# Super Intelligence Terminology in State and Local (SLED) Procurement

Executive Order 14434 directs federal executive agencies to adopt Super Intelligence terminology, but presidential directives carry no legal authority over state and local procurement. State and local solicitations operate under state statutory codes that define and regulate artificial intelligence independently. Understanding the division between federal orders and state procurement laws protects contractors from bidding disqualifications across public sector contracts.

Source: https://fast.io/resources/super-intelligence-terminology-state-local-procurement/
Author: [Tom Langridge](https://fast.io/authors/tom-langridge/)
Last reviewed: 2026-10-09

## Why Federal Super Intelligence Orders Stop at State and Municipal Lines

In the 2024 legislative session, at least 45 states introduced artificial intelligence legislation, and 31 states adopted resolutions or enacted laws, establishing an independent state-level governance framework across the country. That expanding body of state law explains why federal executive actions cannot unilaterally reshape how cities, counties, and state agencies purchase technology.

When the White House issued [Executive Order 14434](https://www.whitehouse.gov/presidential-actions/2026/09/inaugurating-the-era-of-super-intelligence/) on September 29, 2026, titled "Inaugurating the Era of Super Intelligence," federal executive branch operations shifted immediately. Section 2(a) directs executive departments and agencies, to the maximum extent permitted by law, to use "Super Intelligence" and the abbreviation "SI" in place of "Artificial Intelligence" and "AI" across official correspondence, public communications, websites, reports, policy documents, and other non-statutory documents. Section 1 directs agencies not to acknowledge earlier terms in applicable settings, while Section 2(b) leaves existing contracts, grants, and regulations unchanged.

Commercial technology vendors frequently assume that high-profile federal procurement shifts automatically cascade down to state, local, and education (SLED) public contracting. In state and municipal bids, that assumption is legally incorrect and introduces immediate evaluation hazards.

Federal executive orders derive their authority from Article II of the United States Constitution and specific statutory delegations enacted by Congress. Under the Tenth Amendment and established principles of state sovereignty, a presidential executive order cannot direct how state or local governments buy technology. A presidential directive carries no legal authority over state legislatures, county boards of supervisors, municipal purchasing departments, or public school districts. Executive Order 14434 is addressed to executive departments and agencies, and Section 4(c) adds that it creates no right or benefit enforceable at law.

SI also has other meanings, such as the International System of Units. Proposal teams should spell out "Super Intelligence (SI)" on first reference whenever the federal administrative term appears.

The terminology requires distinguishing between two separate concepts that share a label:

- Federal Super Intelligence (two capitalized words, abbreviated as SI) is an administrative label for existing operational software meeting the functional standard codified in 15 U.S.C. 9401(3).

- Research superintelligence (one compound word, commonly abbreviated as ASI for artificial superintelligence) is a hypothetical future computing system that would exceed human expert performance across almost every cognitive discipline. That hypothetical system does not exist today. Commercial research organizations, including Meta Superintelligence Labs, Microsoft's MAI Superintelligence Team, and Safe Superintelligence Inc., cite artificial superintelligence as a long-term research objective.

The governing reality across state, local, and education procurement remains straightforward:

State and local procurement terminology operates under state statutory codes independent of federal Executive Order 14434, retaining standard 'artificial intelligence' definitions across SLED solicitations.

Vendors preparing bid responses for state departments of transportation, county healthcare systems, or municipal utilities must anchor their proposals in the governing legal codes of the specific purchasing entity, rather than adopting federal executive branding.

## How State Procurement Codes Define and Regulate Artificial Intelligence

State and local governments procure software, hardware, and consulting services under state public contracting codes, administrative rules, and municipal charters. State purchasing officials must comply with statutes enacted by their state legislatures, rather than executive directives issued in Washington.

State legislatures across the country have debated, introduced, or enacted explicit statutory definitions and oversight mechanisms for artificial intelligence. Where a state statute defines artificial intelligence, state buyers draw on that definition and on state IT policy when they write solicitations and contract terms.

### California Uniform Statutory Baseline

California established a unified statutory baseline through Assembly Bill 2885 (Chapter 843, Statutes of 2024), effective January 1, 2025. AB 2885 enacted a standard definition of artificial intelligence across the California Government Code, Business and Professions Code, and Education Code. Under California Government Code Section 11546.45.5, artificial intelligence is defined as:

"An engineered or machine-based system that varies in its level of autonomy and that can, for explicit or implicit objectives, infer from the input it receives how to generate outputs that can influence physical or virtual environments."

This definition governs IT purchasing across California state agencies managed by the Department of General Services (DGS) and the California Department of Technology (CDT). Under state policy, state entities acquiring generative AI must complete a Generative Artificial Intelligence Risk Assessment (SIMM 5305-F) and follow the GenAI procurement rules in State Administrative Manual Section 4986.9. Solicitations issued on the Cal eProcure portal use California statutory terminology. Bidders that substitute unauthorized federal phrases risk confusion during administrative compliance reviews.

### State Statutory Enactments

Other state legislatures have codified specific regulatory frameworks:

- Colorado: Senate Bill 24-205 created consumer protections regarding algorithmic discrimination in high-risk automated systems. Codified in Colorado Revised Statutes (C.R.S. Section 6-1-1701 et seq.), the law establishes compliance duties for developers and deployers of high-risk artificial intelligence systems.

- Texas: House Bill 2060 established the Artificial Intelligence Advisory Council to study state agency use of automated decision systems. The law, in Chapter 2054 of the Texas Government Code, also required state agencies to report to the Texas Department of Information Resources (DIR) an inventory of the automated decision systems they develop, use, or procure.

- Maryland and Utah: Maryland directed its Department of Information Technology (DoIT) to establish statewide AI procurement standards. Utah enacted the Artificial Intelligence Policy Act (Senate Bill 149, Utah Code Title 13, Chapter 72), creating the Office of Artificial Intelligence Policy.

### The Federal Statutory Anchor

The reason state statutes do not mirror Executive Order 14434 becomes clear when reviewing the federal order's internal definition. Section 3(a) sets forth:

"For purposes of this order, and except where otherwise provided by law, the terms 'Super Intelligence' and 'SI' mean the technologies and systems encompassed by the term 'artificial intelligence' as defined in section 9401(3) of title 15, United States Code."

Congress enacted [15 U.S.C. 9401(3)](https://www.law.cornell.edu/uscode/text/15/9401) under the National Artificial Intelligence Initiative Act of 2020:

"The term 'artificial intelligence' means a machine-based system that can, for a given set of human-defined objectives, make predictions, recommendations or decisions influencing real or virtual environments."

Section 3(a) ties federal Super Intelligence directly to 15 U.S.C. 9401(3), confirming that federal SI and AI name the exact same functional technologies in federal administration today. However, state procurement officers operate under state procurement codes and rules. Until a state legislature passes a bill updating state code, state procurement officers evaluate bids against enacted state definitions.

## Federal Executive Branch Usage Compared to SLED Procurement Requirements

Understanding the boundary between federal executive branch directives and state procurement requirements prevents expensive bidding mistakes across public sector contracting.

State and local public sector procurement represents significant annual spending across 50 states, thousands of counties, and tens of thousands of municipalities, special districts, and school systems. This market, commonly known as SLED, operates under legal structures that differ from the Federal Acquisition Regulation (FAR).

The following comparison table highlights the operational and statutory differences between federal executive branch usage and SLED procurement:

| Operational Dimension | Federal Executive Branch (EO 14434) | State and Local (SLED) Procurement | Compliance and Bidding Impact |
| :--- | :--- | :--- | :--- |
| Governing Authority | Presidential Executive Order 14434 | State statutory codes, administrative regulations, and municipal charters | Federal directives do not bind state or local agencies |
| Primary Terminology | Super Intelligence (SI) mandatory in non-statutory documents | Artificial Intelligence (AI) standard across state procurement | Bids must mirror the specific terminology of the issuing agency |
| Statutory Basis | 15 U.S.C. 9401(3) (National AI Initiative Act of 2020) | Independent state statutes (such as California AB 2885, Colorado SB 24-205) | Systems are defined by functional capabilities under state law |
| Solicitations and RFPs | SOWs, PWSs, and Section L/M instructions may use Super Intelligence | Requests for Proposals (RFPs) and Invitations for Bids (IFBs) specify AI | Offerors should use the RFP's exact phrasing to pass scoring filters |
| Vendor Binding Mandate | No directive to private companies; agencies follow administrative policy | Vendors must satisfy mandatory state disclosure and inventory rules | Commercial product branding remains private under both jurisdictions |
| Pre-Existing Contracts | Section 2(b) states that nothing in that section requires the alteration of previously issued contracts; historical titles unchanged | Existing state master agreements and cooperative contracts remain valid | Citing historical AI contracts requires original awarded titles |
| Risk Assessments | National Institute of Standards and Technology (NIST) AI RMF | State-specific frameworks (such as California SIMM 5305-F) | State risk assessments require specific state statutory disclosures |
| Evaluation Focus | Compliance with Section M factors and FAR Part 15 source selection | Compliance with state responsive bidder criteria and lowest responsible bid | Mirror the solicitation's terms so evaluators can match the response to each requirement |

### The Role of NASPO and State Procurement Standards

The National Association of State Procurement Officials (NASPO) and the National Association of State Chief Information Officers (NASCIO) publish guidance for state purchasing and IT leaders that commonly addresses topics such as these:

- Algorithmic transparency: Contractors must describe how automated decision tools generate recommendations, particularly when public benefits or civil rights are involved.

- Data ownership and privacy: Vendor contracts must confirm that state public data is not ingested into external public models or used for unauthorized model training.

- Vendor liability: State procurement officers evaluate AI contracts to verify that vendors accept liability for intellectual property infringement or algorithmic errors.

- Public records compliance: Automated outputs are subject to state sunshine laws, requiring vendor systems to support records retention and discovery.

### Competitor Gaps and SLED Bidding Traps

Enterprise capture teams often assign federal bid managers to handle major state solicitations without adjusting their terminology, creating three critical bidding traps in SLED proposals:

- The Terminology Mismatch Trap: If a state RFP specifies 'Artificial Intelligence technical requirements' and an offeror writes about 'Super Intelligence architectures' without using the state's terms, evaluators may struggle to match the response to the requirements and score it lower.

- The Autonomous Capability Alarm: Because 'superintelligence' in general commentary denotes speculative superhuman autonomy, introducing the phrase into a conservative municipal procurement can alarm evaluators assessing public safety, utilities, or transit tools.

- The State AI Inventory Disconnect: Many states require vendors to complete an AI disclosure checklist during bid submission. An offeror that renames its product literature to 'Super Intelligence' might check 'No' on a state AI disclosure form, which can constitute a material misrepresentation under state procurement integrity laws.

## Bid Response Strategies for SLED Proposals and Vendor Solicitations

Commercial vendors, system integrators, and software providers bidding on public sector contracts must implement disciplined bid strategies that respect jurisdictional boundaries. Public sector sales teams can adopt five practical strategies to navigate state, local, and federal solicitations successfully:

### 1. Mirror the RFP's Explicit Terminology

The foundational rule of government proposal writing is strict responsiveness. Offerors must match the exact terminology used in the solicitation:

- Federal solicitations: When responding to a federal RFP requesting "Super Intelligence technical approaches," use Super Intelligence (SI) in technical volumes, noting functional machine learning architectures codified in 15 U.S.C. 9401(3).

- SLED solicitations: When responding to a state, county, municipal, or school district RFP requesting "Artificial Intelligence software solutions," use Artificial Intelligence (AI) consistently across every volume, executive summary, and compliance matrix.

Never attempt to educate state evaluators by claiming artificial intelligence has been replaced by Super Intelligence. State evaluators score proposals against criteria approved by state contracting officers.

### 2. Maintain a Bid Vocabulary Crosswalk

Organizations competing for both federal and SLED contracts should maintain an internal vocabulary crosswalk mapping technical capabilities across naming conventions:

- Core Technology: Machine learning, predictive analytics, natural language processing, automated document extraction, and computer vision.

- Federal Solicitations: Super Intelligence (SI), anchored to 15 U.S.C. 9401(3) and Executive Order 14434 Section 2(a).

- SLED Solicitations: Artificial Intelligence (AI), automated decision systems, and advanced data analytics, anchored to state codes (such as California Government Code Section 11546.45.5 or Colorado C.R.S. Section 6-1-1701).

- Commercial Product Descriptions: Standard commercial off-the-shelf (COTS) branding, functional software feature descriptions, and technical specifications.

Capture teams use this crosswalk to verify that proposal text and solution architectures match the target solicitation before submission.

### 3. Complete State AI Inventories Accurately

State procurement offices increasingly require bidders to declare whether their proposed solution contains artificial intelligence components. In states such as California and Texas, state agencies must inventory the automated decision systems they use, and some solicitations include questionnaires on algorithm use, training data sources, and bias testing.

Offerors must answer these questions based on functional technology. If a solution uses machine learning to classify documents, route tickets, or detect fraud, the vendor must check "Yes" on the state form. Omitting disclosure because software was marketed under a federal administrative phrase creates severe compliance liability.

### 4. Submit Formal Clarification Requests on Blended Solicitations

A frequent challenge in SLED contracting arises when state agencies issue solicitations funded partially or entirely by federal grant programs. In these blended scenarios, solicitation documents occasionally display mixed terminology, with federal grant attachments referencing federal directives and the primary state RFP using state statutory phrasing.

When solicitations contain conflicting terminology, offerors should submit a formal question during the pre-proposal question-and-answer period:

"Reference Section 3.2 of the RFP Specifications and Attachment D (Federal Grant Provisions): Section 3.2 references 'Artificial Intelligence (AI) predictive models,' while Attachment D references federal administrative guidelines under Executive Order 14434. Please confirm that offerors should structure their technical proposal volumes using the state's standard 'Artificial Intelligence (AI)' terminology to demonstrate responsiveness to Section 4 evaluation criteria."

If the agency changes the solicitation in response, it issues a written addendum to all bidders; keep the response with the bid file.

### 5. Preserve Historical Past Performance Records

When submitting past performance citations for state and municipal bids, vendors must cite previous projects using the exact legal contract titles awarded. State evaluators contact client references and verify past performance through state contractor databases or federal repositories. If an offeror lists a prior project as "Municipal Super Intelligence Deployment," but the original contract and reference contact know the work as "Municipal AI Fleet Optimization," the discrepancy raises verification red flags.

Section 2(b) of Executive Order 14434 states that nothing in that section requires the alteration of previously issued federal contracts, grants, or other historical documents. It does not govern state procurement, but citing awards by their original titles is standard practice in state bids too. Always cite historical awards by their original statutory and contractual titles.

## Coordinating SLED Proposals and Compliance Records in Centralized Workspaces

Coordinating state, local, and federal procurement proposals requires rigorous document control across distributed capture teams, commercial partners, and legal reviewers.

A competitive SLED capture effort involves tracking multiple state solicitations, local amendments, subcontractor agreements, pricing sheets, and state disclosure affidavits. Storing files across disconnected local drives and email threads introduces compliance vulnerabilities, such as submitting outdated commitment letters or unapproved pricing models.

To keep proposal files aligned, versioned, and auditable, contracting teams and public sector vendors rely on centralized cloud workspaces.

[Fast.io workspaces](/product/workspaces/) provide dedicated environments where procurement professionals, capture managers, and their automated tools organize, review, and maintain bid packages. Organizations create dedicated, org-owned workspaces for specific state procurement opportunities, cooperative purchasing vehicles, or proposal efforts, establishing a single source of truth for all participating personnel.

Key workspace capabilities for public sector proposal operations include:

- Granular access controls: Permissions are set per organization, workspace and share; a share gives an outside party access to only the files or folder placed in it. Prime contractors can invite external teaming partners and certified minority-owned, woman-owned, or disabled veteran business enterprise (MBE/WBE/DVBE) subcontractors to specific contribution folders while restricting access to proprietary margin analyses, labor rate build-ups, and executive cost summaries.

- Per-file version history: Every document uploaded to a workspace maintains a complete revision history. Teams can track draft revisions across color-team review milestones (Pink Team for storyboards, Red Team for detailed compliance, Gold Team for final executive sign-off), verify that mandatory review comments were incorporated, and restore earlier text if needed.

- Detailed activity log: Fastio keeps a detailed activity log of file uploads, changes, and permission and membership changes, so capture executives and compliance officers can see who changed which file and when.

- Metadata Views: SLED solicitations and master contracts (such as NASPO ValuePoint agreements) frequently run hundreds of pages across terms, conditions, and addenda. [Metadata Views](/product/document-data-extraction/) turn unstructured solicitation documents and contracts into structured, queryable data. Teams describe extraction fields in plain language, and the system extracts submission deadlines, mandatory state clauses, insurance requirements, and subcontracting percentage goals into a sortable spreadsheet view.

- Notes: Proposal contributors and reviewers can keep outlines, compliance matrices, and reviewer action items as notes in the workspace, next to the files they reference.

- Workspace e-signature: Teaming agreements, non-disclosure agreements, and subcontractor commitment letters can be routed and signed directly within the workspace through [e-signature](/product/e-signature/). Documents support sequential or parallel signer routing, optional one-time passcodes per signer, and a tamper-evident audit certificate filed back into the workspace upon execution.

Fastio encrypts data in transit and at rest, scopes access by workspace and share, and keeps a detailed activity log.

Fast.io provides transparent subscription tiers on [Fast.io pricing](/pricing/). Organizations begin evaluating the platform through a 14-day trial on monthly plans, which requires a credit card.

| Plan Tier | Monthly Billing | Workspace Allowance | Included Storage | Monthly AI Work Credits |
| :--- | :--- | :--- | :--- | :--- |
| Starter | $9.99 per month | 5 workspaces | 250 GB | 100,000 credits |
| Business | $49.99 per month | 50 workspaces | 5 TB | 600,000 credits |
| Enterprise | $199.99 per month | 200 workspaces | 25 TB | 3,000,000 credits |

Additional AI work credits can be added as procurement operations expand. Centralizing procurement documentation inside dedicated workspaces keeps acquisition records coordinated and auditable throughout the contracting lifecycle.

## Policy Timelines, Federal Proposals, and Future SLED Alignment

Procurement professionals, state contracting officers, and commercial vendors must balance immediate solicitation compliance with forthcoming statutory and administrative milestones.

The most notable upcoming federal milestone appears in Section 3(b) of Executive Order 14434. That provision directs the Assistant to the President for Science and Technology (APST), who leads the White House Office of Science and Technology Policy (OSTP), to submit proposed legislative language for a federal definition of "Super Intelligence" and "SI" to the President within 60 days of the signing date. Because President Trump signed the order on September 29, 2026, this 60-day deadline arrives on November 28, 2026.

As of October 2026, no statutory definition of Super Intelligence exists in federal law. The November 28, 2026 report is an internal executive proposal submitted to the President, not an enacted statute. An executive order cannot amend federal statutes; only an Act of Congress signed by the President can update the United States Code. What the proposal from the Assistant to the President for Science and Technology will contain, and whether Congress will introduce or enact conforming statutory amendments, remains undetermined as of October 2026.

### Why State Codes Will Not Automatically Follow Federal Proposals

Even if the federal government eventually enacts statutory definitions of Super Intelligence, state legislatures will not automatically alter state procurement codes:

- Independent Legislative Calendars: State legislatures operate on independent schedules, often meeting part-time or biennially. Proposed statutory updates require deliberate committee hearings and floor votes.

- Model Procurement Codes: Many states base statutes on the ABA Model Procurement Code. Terminology updates follow deliberate study by NASPO, NCSL, and state advisory bodies.

- Constitutional Autonomy: States maintain sovereign authority over public expenditures under the Tenth Amendment. Unless a federal grant statute explicitly conditions funds on adopting specific terminology, state legislatures retain full authority over state contracting categories.

### Practical Guidelines for Contracting Officers and Bidding Vendors

To maintain compliance across federal and SLED markets, contracting personnel should observe five practical guidelines:

- Focus on Functional Capabilities: Anchor technical specifications, statements of work, and proposal volumes in verifiable functional performance (machine learning models, automated data processing, computer vision, natural language understanding). Such systems generally fall within both 15 U.S.C. 9401(3) and state statutory definitions, though state definitions vary.

- Respect Solicitation Primacy: Treat the individual RFP as the authoritative standard for bid vocabulary. Do not impose federal executive terminology onto state bids, and do not use informal terminology on federal solicitations.

- Maintain Complete Audit Trails: Document all procurement decisions, pre-bid clarification questions, and proposal revisions in centralized, auditable workspaces to protect against post-award bid protests.

- Monitor State Legislative Sessions: Track state legislative developments through resources such as the NCSL Artificial Intelligence Legislation Database to anticipate changes in state disclosure rules, algorithmic impact assessment requirements, and procurement standards.

- Consult Qualified Legal Counsel: Because Executive Order 14434 creates no privately enforceable legal rights under Section 4(c), contractors facing ambiguous contract terms or blended funding requirements should consult their organization's legal counsel or the cognizant contracting officer.

## Frequently asked questions

### Does the federal Super Intelligence executive order apply to state and local contracts?

No. Executive Order 14434 applies only to federal executive departments and agencies. Under the Tenth Amendment and state administrative law, presidential directives carry no legal authority over state legislatures, municipal purchasing departments, or public school districts. SLED contracts operate under state statutory procurement codes.

### Should vendors use Super Intelligence or artificial intelligence in state government proposals?

Vendors should use artificial intelligence (AI) in state and local proposals unless a specific solicitation explicitly instructs offerors otherwise. State procurement officers evaluate bids against state statutory definitions and RFP compliance rubrics. Introducing the federal term can confuse evaluators who score against the state's own wording.

### How do state procurement codes define artificial intelligence?

State procurement codes define artificial intelligence through specific state statutes. For example, California Government Code Section 11546.45.5 defines AI as an engineered or machine-based system that infers from inputs how to generate outputs influencing physical or virtual environments. Colorado, Texas, Utah, and Maryland maintain similar functional statutory definitions.

### What happens if a vendor submits a proposal using Super Intelligence to a state agency?

Submitting a proposal using Super Intelligence to a state agency introduces several evaluation risks. Evaluators checking compliance matrices may have trouble matching the response to an RFP that asked for artificial intelligence solutions. It may also alarm evaluators regarding autonomous capabilities or lead to improper state AI disclosure filings.

### How does federal Super Intelligence differ from research superintelligence?

Federal Super Intelligence (two capitalized words, abbreviated as SI) is an administrative label for existing operational software meeting the functional standard in 15 U.S.C. 9401(3). Research superintelligence (one compound word, commonly abbreviated as ASI) is a hypothetical future system that would surpass human expert performance across all disciplines, which does not exist today.

### Does the November 28, 2026 federal definition deadline change state procurement rules?

No. Section 3(b) of Executive Order 14434 directs the Assistant to the President for Science and Technology to submit proposed legislative language for a federal definition of Super Intelligence to the President by November 28, 2026. This submission is an internal executive proposal, not an enacted law, and has no authority over state procurement codes.

### How should contractors handle past performance citations for state bids?

Contractors should cite past performance projects using the exact legal contract titles awarded. Section 2(b) of Executive Order 14434 does not require federal agencies to alter earlier contracts and grants; it does not apply to state contracting, where citing original titles is simply good practice. Modifying historical contract titles risks verification failures during evaluator reviews.

### Are state agencies required to update their AI inventories under the federal executive order?

No. State agencies maintain AI inventories and risk registries pursuant to state statutes and gubernatorial executive orders, such as directives in California, Texas, Maryland, and Washington. Federal Executive Order 14434 does not govern state agency reporting obligations or inventory frameworks.

## Sources

- [National Conference of State Legislatures: Artificial Intelligence 2024 Legislation](https://www.ncsl.org/technology-and-communication/artificial-intelligence-2024-legislation): In the 2024 legislative session, at least 45 states introduced artificial intelligence legislation, and 31 states adopted resolutions or enacted laws.
- [Cornell Law School: Legal Information Institute (15 U.S.C. 9401)](https://www.law.cornell.edu/uscode/text/15/9401): Under 15 U.S.C. 9401(3), artificial intelligence is defined as a machine-based system that can, for a given set of human-defined objectives, make predictions, recommendations or decisions influencing real or virtual environments.

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