Following a tumultuous start to fiscal year 2026, including a government shutdown that lasted 43 days, the National Defense Authorization Act for fiscal year 2026 (NDAA 2026), Pub. L. 119-60, was passed by Congress and signed into law on December 18, 2025. NDAA 2026 is a critical legislative act, setting acquisition reforms and policies and authorizing appropriations and funding levels for the Department of Defense (DoD). With $900.6 billion in funding for the DoD, NDAA 2026 contains a plethora of acquisition reform provisions and critical updates impacting defense contractors. Title XVIII of NDAA 2026 significantly increased certain acquisition thresholds, including triggers for the Truthful Cost or Pricing Data Act (formerly the Truth in Negotiations Act) and Cost Accounting Standards application, which you can read about here. Additionally, NDAA 2026 increases the thresholds for noncompetitive acquisitions and when information technology requirements qualify as a major system.Continue Reading FY2026 NDAA: Major Increases to Critical Acquisition Thresholds
Software
FAR 2.0 Part 39 in Arcade Mode—How Federal IT Acquisition Just Hit Reset
For those who grew up gripping a joystick and dodging alien fire in Defender, riding ostriches through floating platforms in Joust, or crossing a hectic freeway in Frogger, winning wasn’t about memorizing rules; it was about adapting fast, reading the patterns, and leveling up. That same urgency now applies to federal information and communication technology (ICT) contractors. A sweeping overhaul of FAR Part 39 has just been released, and while it may not blink and beep like a cabinet in a darkened arcade, it’s just as demanding. There’s no attract mode here. The game has already started.Continue Reading FAR 2.0 Part 39 in Arcade Mode—How Federal IT Acquisition Just Hit Reset
Building the Cyber Fortress: New Cybersecurity Executive Order Targets Quantum, AI, and Supply Chain Security
On June 6, 2025, President Trump issued a new executive order, “Sustaining Select Efforts to Strengthen the Nation’s Cybersecurity and Amending Executive Order 13694 and Executive Order 14144” (EO), signaling the construction of a fortified cyber defense across federal operations. This directive updates the nation’s digital stronghold, modernizing risk management, defending against quantum and artificial intelligence (AI) threats, and drawing sharper lines in the battle against foreign cyber adversaries. For technology companies and federal suppliers, this is a clarion call to reinforce their digital walls and sharpen their defenses. Agencies will soon build these secure-by-design principles into every contract and procurement decision. In this era of fortress-building, failing to meet these standards not only will leave your gates unguarded but also could bar you from the entire federal marketplace. The EO may read like ordinary policy, but don’t be misled: It’s a direct command for companies to strengthen their cyber defenses or be locked out of federal opportunities altogether.Continue Reading Building the Cyber Fortress: New Cybersecurity Executive Order Targets Quantum, AI, and Supply Chain Security
The Need for Speed: DoD’s “Software Fast Track” Targets Bureaucracy at Mach 2
The Department of Defense (DoD) is revving its engines again—this time to rocket past its own software acquisition drag. Launched via an April 24 memo from Acting DoD CIO Katie Arrington, the DoD’s Software Fast Track (SWFT) Initiative entered a 90‑day sprint to redefine Accelerating the Authority to Operate (ATOs), aiming to replace the outdated Risk Management Framework (RMF) with AI‑enabled, continuous compliance workflows. Officially live on June 1, 2025, SWFT isn’t a fully cleared runway—it’s a mission in motion, with Requests for Information (RFIs) out and industry poised to respond. But the real turbulence won’t be technical—it’ll be cultural: Can Pentagon policy and personnel move at Top Gun pace?Continue Reading The Need for Speed: DoD’s “Software Fast Track” Targets Bureaucracy at Mach 2
OMB Issues Guidance to Agencies on Responsible Artificial Intelligence Acquisitions
Contractors interested in offering federal agencies artificial intelligence (AI) can now glean insight into how agencies are expected to conduct AI acquisitions. On September 24, 2024, the Office of Management and Budget (OMB) issued Memorandum M-24-18, Advancing the Responsible Acquisition of Artificial Intelligence in Government (the Memorandum), providing guidance and directing agencies “to improve their capacity for the responsible acquisition of AI” systems or services, including subcomponents. The Memorandum builds on the White House’s Executive Order 14110, Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence, and OMB Memorandum M-24-10, Advancing Governance, Innovation, and Risk Management for Agency Use of Artificial Intelligence. Taking effect on March 23, 2025, M-24-18 will apply to all solicitations and contract option exercises for AI systems covered under the Memorandum.Continue Reading OMB Issues Guidance to Agencies on Responsible Artificial Intelligence Acquisitions
Executive Order 14410: An Artificial Intelligence Odyssey
What do you think is going to be scarier—artificial intelligence (AI) or the government’s effort to regulate AI? On October 30, 2023, the White House issued Executive Order (E.O.) 14410, Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence. As the federal government’s latest foray into harnessing AI, this E.O.—like those before it, generally—recognizes that AI offers extraordinary potential and promise, provided that it is harnessed responsibly to prevent the exacerbation of societal harms. Since E.O. 14410, there has been a flurry of activity in the federal government, including guidance and policies providing an indication of how agencies can/should/will harness AI to support agency objectives. While we are far from a situation similar to Skynet from the Terminator franchise or HAL 9000 from 2001: A Space Odyssey, the government’s accelerated activity to reap AI’s potential benefits far outpaces the provision of actionable guidance so contractors can understand and adapt to what will be required in offering AI products and services to the government. So let’s open the pod bay doors and explore…Continue Reading Executive Order 14410: An Artificial Intelligence Odyssey
Here to Remind You of the Key Provisions of the Fiscal Year 2021 National Defense Authorization Act – You Oughta Know!
Each year, Congress presents us in Title VIII of the National Defense Authorization Act (NDAA) a potpourri of procurement reforms, changes, and additions. Some are effective immediately, while some are bound for rulemaking and regulation and surface years from enactment. Some require analyses, reports, and studies which have no immediate impact but provide a roadmap that can and should be used by government contractors in their business planning. Finally, some provisions of the NDAAs just wither away and have no impact whatsoever. Nineteen days before the Trump Administration ended, the US Senate followed the US House of Representatives in overriding the President’s veto of the William (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 (H.R. 6395) (FY2021 NDAA), making it law on January 1, 2021. Happy New Year! As for its Title VIII, the FY2021 NDAA is no different from its predecessors in its procurement potpourri. Here’s a tour of key provisions you oughta know.
Continue Reading Here to Remind You of the Key Provisions of the Fiscal Year 2021 National Defense Authorization Act – You Oughta Know!
Slow and Steady Doesn’t Always Win the (Acquisition) Race: The CODER Act Aims to Transform DoD Software Acquisition
As the frequency and sophistication of existential threats to national security over the past decade have drastically increased, the United States’ reliance on software to identify threats, rapidly share information, and manage its military resources has increased. Accordingly, the federal government’s ability to timely develop, procure, and deploy software to the field has been—and continues to be—a critical component of national security. Notwithstanding the growing importance of software to national security, the Department of Defense (DoD) software-acquisition process mirrors the lengthy, inflexible process typically reserved for the acquisition of major weapon systems. As a result, the DoD’s software development and acquisition cycles are significantly longer for their commercial counterparts, thus affecting the DoD’s ability to deliver timely solutions to users and rapidly respond to urgent threats.
Continue Reading Slow and Steady Doesn’t Always Win the (Acquisition) Race: The CODER Act Aims to Transform DoD Software Acquisition
