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 ConsultantsCongress Considers Further FOCI Reforms as DoW Moves to Expand Disclosure Requirements for Unclassified Defense Contractors
The public comment period for the long-awaited Defense Federal Acquisition Regulation Supplement (“DFARS”) proposed rule, “Mitigating Risks Related to Foreign Ownership, Control, or Influence” (the “proposed DFARS FOCI rule”), closed on July 6, 2026. But recent activity in Congress suggests that the Department of War (“DoW”)’s proposed rule may be only one part of a broader effort to expand the government’s visibility into and mitigation of foreign ownership, control, or influence (“FOCI”) risks across the defense industrial base. Taken together, the proposed DFARS FOCI rule and pending provisions in the House and Senate versions of the Fiscal Year (“FY”) 2027 National Defense Authorization Act (“NDAA”) could substantially extend FOCI-related scrutiny beyond the traditional universe of cleared contractors performing classified work.
Continue Reading Congress Considers Further FOCI Reforms as DoW Moves to Expand Disclosure Requirements for Unclassified Defense ContractorsGSA Issues RFI to Explore Ideas to Promote Domestic Procurement on GSA Advantage
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 AdvantageNew 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 EffectGAO Scrutinizes DoD Civilian Workforce Cuts: What the Report Means for Federal Contractors
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 ContractorsFrom 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 TimeRevolutionary FAR Overhaul Incorporates New “Addressing DEI Discrimination” Executive Order Provisions
As we previously covered, on March 26, 2026, President Trump issued Executive Order (EO) 14398, “Addressing DEI Discrimination by Federal Contractors,” to address “racially discriminatory DEI activities” in federal contracting. Among other things, EO 14398 directed the FAR Council to issue deviation and interim guidance within 60 days to implement the new contract clause set forth in Section 3 of the EO. On April 20, the FAR Council issued those model deviations[1] ahead of schedule, along with corresponding implementation guidance.
Continue Reading Revolutionary FAR Overhaul Incorporates New “Addressing DEI Discrimination” Executive Order Provisions