What the CAIO Actually Controls and Where Your Deal Really Lives

The title keeps showing up in your accounts. Chief AI Officer. It looks like a CIO or CISO: a C-suite role with a budget line, procurement authority, and decision rights over the technology domain in the name. The resemblance is misleading in a specific way that will cost you time if you don't correct for it.

OMB Memorandum M-25-21 defines the CAIO as the "senior advisor on AI to the head of the agency." Advisor. The role carries accountability for AI outcomes at the agency. It does not carry, by default, a procurement budget for AI tools. The CAIO is the person who has to answer when something goes wrong. The person who signs your purchase order is usually someone else.

The decision-making surface for AI tool adoption is forming one layer below the CAIO, in the governance boards that M-25-21 required CFO Act agencies to stand up within 90 days. Cross-functional bodies with representation from IT, cybersecurity, data, privacy, and budget. These boards review AI use cases, set risk thresholds, and gate what reaches production. If you want to know where your deal lives or dies, you need to map these boards.

You already know how. The motion is buying-center analysis. But the analogy breaks in a place that matters, and the break point is exactly where most sellers will aim wrong.

The buying center you can see

GSA published the most detailed public model of how an agency operationalizes AI governance. Even if GSA isn't your account, the structure is worth studying because it shows the mechanics that other agencies are building toward.

GSA runs two bodies. The EDGE Board (their AI Governance Board) is chaired by the Deputy Administrator and co-chaired by the CAIO. It reports to the GSA Administrator. It sets risk tolerance, funds data priorities, and reviews all safety-impacting and rights-impacting AI use cases. Below it sits the AI Oversight Committee, the cross-functional working group that reviews every AI request, assesses risk, and enforces privacy and security controls. GSA's March 2026 directive (CIO 2185.1C) also calls this the AI Safety Team.

One operational detail worth holding onto: GSA sorts use cases into four categories. Familiarization, pre-acquisition, R&D, and production. Only R&D and production-intent requests get full AI Safety Team review. The lighter categories move through a lighter process. That differential threshold tells you where friction concentrates. If your tool is in the "let people try it" phase, the governance board may not be your bottleneck yet. If you're pushing toward production, the full cross-functional review is your gate.

Map this the way you'd map any buying center. The Deputy Administrator is the economic buyer. The CAIO is the technical influencer and process owner. The CISO, CPO, and Data Governance Leads are compliance gatekeepers who jointly review all production systems. Program offices are user buyers who originate and sponsor use cases. Each has a different question about your product. Each can slow or stop the deal at a different stage.

So far, your buying-center instinct is serving you well.

Where the analogy stops bearing weight

In a traditional buying center, the C-suite title is a reasonable proxy for budget authority. The CIO controls IT spend. The CISO controls security tooling budget. Title maps to checkbook.

The CAIO title doesn't work that way. At GSA, the CAIO (Zach Whitman, who also holds the CDO and Chief Data Scientist titles) chairs the governance bodies, coordinates with the OCIO on authorization processes, and oversees the AI use case inventory. He does not, based on any published authority, hold direct procurement budget for AI tools. His public framing consistently positions the role as an enabling and coordinating function. The EDGE Board sets and funds priorities. The CAIO facilitates.

Your buying-center instinct has been useful up to this point. Here's where it starts to mislead you. The CAIO has the profile of an economic buyer but functions closer to a coach or technical evaluator. They shape the criteria, run the process, and can champion or quietly kill your deal. The budget authority sits at the board level or higher.

The dual-role pattern makes this even more variable across agencies. At GSA, the CAIO is also the CDO, which gives the role data governance authority alongside AI strategy. At Commerce, the CAIO is also the CIO, which means the role inherits IT procurement authority. At USDA, the CAIO is also the CDO.

GSA's structure is illustrative, not idiosyncratic

This governance pattern isn't a GSA quirk. It's worth establishing that before we get to discovery territory.

Ogletree's December 2025 analysis of published agency AI strategy plans found convergence across agencies on four goals: scalable AI infrastructure, quality data, an AI-ready workforce, and proportional risk governance. Ogletree is a labor and employment law firm that tracks federal AI policy for its government contractor clients, so their lens is compliance-oriented. But the convergence finding is useful here. That fourth goal, proportional risk governance, is the governance board mandate showing up as a shared priority across CFO Act agencies. As of late 2024, 94% of CFO Act agencies had publicly disclosed their CAIOs. GSA built the most visible governance structure. They didn't invent the pattern.

DHS tells a similar structural story. Their AI Governance Board includes representation from IT, cybersecurity, data, privacy, civil rights, civil liberties, procurement, budget, legal counsel, and program evaluation. The DHS CAIO, per Directive 139-08, provides "leadership and accountability" for AI use. Again: accountability, not procurement sign-off.

One detail worth noting because it illustrates the gap between structure and operation: DHS's governance board held its first meeting in July 2025 as a paper-only exercise. A procedural filing to meet the M-25-21 deadline. The compliance plan followed two months later. Agency strategy documents are aspirational. They describe what the agency intends, not necessarily what it has achieved. And given the workforce disruptions across federal agencies since 2024, including funding cuts and staffing shortages that have already delayed programs like FedRAMP 20x, the question of whether a governance board is staffed and meeting regularly is not one you should take on faith. When your buyer describes their governance board, ask when it last met and what it decided. The answer tells you whether you're selling into a functioning review process or a compliance artifact that hasn't been tested yet.

The identity seam inside the governance structure

Every AI use case that clears a governance board still has to answer access questions before it reaches production. Who is authorized to use this tool? What data can it reach? How is access reviewed over time? How does it get revoked?

GSA's compliance plan makes the connection explicit: the CAIO "coordinates within the OCIO so that existing processes like Authorizations to Operate, FITARA reviews, and new software [acquisition] are aligned with AI governance." The CAIO doesn't run the ATO. The OCIO does. But the governance board's approval generates requirements that feed into the ATO process. And AI enhancements to existing IT tools trigger re-authorization within the agency's security framework. Add an AI feature to an already-authorized tool, and the access review starts over.

For your account map, this collapses what looks like two separate gates into one audience. The governance board decides whether a use case can proceed. The ATO process decides whether the system's access controls are adequate. The CISO, CPO, and Data Governance Leads sit on both sides of that boundary. They review the use case in the governance board, then review the access architecture in the ATO process. You are selling to the same person wearing two different hats, and your product needs to make sense to both hats simultaneously. If your governance-board pitch doesn't hold up under ATO scrutiny from the same reviewer, you've created your own objection.

DHS has pushed further than most by committing to continuous authorization of IT systems, shifting from point-in-time security snapshots to ongoing validation. Whether DHS has operationalized this commitment is an open question; the intent is published, the implementation evidence is not. But the direction aligns with FedRAMP 20x's move toward persistent validation and expanded identity assurance controls in the Moderate pilot. If your product connects to the access review lifecycle, the policy tailwind is real.

GSA's own AI deployments rely on "multi-tenant cloud services with built-in encryption, identity management, and logging." Identity management is named explicitly as a component of AI deployment infrastructure. The governance board sets the policy. The identity architecture enforces it. Your discovery should aim at the handoff between those two.

What to ask on Tuesday

The governance board structure gives you specific discovery territory. You already know the buyer is using AI. The productive question is how the agency's governance process handles the access decisions that every approved use case requires.

On the handoff from governance to operations: "When your governance board approves an AI use case for production, what happens next? Who decides what data it can access and who can use it?" This tests whether the board's approval connects to the ATO process or whether there's a manual, ad hoc gap between them. If the buyer pauses, you've found the seam.

On access review cadence: "How often do you review access for AI tools already in production?" GSA requires annual re-registration and continuous monitoring. Most agencies haven't published their cadence. The answer tells you whether the buyer has a lifecycle process or a one-time provisioning event that nobody revisits.

On re-authorization triggers: "When an existing tool adds AI capabilities, does that trigger a new access review?" GSA's directive says yes. If your buyer's agency hasn't decided, that's a conversation you can help them have. Helping them have it is how you become the person they call back.

On revocation: "If you needed to shut down access to an AI tool tomorrow, how long would that take?" A Kiteworks forecast report claims sixty percent of organizations can't quickly terminate a misbehaving AI agent. That's a vendor-published number based on enterprise-general data, not government-specific research, so hold it loosely. But the question it points toward is sound. Most agencies haven't published revocation procedures for AI tools, and the absence of a published answer is itself a finding.

These aren't scripts. They're territories. Adapt them to your account, your relationship, and what you already know about the buyer's maturity.

Revise the account map

Put the governance board on your map the way you'd put a buying center on it. Identify the chair (often a deputy secretary or deputy administrator, not the CAIO). Identify the cross-functional members, especially the CISO and CPO who sit at the intersection of governance approval and access architecture. Identify the program offices that originate use cases, because they're the ones who feel the pain of manual access provisioning most acutely.

Then note the CAIO's actual role: coordinator, facilitator, accountability holder. Your best internal champion if your product makes the governance process work better, and the person most likely to shape evaluation criteria. Unlikely to be the person who writes the check.

The CAIO AI Council that Federal CIO Gregory Barbaccia described this week at the AI & Data Exchange conference is generating shared templates and best practices across CFO Act agencies. As Barbaccia put it:

The governance structures are converging. The account map you build for one agency will increasingly resemble the account map at the next one. Learn the pattern once. Apply it twenty-four times.

The CAIO title is new. The thing underneath it is a cross-functional governance body with distributed authority, a compliance mandate, and an access architecture problem that nobody has fully solved yet. You've sold into that structure before. You just didn't call it a governance board, and it didn't have an AI label on it. The selling motion is the same. The power map has shifted. Adjust accordingly.