treat applications "substantially developed by AI" as original ideas of the applicant, from the September 25, 2025 receipt date (NOT-OD-25-132).
• NSF encourages proposers to say how they used generative AI (NSF notice) and counts AI-assisted fabrication as research misconduct for awards from December 8, 2025 (NSF 26-200).
• NASA science grants allow AI tools but ask proposers to cite the tool, version, date and how it was used (NASA SMD FAQ).
• State and local bids: the rules we found (California SCM 2302, the District of Columbia clause) cover AI in the work you deliver. We found no state rule on AI used to write the bid itself, so read each RFP's instructions.
• Do not carry a grant rule into a FAR-based RFP, or the other way around.

1. 1

   Read the solicitation's AI terms first

   Check the cover letter, Section L, Sections H and I and every amendment for AI, data handling or disclosure language before the first draft. Note anything that limits tools or providers.

2. 2

   Sort the files before anything goes into a tool

   Public RFP text, CUI-marked attachments, export-controlled data and your own pricing each follow different rules. Keep CUI and export-controlled files out of any tool that does not meet their safeguards.

3. 3

   Draft from your own records

   Give the AI your past performance, resumes, capabilities and the outline built from Section L and M. A draft that starts from your evidence needs far less fixing than one that starts from the RFP alone.

4. 4

   Mark gaps instead of filling them

   Where your records have no answer, the draft should say so with a visible marker. A gap you can see gets fixed; a plausible invention gets submitted.

5. 5

   Verify every fact before review

   Names, dates, contract numbers, dollar values, certifications and citations, each checked against the source. Make it a named step in your review, not an assumption.

6. 6

   Keep a human final review and sign-off

   Someone who did not write the proposal reads the final version against the solicitation and signs off. Keep a short note of which tools you used and how, so you can answer accurately if the agency asks.

If you use ProposalWorkspace, the AI proposal writer is built around these steps: it drafts from the outline and your Company Library, marks gaps, and works inside the proposal editor, where AI edits can arrive as tracked changes. This guide is general information, not legal advice; for a specific bid, ask your counsel or the contracting officer.

How ProposalWorkspace handles this

An AI proposal writer that marks what it cannot prove

ProposalWorkspace's built-in AI drafts each section from your outline and your Company Library, and marks where your input is still needed instead of inventing it. With Suggesting mode on, every AI edit lands as a tracked change, and a final RFP proposal cannot move to submission until someone who did not write it signs off. Each workspace is isolated at the data layer and documents are encrypted in transit and at rest. There is no FedRAMP authorization or SOC 2 report, so work with CUI is not a fit. If a contract limits which AI providers you may use, ask us which providers the built-in AI uses: support@proposalworkspace.com.

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This guide is general information for federal contractors drawn from the FAR and standard capture and proposal practice. It is not legal advice; always read the specific solicitation and consult counsel on protests, contract terms and compliance questions.