Frontier AI capabilities are concentrated among a small number of private firms headquartered in the United States and China. For states which neither develop nor host leading models, this concentration creates a dependence on foreign AI providers whose capabilities they often cannot independently evaluate and whose technology may be constrained by the laws of the provider’s home jurisdiction.
Public procurement offers ‘AI middle powers’ one mechanism for governing these dependencies. These are states with significant economic, diplomatic, security or regulatory capabilities that nevertheless depend technologically on foreign frontier AI firms. The report finds that three categories of risk fall disproportionately on state buyers in AI middle powers: vendor lock-in and the threat of service withdrawal, limited visibility into frontier AI development, and data sovereignty and information-security risks.
To mitigate these risks, the report develops a framework of procurement obligations that governments could seek to negotiate with AI providers. These include model access for evaluation, information sharing, funding for reliability research, state-of-the-art risk management requirements, termination and exit provisions, and measures to support domestic and allied capability.
The analysis finds that public procurement is a useful but bounded mechanism for governing frontier AI. Governments are not yet major customers of frontier AI firms, and leading developers may be able to forego government contracts rather than accept costly requirements. Procurement contracts with foreign providers may also remain subordinate to the national-security laws of a vendor’s home state, and state buyers can face persistent information asymmetries when negotiating with leading technology companies. At the same time, government demand for frontier AI is growing, and public-sector contracts offer firms more than revenue alone. They provide financial predictability and a degree of prestige and regulatory validation, making governments strategically important customers even if they are not yet indispensable to firms’ business models.
The central recommendation is that AI middle powers should assess whether collective coordination on procurement requirements can strengthen their bargaining position and state capacity.
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