The Model Follows You Into the Contract: Three Regimes Now Reach Past the Weights to the Whole Stack
Photo: Forkast
When a federal contractor builds a custom application on a foundation model, the working assumption is that the legal risk sits with the weights. That assumption expired this week. Between October 15 and October 20, three governance regimes reached the same layer at once: not the model files themselves, but the implementations deployers build on top of them. The most immediate pressure comes from the Department of Homeland Security. Published October 20 in the Federal Register (FR Doc 2026-21447, filed October 19), the Secretary of Homeland Security’s order does two things under the Federal Acquisition Supply Chain Security Act of…
Source: Forkast
