Louisiana Executive Order JML 25-103 — State Government's Use of AI: AI Compliance Requirements
Executive Order JML 25-103 (signed by Governor Jeff Landry, September 16, 2025; amended by JML 25-109) governs how Louisiana executive-branch state agencies (not private vendors directly) may acquire and use AI. It (1) barred agencies from procuring or licensing AI before December 15, 2025; (2) required the state CIO (or each agency head, for agencies outside OTS's scope) to issue an AI-acquisition policy and an AI-related information-management policy by December 15, 2025 — both deadlines now passed; (3) requires an ongoing inventory of all AI contracts and AI use cases; (4) until an agency's Section 3 policy is implemented, prohibits inputting personal identifying information, property information, proprietary information, confidential data, or restricted data into any AI system; and (5) requires agencies to review/cleanse datasets before AI use. Separately, the Office of Technology Services published an Artificial Intelligence Acceptable Use Policy (effective September 29, 2025) governing AI use — including generative AI/LLMs and automated decision-making — across state agencies and OTS-governed entities. Neither the EO nor the OTS policy creates a public-facing AI-disclosure right or a contractor penalty regime; there is no confirmed Louisiana statute establishing one as of this verification.
Summary of publicly-available regulatory text as of 2026-08-22. Verify against current official sources before relying on this for compliance decisions. Not legal advice.
Key Facts
September 16, 2025
No statutory penalty confirmed. JML 25-103 is an executive order binding state agencies internally, not a penal statute; it creates no direct, sourced penalty against vendors/contractors. A vendor contracting with a Louisiana state agency should expect the agency's own AI-acquisition policy (adopted under EO Section 3) to be incorporated as a contract term, with ordinary contract remedies (not a statutory fine) for noncompliance.
What Your Business Must Do
2 compliance requirements identified. Critical requirements carry the highest risk of enforcement action.
Louisiana State-Agency AI Inventory and Acquisition Policy (EO JML 25-103)
Lower PriorityLouisiana executive-branch agencies must maintain an inventory of all AI contracts and AI use cases (EO §4) and operate under an AI-acquisition and AI-information-management policy (EO §3, required to be issued by Dec 15, 2025). For a vendor: expect a Louisiana state-agency customer to require compliance with its own AI-acquisition policy as a contract term and to ask for AI use-case documentation to satisfy its own inventory duty.
Restricted-Data Input Limits for State-Agency AI Systems (EO JML 25-103)
Lower PriorityUntil an agency's Section 3 policy is implemented, the agency (and by extension any AI system it operates or has a vendor operate on its behalf) may not input members-of-the-public PII, tangible/real-property information, proprietary information, confidential data, or restricted data into any AI system.
Who Does This Apply To?
Applies directly to Louisiana executive-branch state agencies (departments, offices, divisions, agencies, commissions, boards) under Executive Order JML 25-103 (signed 2025-09-16, amended by JML 25-109) and the OTS Artificial Intelligence Acceptable Use Policy (effective 2025-09-29). For a business, the practical trigger is contractual: if you supply an AI-powered product or service to a Louisiana state agency, the agency's own EO-mandated AI-acquisition policy and data-handling restrictions will typically flow to you through the contract, but the EO itself creates no direct statutory duty or penalty against vendors, and no confirmed Louisiana statute yet creates a citizen-facing AI-disclosure right in government services (a 2026 bill that would have done so, HB 734, was withdrawn 2026-03-30).
Recent Regulatory Guidance
Louisiana OTS — Artificial Intelligence Acceptable Use Policy (effective September 29, 2025)
Verified this cycle via WebSearch corroboration (WBRZ, KLAX-TV news coverage of the policy's release; the OTS policy page itself, ots.la.gov/policies-forms/artificial-intelligence-acceptable-use, could not be fetched directly this cycle — a government-site network-block, consistent with prior cycles' pattern). The policy sets guidelines for responsible, ethical AI use across Louisiana state government agencies and OTS-governed entities, covering machine-learning algorithms, automated decision-making systems, generative AI/LLMs, and cognitive-computing applications — aimed at protecting privacy/security, maintaining public trust, and preventing bias, consistent with EO JML 25-103's Section 3 mandate.
Key Case Law & Precedent
Lokken v. UnitedHealth Group (D. Minn., filed 2023)
US District Court, District of Minnesota · 2023Class action alleging UnitedHealth's nH Predict AI system was used to deny Medicare Advantage coverage in violation of medical-necessity standards. An illustrative national example of the AI-driven government/insurance benefits-denial failure mode that state AI-governance measures like EO JML 25-103's data-quality and human-oversight expectations are meant to guard against — not a case Louisiana OTS is independently confirmed to cite.
Outcome: 2025-02-13 ruling PARTIALLY GRANTED the motion to dismiss (unjust-enrichment and bad-faith-insurance claims dismissed; breach-of-contract and implied-covenant-of-good-faith claims allowed to proceed); litigation continues on the surviving claims
Case referenceFrequently Asked Questions
Does Louisiana Executive Order JML 25-103 — State Government's Use of AI apply to my business?
Executive Order JML 25-103 (signed by Governor Jeff Landry, September 16, 2025; amended by JML 25-109) governs how Louisiana executive-branch state agencies (not private vendors directly) may acquire and use AI. It (1) barred agencies from procuring… Use Aegis Firma's free scanner to get a personalized assessment in under 5 minutes.
What is the penalty for non-compliance?
The maximum penalty under Louisiana Executive Order JML 25-103 — State Government's Use of AI is: No statutory penalty confirmed. JML 25-103 is an executive order binding state agencies internally, not a penal statute; it creates no direct, sourced penalty against vendors/contractors. A vendor contracting with a Louisiana state agency should expect the agency's own AI-acquisition policy (adopted under EO Section 3) to be incorporated as a contract term, with ordinary contract remedies (not a statutory fine) for noncompliance.. Fines are typically scaled by company size, severity of violation, and whether violations were willful or accidental.
How do I comply with Louisiana Executive Order JML 25-103 — State Government's Use of AI?
The 2 requirements above cover the core obligations. The fastest path to compliance is: (1) conduct an AI risk assessment, (2) document your AI systems, (3) implement transparency disclosures where required. Aegis Firma generates all required documents automatically.
Official Source
https://gov.louisiana.gov/assets/ExecutiveOrders/2025/JML-Exective-Order-25-103.pdfLast updated: 2026-08-22 — verify at source before relying on this information.
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