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
The 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 ProvisionsNew “Addressing DEI Discrimination” Executive Order: What Federal Contractors Need to Know
On March 26, 2026, President Trump issued an Executive Order (EO) titled “Addressing DEI Discrimination by Federal Contractors,” the latest in a series of Executive Orders and related actions by the Administration targeting what it views as unlawful Diversity, Equity, and Inclusion (“DEI”) related practices. Most notable about
Continue Reading New “Addressing DEI Discrimination” Executive Order: What Federal Contractors Need to KnowIs 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?Contractors Should Not Overlook the Administration’s Call to Action on Commerciality
Last week, Secretary Hegseth delivered a speech at the National War College introducing transformations to the defense procurement process. Among them, the Secretary discussed awarding companies bigger and longer contracts for proven systems; removing “excessive and burdensome” requirements (for example, acquisition rules, accounting standards, and testing oversight); and empowering program leaders with authority to direct program outcomes, move money, and adjust priorities. Overall, the speech outlined a vision for a more agile defense procurement process that leans heavily on practices already proven and featured in the commercial sector.
Continue Reading Contractors Should Not Overlook the Administration’s Call to Action on CommercialityMassachusetts Seeks to Expand Defense Footprint with Nearly $47 Million in New Projects
Massachusetts aims to be the “cornerstone of the defense industry,” with Governor Maura Healey announcing nearly $47 million in government funding for defense-related projects. Last year, the Department of Defense ranked Massachusetts ninth out of the top ten states in total Defense spending in FY2023, and the state is aiming
Continue Reading Massachusetts Seeks to Expand Defense Footprint with Nearly $47 Million in New ProjectsJCIDS, Rewired: What DoD’s New Requirements Memo Means
On August 20, 2025, the Department of Defense (“DoD”) issued a sweeping memo that tears up and rebuilds the way the military decides what new weapons and systems it needs. The Military Services appear to be wasting no time translating the memo into action. Acquisition leaders at last week’s Association of the United States Army conference emphasized that “Transforming in Contact” will serve as the framework for redefining requirements and reprioritizing programs—demonstrating that reform is already underway. For its part, the Air Force has begun reorganizing its A5/7 directorate to assume greater responsibility for requirements generation, while the Chief of Space Operations has publicly outlined the Space Force path to driving requirements and resourcing.
This “requirements process” is the first step in acquisition—it defines the problem and tells the rest of the system what to buy, build, or develop. Change the requirements process and you change the entire defense marketplace. For decades, DoD has used a system called the Joint Capabilities Integration and Development System (“JCIDS”). JCIDS was paperwork-heavy and checklist-driven: the Military Services (Army, Navy, Air Force, Marine Corps, Space Force) would write lengthy justifications for new programs, and those proposals would wind their way through layers of approval at the Joint Staff in the Pentagon. Critics said JCIDS was too slow and too rigid for modern threats, especially as China and other adversaries innovate quickly.
The August 20 memo blows up that model. In its place, DoD is putting forward a problem-focused approach that aims to:
- Define the biggest operational challenges first(not just collect Military Service wish lists)
- Tie priorities to moneyso “important” projects actually get funded
- Bring industry into the process earlierthrough experiments, not just proposals
- Cut out layers of low value review
Below we unpack the memo and offer five practical takeaways for industry.
Continue Reading JCIDS, Rewired: What DoD’s New Requirements Memo MeansSBA Proposes Increasing 200+ Receipts-Based Size Standards
On Friday, August 22, 2025, the Small Business Administration (“SBA”) released a proposed rule to increase the size standard for what it considers to be a small business across 263 industries. The proposed rule principally covers receipts-based size standards. These proposed increases stem from SBA’s periodic review of size standards
Continue Reading SBA Proposes Increasing 200+ Receipts-Based Size Standards