On June 23, 2026, the Federal Acquisition Regulatory Council (“FAR Council”) issued proposed rules covering several parts of the Federal Acquisition Regulation (“FAR”).  The proposed rules mark the beginning of the long-awaited notice-and-comment phase of the Revolutionary FAR Overhaul (“RFO”).  This blog post, focusing on FAR Part 40, provides an overview of the proposed changes to the regulations and the associated contract clauses in FAR Part 52, including the inclusion of requirements around the handling of Controlled Unclassified Information (“CUI”).

Continue Reading Proposed FAR Part 40 Rule: Consolidation of Supply Chain Security and Information Security Requirements and New Changes to the Rules

On June 24, 2026, the General Services Administration (“GSA”) issued a Request for Information (“RFI”) seeking input on two proposals for promoting the purchase of American-made products on GSA Advantage, an online shopping and ordering system, which GSA advertises as providing access to thousands of contractors with millions of products and services.  Comments in response to the RFI are due by July 24, 2026.

Citing Executive Order 14392, which Covington previously covered in a client alert, the RFI reflects a broader push by the Trump administration to increase focus on domestic sourcing, including in federal procurement, and to ensure that “Made in America” representations are accurate.[1] As part of that effort, the Small Business Administration and GSA recently de-listed 22 product offerings from the GSA Advantage platform based on false Made in America representations, and President Trump declared that all federal agencies must buy American. Consistent with this policy direction, the RFI seeks input on ways to “make it easier for federal agencies to buy American-made products.”  This blog post focuses on the mechanics of GSA’s two proposals, the information sought by GSA in the RFI, and considerations for contractors.

Continue Reading GSA Issues RFI to Explore Ideas to Promote Domestic Procurement on GSA Advantage

On June 8, 2026, the Department of War (“DoW”) published its updated list of “Chinese military companies” operating in the United States (“1260H List”), as required by Section 1260H of the Fiscal Year (“FY”) 2021 National Defense Authorization Act (“NDAA”).  The updated list includes, among other companies, WuXi AppTec Co.…

Continue Reading What the Updated 1260H List Means for Biotechnology Procurement

On June 11, 2026, the Small Business Administration (“SBA”) published a proposed rule that would fundamentally alter how individuals qualify as “socially disadvantaged” under the 8(a) Business Development Program (“8(a) BD Program” or “Program”).  The comment period will be underway until July 13, 2026.

This five-page proposed rule states that it aims to align the 8(a) BD Program with constitutional and statutory requirements and remedy what it characterizes as the discriminatory effect of the program in the past.

Continue Reading SBA’s Proposed Update to the 8(a) Business Development Program: A New Approach to Social Disadvantage

On June 10, the Cybersecurity & Infrastructure Security Agency (CISA) released Binding Operational Directive (BOD) 26-04 on Prioritizing Security Updates Based on Risk and the accompanying Implementation Guidance. In releasing the BOD and Implementation Guidance, CISA noted that the documents are “part of CISA’s response to the current threat landscape” and the impact of AI on the volume of identified security vulnerabilities and compressed timelines for remediation as threat actors move quickly to exploit them. While the BOD and Implementation Guidance apply to agencies, CISA Acting Director Nick Anderson noted in the release of the documents that “CISA strongly encourages all partners to adopt similar actions in their vulnerability management policy.”

Continue Reading CISA Releases Binding Operational Directive on Prioritizing Security Updates Based on Risk

In January 2025, Covington issued a client alert noting that the National Defense Authorization Act (“NDAA”) for Fiscal Year (“FY”) 2025, which sets annual spending and policy for the Pentagon, introduced new China-related prohibitions on defense contractors and their consultants. The provision is finally set to take effect on…

Continue Reading New Restrictions on Defense Contractors Retaining Outside Consultants Set to Take Effect
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The Government Accountability Office recently issued a report on the Department of Defense’s civilian workforce reductions.  It offers a concrete record of how DoD has reduced staffing, where those reductions have occurred, and how the Department has assessed their effects. GAO’s report matters not only as a workforce-management review, but also as a practical resource for companies that depend on DoD procurement, oversight, audit, logistics, finance, and program-management functions. For defense contractors, the report suggests that delays, capacity constraints, and operational friction may persist—and that these issues are likely to receive increased congressional and internal DoD attention.

Continue Reading GAO Scrutinizes DoD Civilian Workforce Cuts: What the Report Means for Federal Contractors

On June 2, 2026, the White House issued an executive order titled “Promoting Advanced Artificial Intelligence Innovation and Security” (the “Order”).  The Order reflects the Administration’s stated policy of advancing U.S. leadership in artificial intelligence (“AI”) while addressing national security risks associated with increasingly capable AI systems.  To accomplish these policy goals, the Order outlines two approaches: (1) strengthening U.S. Government and private industry cyber defenses in response to “advanced AI,” and (2) developing voluntary benchmarking and review frameworks for secure development and release of “frontier” AI models.

Continue Reading White House Releases Executive Order on Advanced AI Innovation and Security

On May 29, 2026, the Office of Management and Budget (“OMB”), together with several other federal agencies, published a proposed rule that would fundamentally change many aspects of the regulations in 2 CFR Part 200 governing federal financial assistance awards, including grants, cooperative agreements, loans, and loan guarantees.  The comment period will be underway until July 13.

The 412 page proposed rule states that it is aimed at increasing transparency, accountability, and oversight in federal financial assistance.  It provides examples of “the types of wasteful spending” that it is meant to target, including recipients “potentially misus[ing] funds to provide services for illegal immigrants.”

While the proposed rule contains numerous changes, this post highlights some of the most notable.

Continue Reading Proposed Rule Would Fundamentally Impact Federal Grant and Financial Assistance Framework

Over one year ago, on May 2, 2025, the FAR Council took the first concrete step in the administration’s “Revolutionary FAR Overhaul” (“RFO”) initiative by issuing the initial round of rolling model deviation guidance—a deliberate move to translate reform of the Federal Acquisition Regulation (“FAR”) from an abstract policy goal into acquisition text.  That moment marked the beginning of a new implementation reality: rather than waiting for a single, comprehensive rulemaking, the government began operationalizing the overhaul in increments, part by part, through deviations.  Now, a year later, the question for contractors is no longer whether the overhaul is “coming,” but how it is being implemented across agencies and systems.  This is therefore a good time to take stock of where implementation stands, where friction is emerging, and what sophisticated contractors can do to stay ahead of the curve.  For additional information, our prior coverage of the RFO roll-out can be found here and here.

Continue Reading From Paper Reform to Practice: How Agencies Are Actually Implementing the Revolutionary FAR Overhaul