Over the last month, we have issued multiple client alerts outlining developments related to the Chinese military company covered lobbyist prohibition enacted by Section 851 of the National Defense Authorization Act (“NDAA”) for Fiscal Year (“FY”) 2025, codified at 10 U.S.C. § 4663. This is a follow-up to
Continue Reading Defense Department Publishes Guidance Page Concerning Restrictions on Defense Contractors Retaining Outside Consultants
Regulations Issued for New Restrictions on Defense Contractors Retaining Outside Consultants
The Chinese military company covered lobbyist prohibition enacted by Section 851 of the National Defense Authorization Act (“NDAA”) for Fiscal Year (“FY”) 2025, codified at 10 U.S.C. § 4663, took effect on June 30, 2026. Just before that date, the Department of Defense took steps to implement the
Continue Reading Regulations Issued for New Restrictions on Defense Contractors Retaining Outside ConsultantsNew Restrictions on Defense Contractors Retaining Outside Consultants Set to Take Effect
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 EffectFrom Paper Reform to Practice: How Agencies Are Actually Implementing the Revolutionary FAR Overhaul
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 OverhaulThe Pentagon’s New Sub-Unified Command for Autonomous Warfare: What It Means and Where It Might Land
On April 29, 2026, Secretary of War Pete Hegseth told the House Armed Services Committee that the Pentagon will “shortly announce a sub-unified command of autonomous warfare.” The announcement came as the Department of War (DoW) unveiled its fiscal year (FY) 2027 budget request, which proposes approximately $54 billion for the Defense Autonomous Warfare Group (DAWG)—a dramatic increase from the roughly $226 million the DAWG received previously. When all DoW drone and counter-drone related budget lines in the FY 2027 budget request are aggregated, the total approaches $74 billion—an amount Pentagon officials have described as the largest investment in such technologies in U.S. history.
Beyond the headline numbers, Secretary Hegseth’s reference to a “sub-unified command” is institutionally significant. It raises fundamental questions about how the DoW intends to organize autonomous warfare inside the joint force and warrants a closer look at what a sub-unified command actually is.
Continue Reading The Pentagon’s New Sub-Unified Command for Autonomous Warfare: What It Means and Where It Might LandSBIR/STTR Is Back and the Department of War Is Wasting No Time
On April 20, 2026, one week after President Trump signed the Small Business Innovation and Economic Security Act (Public Law 119-83) into law, the Department of War (“DoW”) issued a press release announcing that it was “immediately advancing” a “redesigned and more focused initiative to accelerate the delivery of advanced capabilities to the warfighter.” As we covered last month, the Small Business Innovation and Economic Security Act reauthorizes the Small Business Innovation Research and Small Business Technology Transfer (“SBIR/STTR”) programs through September 30, 2031, ending a nearly six-month lapse that froze new SBIR/STTR solicitations and awards across federal agencies.
The DoW’s announcement signals that the Department intends to be the first mover in implementing the reauthorized SBIR/STTR programs. The announcement also introduces a new initiative, the Accelerated Research for Transition (“ART”) Program, that warrants close attention from the defense small business community.
Continue Reading SBIR/STTR Is Back and the Department of War Is Wasting No Time“Adjusting Certain Delegations”: New Executive Order Aims to Streamline and Clarify Delegated Authorities Under the Defense Production Act
On March 13, 2026, President Trump issued an Executive Order (EO) titled “Adjusting Certain Delegations Under the Defense Production Act.” As we have covered in prior blog posts, the Defense Production Act (DPA) has traditionally been considered the primary federal means to manage and support defense production.
Continue Reading “Adjusting Certain Delegations”: New Executive Order Aims to Streamline and Clarify Delegated Authorities Under the Defense Production ActDOE Announces Funding Opportunity for Domestic Critical Materials Processing, Recycling, and Manufacturing
On March 13, 2026, the Department of Energy issued a Notice of Funding Opportunity (NOFO) for projects supporting the development of domestic processing, manufacturing, and recycling capabilities for battery materials. With $500 million in total available funding, the NOFO solicits proposals in three topic areas: (1) domestic critical minerals processing from raw feedstocks, (2) domestic critical minerals recycling, and (3) domestic battery materials and component manufacturing. Letters of intent are due March 27, 2026, and full applications are due April 24, 2026.
Continue Reading DOE Announces Funding Opportunity for Domestic Critical Materials Processing, Recycling, and ManufacturingIs Congress Finally Reauthorizing SBIR/STTR—and What’s Changing?
On March 3, 2026, the Senate took a major step toward reauthorizing the Small Business Innovation Research/Small Business Technology Transfer (“SBIR/STTR”) programs, by passing the Small Business Innovation and Economic Security Act (S. 3971). Known collectively as “America’s Seed Fund,” the SBIR and STTR programs provide small businesses with early-stage
Continue Reading Is Congress Finally Reauthorizing SBIR/STTR—and What’s Changing?Defense Industrial Base Consortium Issues New Critical Minerals Request for Project Proposals
Introduction
On February 27, 2026, the Defense Industrial Base Consortium (DIBC) issued a new Request for Project Proposals (RPP) focused on Strategic and Critical Materials. Phase 1 submissions are due March 20, 2026, at 5:00 p.m. (Eastern).
This solicitation represents the second DIBC RPP targeting critical minerals since the issuance of Executive Order (EO) 14241, “Immediate Measures to Increase American Mineral Production.” The EO directed federal agencies to expand domestic access to critical minerals and reduce reliance on foreign supply chains.
Continue Reading Defense Industrial Base Consortium Issues New Critical Minerals Request for Project Proposals