Executive Order 14434, signed September 29, 2026 and published at 91 FR 63129 on October 2, tells federal executive agencies to write "Super Intelligence" and "SI" wherever they used to write "Artificial Intelligence" and "AI" in correspondence, websites, reports and policy documents. It changes the words agencies use. The law underneath is the same. Section 3(a) defines SI as the systems already covered by the statutory definition of artificial intelligence at 15 U.S.C. § 9401(3), and Section 2(b) leaves existing regulations, contracts and grants as they were issued. Nothing in the order binds companies, states or local governments. The provision worth your calendar is Section 3(b): by November 28, 2026 the President's science adviser must deliver proposed legislation defining SI, and that proposal may expand or supersede the definition that every AI obligation in federal law hangs on.
We build and document AI systems for government clients. Below is what we are changing in our own deliverables because of this order, and what we are leaving alone.
What does Executive Order 14434 require?
Section 2(a) is the operative text: "to the maximum extent permitted by law, executive departments and agencies (agencies) shall use 'Super Intelligence' and 'SI' in place of 'Artificial Intelligence' and 'AI' in official correspondence, public communications, websites, reports, policy documents, and other non-statutory documents within the executive branch."
Read what is missing from that sentence. There is no effective date beyond the signing, no deadline, no compliance report and no penalty. Section 1 adds a policy statement that the executive branch "will not acknowledge the usage of 'Artificial Intelligence' and 'AI' in any applicable setting," and the order never defines "applicable setting." No OMB memo has followed as of October 12. The OMB memoranda index ends at M-26-19, dated September 10, and the FAR Council and GSA have published nothing on the rename.
Agencies moved anyway. The EPA retitled its artificial-intelligence page "Super Intelligence" on October 1 and now publishes an "SI Use Case Inventory" and an "SI Compliance Plan," both still citing OMB memo M-25-21, which says "AI" throughout. NIST's center heading reads "Center for Advancing Innovation and Standards for Super Intelligence," while its AI Risk Management Framework page keeps the old name. Expect that pattern across government: new labels on top of documents whose governing text has not changed.
Does the order change existing contracts, grants or regulations?
No. Section 2(b): "Nothing in this section requires the alteration of previously issued regulations, Presidential actions, contracts, grants, or other historical documents."
Two words in that sentence do the work. "Requires" means agencies may re-paper old documents but do not have to, so do not expect your contracting officer to open a modification over vocabulary. "Previously issued" means the carve-out covers what already exists. New solicitations, new grant notices and new regulations are not mentioned, and whether a solicitation counts as a "non-statutory document within the executive branch" is the open question in the text. Wiley and Freshfields both expect SI to appear in new solicitations and RFIs. Plan for that.
Your current contract's attestations stay as written. If a clause requires you to disclose "AI" use or to follow an "AI" risk-management standard, the clause binds you under its own words, and the agency has no mandate to rewrite it.
What should contractors do with "AI" in proposals and deliverables?
Our rule has three parts: mirror the solicitation, define the term once, and change nothing already delivered.
Mirror the solicitation. If the RFP says SI, the proposal says SI. Evaluators read for responsiveness, and a vocabulary mismatch is a reason to score you down before anyone reads your architecture.
Define it once, anchored to the statute. One sentence in the definitions section: "'Super Intelligence' (SI) as used in this proposal has the meaning given to 'artificial intelligence' in 15 U.S.C. § 9401(3)." That is the anchor the order itself uses in Section 3(a). It ends the question of whether SI is a different, larger or smaller category than the AI your compliance program already covers. The Cloud Security Alliance gives the same advice and adds one more: do not create a separate "SI" risk tier. It is the same system with a new label.
Leave delivered documents alone. Architecture descriptions, model cards, user guides and test reports accepted under an existing contract are "historical documents" under Section 2(b). A rename pass produces a new version for the client to review and approve with no change in substance, and in an audit-sensitive environment every version is a question later.
Two housekeeping items follow from the rule. Ask the contracting officer in writing whether any requirement changed when the term did. Today the answer is no, and the email is worth keeping. Then fix your keyword searches. If you watch agency AI activity through SAM.gov saved searches, agency RSS feeds or scrapes of use-case inventories, add "Super Intelligence" and "SI" now. The EPA inventory has already moved out from under a search for "AI."
Does the Super Intelligence order apply to state and local governments?
No. The order's scope is "executive departments and agencies" of the federal government, and Section 4 disclaims any right enforceable by anyone else.
California answered the next day. Governor Newsom's Executive Order N-10-26, signed September 30, 2026, directs California agencies to "refer to Artificial Intelligence and AI as 'Artificial Intelligence' and 'AI,' notwithstanding any rebranded or different terminology used by the federal government." Texas's Responsible Artificial Intelligence Governance Act, in effect since January 1, 2026, and the Colorado AI Act keep "artificial intelligence" in statute, and neither state has moved.
For a vendor serving both levels of government, one system now carries two names. A federally funded state program will write its grant reports in one vocabulary and its state disclosures in the other. The IAPP's analysis calls this running "two vocabularies," and that is the right frame. We keep one glossary, one set of system identifiers and two labels, so a reviewer at either level can trace a claim back to the same component.
What happens on November 28, 2026?
Section 3(b) gives the Assistant to the President for Science and Technology 60 days from signing to submit "proposed legislative language to establish a Federal definition of 'Super Intelligence' and 'SI.'" The proposal must assess whether SI should "modify, expand upon, or otherwise supersede the existing statutory definition of 'artificial intelligence,'" propose conforming amendments to existing statutory references, and recommend further executive action. It goes to the President, and the order does not require anyone to publish it.
This is the provision with consequences for your compliance program. Agency use-case inventories under the Advancing American AI Act, the procurement terms in OMB memo M-25-22, and the Department of Defense's AI provisions in successive NDAAs all key off the § 9401(3) definition or one close to it. A broader definition pulls more systems into inventory and risk-management duties. A narrower one, say one limited to frontier models, pulls an ordinary document classifier or OCR pipeline out of them. Either outcome needs an Act of Congress, and until Congress acts, Section 3(a) holds and SI means what AI means.
Put the date on the calendar. When the proposal surfaces, read it against your own system inventory before you read anyone's summary of it.
A checklist for the next solicitation
- Use the solicitation's term. Do not correct the agency's vocabulary in your response.
- Add one definition sentence tying SI to 15 U.S.C. § 9401(3).
- Keep your compliance crosswalk keyed to the statute and the standard (§ 9401(3), NIST AI RMF, OMB M-25-21 and M-25-22), with the label as a column, not a row.
- Ask the contracting officer in writing whether requirements changed. File the answer.
- Leave accepted deliverables under existing contracts as issued.
- Add "Super Intelligence" and "SI" to every saved search and feed you use to track agency activity.
- If you also serve state or local clients, maintain one glossary with both labels and shared system identifiers.
- Calendar November 28, 2026 and assign someone to read the Section 3(b) proposal against your inventory.
Frequently asked questions
What is the definition of "Super Intelligence" under Executive Order 14434?
The same as artificial intelligence. Section 3(a) defines SI as "the technologies and systems encompassed by the term 'artificial intelligence' as defined in section 9401(3) of title 15, United States Code." That definition covers "a machine-based system that can, for a given set of human-defined objectives, make predictions, recommendations or decisions influencing real or virtual environments." A change would need a later Presidential action or an Act of Congress.
Do companies have to rename their products or websites?
No. Section 2(a) applies to executive departments and agencies. Section 4(c) states the order creates no right or obligation enforceable against any other person. Some vendors have adopted the term by choice; nothing requires it.
Will federal AI use-case inventories change?
The requirement is unchanged; the label is changing. The Advancing American AI Act and OMB memo M-25-21 still say "AI." Agencies such as the EPA now publish the same inventory under "SI." Search for both terms.
Does the order apply to federal grants?
Existing grants are covered by the Section 2(b) carve-out and stay as issued. The order does not address new funding notices, so expect the new vocabulary there and apply the same definition sentence in your application.
Does the order affect state AI laws?
Not directly. California's Executive Order N-10-26 requires state agencies to keep saying "AI." Texas and Colorado statutes keep "artificial intelligence." Wiley notes that the Section 3(b) legislative package could include preemption language; nothing in the order itself preempts state law.
Where the words change and the law does not, the cost lands on documents, searches and the people who maintain them. We build inside the client's boundary, and the boundary includes the paperwork. For how we handle oversight requirements in regulated deployments, read AI agents in regulated industries and how we work.
