Several months into the Department of War’s (DoW) suspension of the next phase of the Cybersecurity Maturity Model Certification (CMMC) Program, contractors are continuing to navigate uncertainty relating to the program. With the Department’s review underway, this post takes stock of where the program stands, what remains in effect, and what contractors should be considering.
Continue Reading CMMC Reform Task Force Updates September 2026DoW Issues Revision 3 of its Class Deviation on Security Requirements
On September 3, 2026 the Department of War (DoW) issued Revision 3 to its Class Deviation and associated Procedures, Guidance and Information (PGI) that implements a new Part 240 (consistent with the Revolutionary FAR Overhaul of Part 40, which we reported on in July). Like the proposed FAR Rule, this DFARS Class Deviation addresses supply chain and information security issues but is focused on requirements that are unique for DoW contracts.
Continue Reading DoW Issues Revision 3 of its Class Deviation on Security RequirementsDSCA Expands FMF Eligibility for Direct Commercial Contracts
Earlier this year, the Defense Security Cooperation Agency (“DSCA”) issued updated policy guidance implementing a significant expansion of the universe of countries authorized to use Foreign Military Financing (“FMF”) for direct purchases of U.S. defense items. Previously, only ten countries were eligible for use of FMF for direct commercial contracting
Continue Reading DSCA Expands FMF Eligibility for Direct Commercial ContractsCongress 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 ContractorsNew 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 ContractorsDefense 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 ProposalsPentagon Releases Artificial Intelligence Strategy
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.
Continue Reading Pentagon Releases Artificial Intelligence StrategyMassachusetts 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 ProjectsAugust, September, and October 2025 Cybersecurity Developments Under the Trump Administration
This is the seventh blog in a series of Covington blogs on cybersecurity policies, executive orders (“EOs”), and other actions of the Trump Administration. The sixth blog is available here and our initial blog is available here. This blog describes key cybersecurity developments that took place in August, September
Continue Reading August, September, and October 2025 Cybersecurity Developments Under the Trump Administration