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The Pentagon has no single buying process for AI software. The route depends on whether a program needs custom software development, commercial software or services, or software integrated into a larger weapon or business program. Under a March 6, 2025 Secretary of Defense memorandum, the Software Acquisition Pathway (SWP) is the preferred route for software-development components of DoD programs. For qualifying SWP efforts, the memorandum directs components to use Commercial Solutions Openings (CSOs) and Other Transactions (OTs) as default solicitation and award approaches when statutory conditions are met. That policy does not make SWP mandatory for every AI purchase or remove security, integration, or intellectual-property requirements.
Why there is no single Pentagon AI contract
“The Pentagon” is convenient shorthand, but the 2025 software policy applies to Department of Defense (DoD) components and program offices. Headquarters does not personally choose and buy every AI application. A program’s mission, software scope, contracting authority, security needs, and place within a larger acquisition determine which office and process are involved.
The first distinction is what the government is acquiring. A team developing mission-specific AI software faces a different acquisition problem from an office licensing commercial software or maintaining an existing product. A third case is software that forms part of a larger weapon or business-system program. The software may be handled through the SWP even when the broader program follows another acquisition pathway.
Secretary of Defense Pete Hegseth gave the rationale in the March 6, 2025 memorandum: “Software is at the core of every weapon and supporting system we field to remain the strongest, most lethal fighting force in the world.” The memorandum promotes faster software acquisition, but its preferred-pathway language and statutory qualifications matter: it is not a blanket instruction to buy every AI product the same way.
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How a DoD program chooses a route
A program office starts with the capability it needs and the software work required to deliver it. The acquisition approach follows from that scope rather than from the label “AI.” The 2025 memorandum makes SWP the preferred path for software-development components of business and weapon-system programs, while other acquisition pathways remain available where the program context calls for them.
Custom software development
When the requirement is to build or substantially develop software, the SWP is the policy-preferred pathway. DoD describes the approach as iterative: deliver working software, gather feedback, and continue development as needs evolve. AI development may fit this model, but the existence of an AI component alone does not establish that SWP is the right route. The program still has to address how the software will obtain and use data, connect to operational systems, and meet mission and security requirements.
Iteration is useful when teams can assess working increments and use that feedback to shape later development. It does not remove the need to define the mission capability or decide how success will be assessed. Program teams should distinguish an early, usable increment from the complete operational capability they ultimately require; the former can help reveal integration or user issues without proving that all deployment conditions have been satisfied.
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AI inside a larger program
An AI feature may be one part of a major weapon-system or other capability program. The larger program can use a major-capability or another applicable pathway, while its software-development component is handled separately. A 2025 U.S. Army University Press article gives Project Linchpin as an SWP example and discusses major-capability pathways as another relevant route. That article is an example of pathway use, not a regulation making every AI integration an SWP effort.
This distinction matters for planning: a program may have to coordinate the software work with the larger system’s schedule, interfaces, testing, and mission environment. The fact that one software component follows the SWP does not mean the whole weapon or business program has switched pathways. Conversely, being embedded in a larger program does not by itself rule out a separate software approach.
Commercial software, services, and maintenance
Buying an existing commercial product or related maintenance is not the same as commissioning custom development. DFARS Subpart 208.74 governs DoD procedures for commercial software and related maintenance. It directs DoD components to fulfill those needs in accordance with the DoD Enterprise Software Initiative (ESI). ESI promotes enterprise agreements intended to obtain favorable terms and pricing; it does not dictate which products or services DoD must select.
In practical terms, the relevant comparison is not simply “AI versus non-AI.” It is whether the government is buying an existing product or service, funding development, or acquiring a software element as part of a broader capability. Commercial availability does not mean a product is automatically suitable for a classified or operational environment, and the ESI direction is a purchasing procedure rather than an endorsement of any particular vendor or tool.
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| Acquisition situation | Route or procedure to consider | Key issue to resolve |
|---|---|---|
| Custom software development | SWP is the preferred pathway under the 2025 memorandum | Define the increments, mission evaluation, integration, rights, security, and sustainment needs. |
| AI software within a major weapon or business program | The larger effort may use a major-capability or other pathway; software development may be handled separately | Coordinate the software component with the full program and its operational environment. |
| Commercial software or related maintenance | DFARS Subpart 208.74 and DoD ESI procedures | Assess product suitability and terms; ESI does not select the product. |
What the Software Acquisition Pathway changes
The SWP is intended to support software delivery on an iterative cadence rather than treating software as a one-time component that is finished only when a larger program concludes. The March 2025 DoD description presents a minimum viable product in under a year as a pathway goal. That is a target, not a promise that any given AI system will be ready for operational use within that period.
For a program office, the practical question is whether the software can be delivered and evaluated in useful increments. A minimum viable product is an early working capability, not necessarily a fully integrated, authorized, or final system. In an AI effort, the path from an initial capability to mission use may depend on access to usable data, integration with existing systems, user testing, and the required security and mission-assurance work.
The pathway also does not mean that all software requirements or controls disappear. DoD’s Software Fast Track (SWFT) initiative addresses cybersecurity and supply-chain requirements, verification, information sharing, and risk determinations. Acquisition planning must still account for how software will be secured, tested, deployed, supported, and maintained.
“Faster” should therefore be understood as an acquisition and delivery objective, not a promise to skip necessary evidence or approvals. Software that works in a development setting may still need additional work to function with operational systems, meet the requirements of its intended environment, and remain supportable after fielding. The sources do not establish one authorization timeline that applies to every AI effort.
CSOs and Other Transactions: default tools, not shortcuts
The March 6, 2025 memorandum directs DoD components to use CSOs and OTs as default solicitation and award approaches for qualifying SWP efforts when the relevant statutory authorities and thresholds apply. Those qualifications are essential. A program cannot treat either tool as automatically available just because it is buying AI or using SWP.
Commercial Solutions Openings
A CSO is a solicitation approach intended to reach potential providers of innovative commercial solutions. DoD’s March 7, 2025 background briefing described the policy as a way to widen access for commercial and nontraditional vendors. A CSO still involves an acquisition evaluation: a vendor must respond to the program’s needs, and the government must determine whether the proposed solution is suitable.
Other Transactions
An OT is an agreement made under specific statutory authority; it is not a general-purpose substitute for every contract. Whether an OT can be used depends on the applicable authority and the effort’s circumstances. The memorandum’s default direction for qualifying SWP efforts does not override those legal limits.
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These are different kinds of acquisition tools: a CSO describes a solicitation approach, while an OT is an agreement available under specific authority. The memorandum treats CSOs and OTs as default approaches for qualifying efforts, but that does not make them interchangeable in every case or eliminate the need to establish eligibility. A program must match the tool to the applicable law and circumstances.
Neither approach is a waiver of a program’s technical, security, supply-chain, or software-rights requirements. They describe ways to solicit or award work, not a guarantee that a vendor can bypass evaluation or that a chosen product can be deployed without further review.
What a procurement needs to resolve beyond the award
Selecting a solicitation and award method is only one part of buying software. An AI capability has to function in its intended operational environment, and the acquisition needs to define what the government will receive and what it can do with it.
Security and supply-chain risk
Cybersecurity and supply-chain considerations remain part of the acquisition. SWFT’s stated focus includes requirements, verification, information sharing, and risk determinations. A rapid solicitation or iterative development plan does not itself establish that a system has received the approvals needed for a particular environment. The evidence available here does not establish a universal security-authorization timeline for AI systems.
These considerations belong in planning as well as later review. A program should identify the intended environment and account for verification and risk determinations in its delivery plan. The source materials do not specify one checklist or approval duration for every program, so a vendor or buyer should not infer a standard path from the use of SWP, a CSO, or an OT.
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Software rights and delivery materials
Rights and access need to be considered as part of the procurement, not left as an afterthought. DoD’s current DFARS guidance points acquisition personnel toward software-pathway and intellectual-property guidance. In practical planning, teams need to determine which code, documentation, test materials, and other deliverables the government will receive, and what rights it will have to use or modify them. The specific rights depend on the contract or agreement; no single rights package can be assumed for every AI acquisition.
For vendors, this makes the proposed deliverables and rights terms part of the offer’s fit, not a detail to postpone until after selection. For program teams, the question is what access is needed to operate, test, update, or sustain the software over time. The applicable agreement controls the actual rights, and the general pathway policy alone does not answer that question.
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Integration and sustainment
Software needs to connect to the systems and workflows in which it will be used, and the program must plan for continued operation after initial delivery. That includes considering deployment, updates, maintenance, and support in the intended mission environment. A commercially available AI service, custom software, and an embedded system can create different integration and sustainment needs, so these should be defined with the scope of the purchase.
Integration can also affect how a program defines a meaningful delivery increment. A working capability that cannot yet connect to necessary data or systems may be useful for evaluation but is not necessarily ready for operational use. Planning for updates and ongoing support helps distinguish a successful demonstration from a capability the organization can continue to use.
What the adoption and delivery figures do—and do not—show
DoD has reported substantial use of the SWP, but the figures describe adoption or program-level cadence at specific dates. They do not prove that every program delivered successfully, establish the current total, or predict the schedule of a new AI procurement.
| Reported figure | What it measures | Qualification |
|---|---|---|
| 82 SWP programs; nearly 400% growth since launch | DoD briefing officials’ reported program count and growth | Published March 7, 2025; the count was attributed to an unnamed defense official, not presented as an independently audited total. |
| Approximately 50% annual growth | Growth in programs adopting the pathway during FY23–24 | Reported by the DoD Chief Information Officer in a 2025 implementation-plan summary. This is adoption growth, not a delivery-success rate. |
| 75% delivered on cadences shorter than six months; 74 active programs; $13.1 billion in spending | Program cadence, active program count, and spending | DoD figures published in August 2024; they should not be read as a 2026 count or as a statistic specific to AI programs. |
| Minimum viable product in under a year | SWP target or pathway description | Described by DoD News on March 10, 2025; it is not evidence that every program achieves that schedule. |
These figures show that DoD has been adopting the pathway and that many programs have reported short delivery cadences. They do not say how long a particular AI system will take to field. Data readiness, integration, classification, cyber authorization, mission assurance, and user testing can all affect the work, and the cited sources provide no universal schedule.
The figures also measure different things and come from different reporting periods. The 82-program and nearly 400% statements were given in a March 7, 2025 DoD briefing; the FY23–24 growth rate appears in the DoD Chief Information Officer’s 2025 implementation-plan summary. The August 2024 numbers describe active programs, spending, and cadence at that time. None should be converted into a claim about the number of AI projects, a current 2026 program count, or a guaranteed delivery result.
A practical decision sequence for a program office
- Define the capability and scope. Specify whether the need is custom development, a commercial product or service, maintenance, or software integrated into a broader program. Identify the mission context and the users who will evaluate the result.
- Choose the acquisition pathway for the work. Consider SWP for software development in light of the 2025 preferred-pathway policy. If the software is a component of a larger program, assess how that component relates to the program’s broader pathway rather than assuming the entire effort uses one route.
- Check authority before choosing solicitation and award tools. For a qualifying SWP effort, assess whether statutory conditions and thresholds permit the directed default approaches of a CSO and OT. Do not assume eligibility based only on the technology category.
- Plan commercial software purchases under the applicable procedures. For commercial software and related maintenance, account for DFARS Subpart 208.74 and the direction to use DoD ESI processes. ESI supports enterprise agreements but does not make the product-selection decision.
- Define the technical and operational conditions for delivery. Establish how the software will be evaluated, integrated, secured, and sustained. Decide what an initial usable increment means for this mission and what remains necessary before operational use.
- Set software-rights and delivery expectations. Address code, documentation, test materials, deployment needs, and the government’s intended use rights in the applicable agreement.
- Plan for iteration and scale-up. Set review points for feedback, verification, and decisions about continued development or broader use. Treat the under-one-year MVP language as a target, not a schedule commitment.
The sequence is a planning framework, not a substitute for the governing solicitation, contract, statute, or acquisition rules. The early scope decision helps prevent a common mismatch: applying a development pathway to a straightforward commercial-software purchase, or assuming that a commercial product solves integration and sustainment questions by itself. Revisit assumptions as the program learns from testing and user feedback, while keeping authority, security, and rights requirements explicit.
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A vendor considering DoD work should first determine what the solicitation is actually seeking: a commercial product or service, development work, or a software component within a larger program. That distinction affects which policy and procurement procedures may apply. A CSO or OT may be a default approach for a qualifying SWP effort, but neither guarantees that the program will select a particular company or that the company’s offering satisfies mission requirements.
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Vendors should be prepared to explain how their offering fits the requested environment, how it will be integrated and sustained, what data or system dependencies it has, and what software rights and deliverables are proposed. Security and supply-chain requirements remain part of the procurement. The available sources do not establish a universal AI contract price, a single award timeline, or a standard authorization path, so vendors need to rely on the specific solicitation and agreement terms rather than assume a common process.
For commercial and nontraditional companies, the 2025 DoD briefing’s stated aim of widening access is relevant, but access to an opportunity is not the same as eligibility for every award tool or selection for an award. The solicitation defines the need and evaluation; applicable authority determines which instrument can be used. Companies should avoid assuming that the word “AI” or the presence of a CSO or OT means that standard mission, security, integration, or rights questions will not be asked.
Where the evidence is specific—and where it is not
The policy position described here is based on the Secretary of Defense’s March 6, 2025 memorandum, DoD’s contemporaneous March 2025 explanations, the FY25–26 modernization-plan summary, the DFARS enterprise-software provision effective May 7, 2026, and official DoD summaries of SWFT and CDAO’s Open DAGIR. The Project Linchpin example comes from a 2025 U.S. Army University Press article, not from acquisition regulation.
Those materials establish the preferred role of SWP for software development, the qualified default direction on CSOs and OTs, and the distinction between software development and commercial-software procedures. They do not provide a current named AI award example, a price schedule, or a universal timetable. Because the subject is policy-sensitive, a team preparing an actual solicitation should verify the operative directive, statutory authority, and applicable DFARS text for that procurement.
Frequently Asked Questions
Does every DoD AI purchase use the Software Acquisition Pathway?
No. The March 6, 2025 memorandum makes SWP the preferred pathway for software-development components of programs, not a universal route for every AI product. Commercial software and maintenance follow applicable commercial-software procedures, and software within a larger program may be handled alongside a broader major-capability or other pathway.
What are CSOs and Other Transactions?
A Commercial Solutions Opening (CSO) is a solicitation approach intended to reach providers of innovative commercial solutions. An Other Transaction (OT) is an agreement available under specific statutory authority. The 2025 memorandum directs these as default approaches for qualifying SWP efforts when statutory conditions and thresholds apply; neither is an automatic shortcut around evaluation or security requirements.
How long does it take to field AI software for DoD?
There is no universal timeline in the cited DoD materials. DoD described an under-one-year minimum viable product as a SWP goal in March 2025, not a guarantee that every AI system will be operational within a year. Data readiness, system integration, classification, cyber authorization, mission assurance, and user testing can affect delivery.
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DFARS Subpart 208.74 governs commercial software and related maintenance procedures and directs DoD components to use DoD Enterprise Software Initiative processes. ESI promotes enterprise agreements for favorable terms and pricing; it does not select or endorse a particular product.
Do CSOs or OTs remove cybersecurity and software-rights requirements?
No. They are solicitation and award approaches, not waivers of cybersecurity, supply-chain, integration, intellectual-property, or sustainment requirements. The specific agreement and applicable authority determine the permitted instrument and software rights.
The Bottom Line
DoD’s 2025 policy makes the Software Acquisition Pathway preferred for software-development components, with CSOs and Other Transactions as default approaches only for qualifying efforts where the law permits. Commercial software, AI embedded in larger programs, and custom development can follow different routes. Whatever the instrument, mission fit, security, integration, software rights, and sustainment still shape what can actually be fielded.
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