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
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Proposed FAR Part 40 Rule: Consolidation of Supply Chain Security and Information Security Requirements and New Changes to the Rules
On June 23, 2026, the Federal Acquisition Regulatory Council (“FAR Council”) issued proposed rules covering several parts of the Federal Acquisition Regulation (“FAR”). The proposed rules mark the beginning of the long-awaited notice-and-comment phase of the Revolutionary FAR Overhaul (“RFO”). This blog post, focusing on FAR Part 40, provides an overview of the proposed changes
GSA 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
What the Updated 1260H List Means for Biotechnology Procurement
On June 8, 2026, the Department of War (“DoW”) published its updated list of “Chinese military companies” operating in the United States (“1260H List”), as required by Section 1260H of the Fiscal Year (“FY”) 2021 National Defense Authorization Act (“NDAA”). The updated list includes, among other companies, WuXi AppTec Co., Ltd. (“WuXi AppTec”), a China-based
SBA’s Proposed Update to the 8(a) Business Development Program: A New Approach to Social Disadvantage
On June 11, 2026, the Small Business Administration (“SBA”) published a proposed rule that would fundamentally alter how individuals qualify as “socially disadvantaged” under the 8(a) Business Development Program (“8(a) BD Program” or “Program”). The comment period will be underway until July 13, 2026.
This five-page proposed rule states that it aims to align the
New 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 June 30, 2026. Covington’s latest
GAO 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
Proposed Rule Would Fundamentally Impact Federal Grant and Financial Assistance Framework
On May 29, 2026, the Office of Management and Budget (“OMB”), together with several other federal agencies, published a proposed rule that would fundamentally change many aspects of the regulations in 2 CFR Part 200 governing federal financial assistance awards, including grants, cooperative agreements, loans, and loan guarantees. The comment period will be underway until
From 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
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