The past month has marked a series of announcements from the Department of War (the “Department”) emphasizing rapid deployment of artificial intelligence (“AI”) industry partnerships.  These announcements signal opportunities for not only the defense industrial base, but also nontraditional defense contractors focused on technology and data.

On January 9, 2026, the Department released two key memoranda: (1) Artificial Intelligence Strategy for the Department of War, setting out measurable pace-setting projects, barrier removal authorities, and mandated data access; and (2) Transforming the Defense Innovation Ecosystem to Accelerate Warfighting Advantage, which aims to unify the defense innovation ecosystem under the Under Secretary of War for Research & Engineering as Chief Technology Officer (“CTO”).  

Shortly after, on January 12, Secretary Hegseth delivered a speech, presenting an overhaul of the Department’s innovation and acquisition ecosystems.

The January 9 memoranda and Secretary Hegseth’s speech signal the Department’s intent to formalize a single, CTO-led innovation operating system designed to produce three outputs: next-generation technology, scalable products, and new ways of fighting—and to do it at “wartime speed,” with AI as the first major proving ground.

We provide additional details on each of these developments below.

1. January 12 Speech

In his January 12 remarks, Secretary Hegseth framed the ongoing strategic competition as a race in which the fastest innovator and iterator wins, rejecting the legacy “linear” model that moves from lab to program of record over many years.  The speech focused on reshaping the Pentagon’s approach to innovation, signaling to nontraditional defense contractors that barriers to rapid technological development and adoption will be removed.  Three elements of the speech are especially relevant to defense industry stakeholders:

  • A single CTO with decision authority.  The Secretary designated the Under Secretary of War for Research & Engineering as the Department’s “single CTO,” with commensurate decision authority and accountability for outcomes.  This change is part of the rethinking of the existing ecosystem in which entrepreneurs must “run endless laps” around the Department looking for the right office to engage. 
  • AI-first as a Department-wide execution standard.  The Secretary described an “AI acceleration strategy” built around pace-setting projects, execution-speed benchmarks, and a dedicated “barrier removal” team empowered to waive non-statutory requirements and escalate impediments to the rapid deployment of AI capabilities to the Deputy Secretary for resolution.
  • Private capital and industrial capacity as warfighting inputs.  The Secretary clarified that private capital, in partnership with the Office of Strategic Capital, will be integral to the Department’s operating model moving forward.

2. The AI Strategy Memorandum

Artificial Intelligence Strategy for the Department of War outlines the plan to create an “AI first” warfighting force by leveraging asymmetric advantages in compute, data, capital markets, and operational experience, while driving rapid experimentation with leading AI models.  This memorandum is the first major effort to execute the Pentagon’s vision for embracing a “test, fail, adjust” culture and pursuing innovation at “wartime speed.”

The memorandum outlines two primary initiatives: execution of seven “Pace-Setting Projects” (“PSPs”) that will demonstrate accelerated project execution and AI infrastructure development, and elimination of bureaucratic barriers to deeper AI integration.  A companion memorandum from Deputy Secretary of War Feinberg, Transforming Advana to Accelerate Artificial Intelligence and Enhance Auditability, underscores the view that data platform modernization and auditability are not back-office concerns, but rather prerequisites to deploying warfighting AI at scale.

Pace-Setting Projects

At the heart of the Department’s AI strategy are seven AI-focused PSPs across warfighting, intelligence, and enterprise missions:

  • Swarm Forge: a mechanism for iteratively discovering, testing, and scaling new ways of fighting with and against AI-enabled capabilities;
  • Agent Network: development of AI-enabled battle management and decision support;
  • Ender’s Foundry: AI-enabled simulation capabilities;
  • Open Arsenal: acceleration of weapons development from intelligence;
  • Project Grant: transformation of deterrence from static postures to dynamic pressure;
  • GenAI.mil: utilization of AI models by civilian and military personnel at all classification levels; and
  • Enterprise Agents: development of the playbook for rapid development and deployment of AI agents to transform enterprise workflows.

Each PSP will be led by a single program leader partnering with a sponsoring organization.  Progress will be reported on a monthly basis to the Deputy Secretary of War and Under Secretary of War for Research and Engineering. 

AI Enablers and Data Access

The memorandum tasks the Chief Digital and AI Office (“CDAO”) with operationalizing the new AI vision.  The CDAO will ensure that all “AI enablers,” defined as “infrastructure, data, models, policies, and talent,” developed through the PSPs are made available for other projects within the Department.  To facilitate this rollout, each military department, combatant command, and defense agency and field activity must identify within 30 days at least three priority projects to follow the PSPs in the AI-enabled, accelerated execution effort. 

In addition, the CDAO will enforce the “DoD Data Decrees.”  Under these decrees, military departments and components will deliver their federated data catalogues to the CDAO within 30 days of the memo.  The CDAO can direct release of any Department data to cleared users with valid purpose, such as developers and operators.  Any denial of CDAO requests must be justified to the Under Secretary of War for Research and Engineering within seven days.  The CDAO will also work with the Department’s Chief Information Officer to accelerate the delivery of AI capabilities, including by facilitating cross-domain data access and rapid Authorization to Operate (“ATO”) reciprocity.

AI Investments and Barriers

The memorandum discusses various approaches to increasing the adoption of AI within the Department.  These include investing “substantial resources” into datacenters used by the Department, as well as strategies to reduce the perceived barriers to the Department’s access to the latest AI models.  Also, planned new criteria for future model acquisitions will ensure the Department’s access to the latest AI model versions within 30 days of public release.  Further, the memo calls for reducing the time required to obtain ATOs for AI systems and to conduct evaluation and certification. 

Finally, the Department has clarified that it views “responsible AI” to mean that AI systems will be free from “ideological ‘tuning’” that interferes with their ability to provide responses and that there should be no usage policy constraints for those systems beyond those imposed by statute.  In support of this view, the Department intends to include new language in contracts—not yet publicly released—that will permit “any lawful use” of AI systems by the Department.  As stated by Secretary Hegseth in his January 12 speech, “responsible AI at the War Department means objectively truthful AI capabilities employed securely and within the laws governing the activities of the department.  We will not employ AI models that won’t allow you to fight wars.”

The policies set out in this memorandum signal the approaches the Department may take to implementing certain legal requirements relating to AI acquisition and use promulgated in the Fiscal Year 2026 National Defense Authorization Act (“FY26 NDAA”).  For example, Section 1513 of the FY26 NDAA requires development of a risk-based framework for implementing cybersecurity and physical security standards and best practices relating to certain AI systems.  Section 1533 requires a cross-functional team to develop frameworks for, among other things, compliance with ethical principles in the development and procurement of AI models.  The memorandum suggests that the Department may take an approach to compliance with these requirements that favors speed and fewer constraints on use. 

Transforming Advana to Accelerate AI and Enhance Auditability

Deputy Secretary of War Feinberg’s companion memorandum, Transforming Advana to Accelerate Artificial Intelligence and Enhance Auditability highlights that platform modernization is essential to AI adoption; Advana, the Department’s aging enterprise data and analytics platform, will be restructured into a centralized War Data Platform capable of standardized data access for “agentic AI and other applications” and a dedicated financial management track for achieving clean audit results.

3. The Transformation of Defense Innovation Memorandum

The Transforming the Defense Innovation Ecosystem to Accelerate Warfighting Advantage memo seeks to unify the innovation ecosystem under a single CTO, to facilitate three outcomes: (1) technology innovation, which aims to focus on highly differentiated, often classified, defense‑unique breakthroughs; (2) product innovation, which emphasizes commercial and dual‑use technology adoption from American entrepreneurs and capital markets; and (3) operational capability innovation, which includes focusing on integrating technology with new warfighting tactics to create an asymmetric advantage.

Key execution features include:

  • Governance simplification.  The memorandum replaces the Defense Innovation Steering Group, the Defense Innovation Working Group, and the CTO Council with a CTO Action Group, empowered to “make decisions, clear bureaucratic blockers, [and] hold leaders accountable.”  Designed as a small, decisive body, the Action Group will support the CTO with rapid issue resolution, portfolio alignment, and accelerated delivery of innovations to warfighters.
  • Defense Innovation Unit (“DIU”) and the Strategic Capabilities Office (“SCO”) are elevated and stabilized.  With DIU and SCO designated as Department Field Activities, the memorandum reinforces lean governance and clarifies DIU’s role to lead commercial product adoption/transition and SCO’s role for cross-Military Service operational capability innovation.
  • Military Service-level accountability and “last mile” funding.  Beginning in FY 2028, each portfolio acquisition executive must establish, manage, and actively use an Innovation Insertion Increment to fund rapid capability and modular upgrades, which are intended to overcome “last mile” barriers to fielding innovation.  Secretaries of the military departments must also brief the CTO on how they will organize their innovation communities around the framework outlined in this memorandum.
  • Two clear engagement channels for industry.  The Mission Engineering and Integration Activity (“MEIA”), discussed in our prior blog post here, will communicate operational, problem-driven demand signals to industry, while DIU will focus on product-driven engagement to help program offices adopt capabilities industry has already built.

4. Key Takeaways

These developments focused on innovation and private partnership pose significant opportunities for the defense industrial base and nontraditional data-focused and technology companies alike.

Following the release of these memoranda, Cameron Stanley, the newly-appointed Chief Digital and AI Officer, called on the private sector to partner with the Pentagon on AI efforts, encouraging active use of flexible contracting vehicles, such as Other Transaction Authority, or OTAs, to reach industry partners, including nontraditional partners, with innovative approaches to solving problems.  As we have seen in the past year, the current administration has demonstrated an unprecedented degree of flexibility in engaging with industry on areas of critical importance, and we expect that to continue in the AI field. 

For companies already doing business with the Pentagon, these memoranda foreshadow a market in which cycle time, integration readiness, data discipline, and demonstrable adoption paths will matter as much as past performance and legacy program history.  For companies seeking to break into defense contracting, these memoranda signal the vision to make defense contracting easier to navigate—by consolidating the AI procurement structure, sending clearer demand signals, allowing faster decision-making, and strengthening the internal mandate to adopt commercial capabilities at scale—as long as contractors can meet the Department’s requirements for data-driven, AI-enabled, and iterative systems.

In all cases, companies will likely need to ensure that they are providing the Department with new models on a timely basis and that those models align with the Department’s views on model outputs. 

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Photo of Nooree Lee Nooree Lee

Nooree Lee represents government contractors in all aspects of the procurement process and focuses his practice on the regulatory aspects of M&A activity, procurements involving emerging technologies, and international contracting matters.

Nooree advises government contractors and financial investors regarding the regulatory aspects of…

Nooree Lee represents government contractors in all aspects of the procurement process and focuses his practice on the regulatory aspects of M&A activity, procurements involving emerging technologies, and international contracting matters.

Nooree advises government contractors and financial investors regarding the regulatory aspects of corporate transactions and restructurings and – more recently – on equity investments by the U.S. government. His experience includes preparing businesses for sale, negotiating deal documents, coordinating large-scale diligence processes, and navigating pre- and post-closing regulatory approvals and integration. He has advised on 40+ M&A deals involving government contractors totaling over $30 billion in combined value. This includes Veritas Capital’s acquisition of Cubic Corp. for $2.8 billion; the acquisition of Perspecta Inc. by Veritas Capital portfolio company Peraton for $7.1 billion; and Cameco Corporation’s strategic partnership with Brookfield Renewable Partners to acquire Westinghouse Electric Company for $7.8+ billion.

Nooree also counsels clients focused on delivering emerging technologies to public sector customers. Over the past several years, his practice has expanded to include advising on the intersection of government procurement and artificial intelligence. Nooree counsels clients on the negotiation of AI-focused procurement and non-procurement agreements with the U.S. government and the rollout of federal and state-level regulations impacting the procurement and deployment of AI solutions on behalf of government agencies.

Nooree also counsels clients navigating the Foreign Military Sales (FMS) program and Foreign Military Financing (FMF) arrangements. Nooree has advised both U.S. and ex-U.S. companies in connection with defense sales to numerous foreign defense ministries, including those of Australia, Israel, Singapore, South Korea, and Taiwan.

In addition to his government contracts advising, Nooree assists clients with navigating federal Freedom of Information Act and state public records requirements, including objecting to a government agency’s proposed release of a company’s proprietary information.

Nooree maintains an active pro bono practice focusing on appeals of denied industrial security clearance applications and public housing and housing discrimination matters. In addition to his work within the firm, Nooree is an active member of the American Bar Association’s Section of Public Contract Law and has served on the Section Council and the Section’s Diversity Committee. He also served as the firm’s Fellow for the Leadership Council on Legal Diversity program in 2023.

Photo of Stephanie Barna Stephanie Barna

Stephanie Barna draws on over three decades of U.S. military and government service to provide advisory and advocacy support and counseling to clients facing policy and political challenges in the aerospace and defense sectors.

Prior to joining the firm, Stephanie was a senior…

Stephanie Barna draws on over three decades of U.S. military and government service to provide advisory and advocacy support and counseling to clients facing policy and political challenges in the aerospace and defense sectors.

Prior to joining the firm, Stephanie was a senior leader on Capitol Hill and in the U.S. Department of Defense (DoD). Most recently, she was General Counsel of the Senate Armed Services Committee, where she was responsible for the annual $740 billion National Defense Authorization Act (NDAA). Additionally, she managed the Senate confirmation of three- and four-star military officers and civilians nominated by the President for appointment to senior political positions in DoD and the Department of Energy’s national security nuclear enterprise, and was the Committee’s lead for investigations.

Previously, as a senior executive in the Office of the Army General Counsel, Stephanie served as a legal advisor to three Army Secretaries. In 2014, Secretary of Defense Chuck Hagel appointed her to be the Principal Deputy Assistant Secretary of Defense for Manpower and Reserve Affairs. In that role, she was a principal advisor to the Secretary of Defense on all matters relating to civilian and military personnel, reserve integration, military community and family policy, and Total Force manpower and resources. Stephanie was later appointed by Secretary of Defense Jim Mattis to perform the duties of the Under Secretary of Defense for Personnel and Readiness, responsible for programs and funding of more than $35 billion.

Stephanie was also previously the Deputy General Counsel for Operations and Personnel in the Office of the Army General Counsel. She led a team of senior lawyers in resolving the full spectrum of issues arising from Army wartime operations and the life cycle of Army military and civilian personnel. Stephanie was also a personal advisor to the Army Secretary on his institutional reorganization and business transformation initiatives and acted for the Secretary in investigating irregularities in fielding of the Multiple Launch Rocket System and classified contracts. She also played a key role in a number of high-profile personnel investigations, including the WikiLeaks breach. Prior to her appointment as Deputy, she was Associate Deputy General Counsel (Operations and Personnel) and Acting Deputy General Counsel.

Stephanie is a retired Colonel in the U.S. Army and served in the U.S. Army Judge Advocate General’s Corps as an Assistant to the General Counsel, Office of the Army General Counsel; Deputy Staff Judge Advocate, U.S. Army Special Forces Command (Airborne); Special Assistant to the Assistant Secretary of the Army (Manpower & Reserve Affairs); and General Law Attorney, Administrative Law Division.

Stephanie was selected by the National Academy of Public Administration for inclusion in its 2022 Class of Academy Fellows, in recognition of her years of public administration service and expertise.

Photo of Robert Huffman Robert Huffman

Bob Huffman counsels government contractors on emerging technology issues, including artificial intelligence (AI), cybersecurity, and software supply chain security, that are currently affecting federal and state procurement. His areas of expertise include the Department of Defense (DOD) and other agency acquisition regulations governing…

Bob Huffman counsels government contractors on emerging technology issues, including artificial intelligence (AI), cybersecurity, and software supply chain security, that are currently affecting federal and state procurement. His areas of expertise include the Department of Defense (DOD) and other agency acquisition regulations governing information security and the reporting of cyber incidents, the Cybersecurity Maturity Model Certification (CMMC) program, the requirements for secure software development self-attestations and bills of materials (SBOMs) emanating from the May 2021 Executive Order on Cybersecurity, and the various requirements for responsible AI procurement, safety, and testing currently being implemented under President Trump’s AI Executive Order. 

Bob also represents contractors in False Claims Act (FCA) litigation and investigations involving cybersecurity and other technology compliance issues, as well more traditional government contracting costs, quality, and regulatory compliance issues. These investigations include significant parallel civil/criminal proceedings growing out of the Department of Justice’s Cyber Fraud Initiative. They also include investigations resulting from False Claims Act qui tam lawsuits and other enforcement proceedings. Bob has represented clients in over a dozen FCA qui tam suits.

Bob also regularly counsels clients on government contracting supply chain compliance issues, including those arising under the Buy American Act/Trade Agreements Act and Section 889 of the FY2019 National Defense Authorization Act. In addition, Bob advises government contractors on rules relating to IP, including government patent rights, technical data rights, rights in computer software, and the rules applicable to IP in the acquisition of commercial products, services, and software. He focuses this aspect of his practice on the overlap of these traditional government contracts IP rules with the IP issues associated with the acquisition of AI services and the data needed to train the large learning models on which those services are based. 

Bob is ranked by Chambers USA for his work in government contracts and he writes extensively in the areas of procurement-related AI, cybersecurity, software security, and supply chain regulation. He also teaches a course at Georgetown Law School that focuses on the technology, supply chain, and national security issues associated with energy and climate change.

Photo of Ryan Burnette Ryan Burnette

Ryan Burnette is a government contracts and technology-focused lawyer that advises on federal contracting compliance requirements and on government and internal investigations that stem from these obligations. Ryan has particular experience with defense and intelligence contracting, as well as with cybersecurity, supply chain…

Ryan Burnette is a government contracts and technology-focused lawyer that advises on federal contracting compliance requirements and on government and internal investigations that stem from these obligations. Ryan has particular experience with defense and intelligence contracting, as well as with cybersecurity, supply chain, artificial intelligence, and software development requirements.

Ryan also advises on Federal Acquisition Regulation (FAR) and Defense Federal Acquisition Regulation Supplement (DFARS) compliance, public policy matters, agency disputes, and government cost accounting, drawing on his prior experience in providing overall direction for the federal contracting system to offer insight on the practical implications of regulations. He has assisted industry clients with the resolution of complex civil and criminal investigations by the Department of Justice, and he regularly speaks and writes on government contracts, cybersecurity, national security, and emerging technology topics.

Ryan is especially experienced with:

Government cybersecurity standards, including the Federal Risk and Authorization Management Program (FedRAMP); DFARS 252.204-7012, DFARS 252.204-7020, and other agency cybersecurity requirements; National Institute of Standards and Technology (NIST) publications, such as NIST SP 800-171; and the Cybersecurity Maturity Model Certification (CMMC) program.
Software and artificial intelligence (AI) requirements, including federal secure software development frameworks and software security attestations; software bill of materials requirements; and current and forthcoming AI data disclosure, validation, and configuration requirements, including unique requirements that are applicable to the use of large language models (LLMs) and dual use foundation models.
Supply chain requirements, including Section 889 of the FY19 National Defense Authorization Act; restrictions on covered semiconductors and printed circuit boards; Information and Communications Technology and Services (ICTS) restrictions; and federal exclusionary authorities, such as matters relating to the Federal Acquisition Security Council (FASC).
Information handling, marking, and dissemination requirements, including those relating to Covered Defense Information (CDI) and Controlled Unclassified Information (CUI).
Federal Cost Accounting Standards and FAR Part 31 allocation and reimbursement requirements.

Prior to joining Covington, Ryan served in the Office of Federal Procurement Policy in the Executive Office of the President, where he focused on the development and implementation of government-wide contracting regulations and administrative actions affecting more than $400 billion dollars’ worth of goods and services each year.  While in government, Ryan helped develop several contracting-related Executive Orders, and worked with White House and agency officials on regulatory and policy matters affecting contractor disclosure and agency responsibility determinations, labor and employment issues, IT contracting, commercial item acquisitions, performance contracting, schedule contracting and interagency acquisitions, competition requirements, and suspension and debarment, among others.  Additionally, Ryan was selected to serve on a core team that led reform of security processes affecting federal background investigations for cleared federal employees and contractors in the wake of significant issues affecting the program.  These efforts resulted in the establishment of a semi-autonomous U.S. Government agency to conduct and manage background investigations.

Photo of Krissy Chapman Krissy Chapman

Kristen “Krissy” Chapman is an associate in the firm’s Washington, DC office. She represents and advises clients on a range of cybersecurity, data privacy, and government contracts issues, including cyber and data security incident response and preparedness, cross-border privacy law, government and internal…

Kristen “Krissy” Chapman is an associate in the firm’s Washington, DC office. She represents and advises clients on a range of cybersecurity, data privacy, and government contracts issues, including cyber and data security incident response and preparedness, cross-border privacy law, government and internal investigations, and regulatory compliance.

Prior to joining the firm, Krissy served as a consultant in both the private and public sectors, advising clients across a range of industries, including transportation and infrastructure, life sciences and healthcare, and national security.

Photo of Eunsun Cho Eunsun Cho

Eunsun Cho is an associate in the Government Contracts Practice Group. She assists clients on a range of regulatory and compliance issues.

Eunsun also maintains an active pro bono practice.