On September 16, 2026, President Trump issued a Presidential Memorandum (the “Memorandum”) titled “Restoring Reciprocity in Government Procurement,” which aims to remove Canadian origin items from the U.S. government procurement system. The Memorandum provides few details on how this policy goal should be effectuated, but directs the following actions:
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The U.S. Small Business Administration (“SBA”) has extended the comment periods for its proposed overhaul of small business size standards and its accompanying Revised Size Standards Methodology by 60 days, from September 21 to November 20, 2026.
As we discussed in our prior post, SBA’s proposed rule would establish new size standards for 338…
Congress is considering so-called “right to repair” legislation that could produce one of the most consequential changes to Department of War (“DoW”) intellectual property rights in decades. Provisions advanced during consideration of the Fiscal Year (“FY”) 2027 National Defense Authorization Act (“NDAA”) would make Government Purpose Rights the default for certain technical data, computer software,…
On September 14, 2026, Deputy Secretary of War Stephen Feinberg issued a memorandum and an accompanying appendix focused on strengthening the defense industrial base by reforming acquisition requirements related to a wide range of issues, including accounting standards, efficiency, government oversight, procedural requirements, audits, pricing, and more. Building on prior policymaking, including Executive Order 14402…
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.…
Key Takeaways:
On August 25, 2026, the Ninth Circuit issued a 2-1 decision in…
For decades, the United States and India circled each other as potential defense partners—aligned by democratic values and shared strategic concerns, yet separated by Cold War legacies and divergent procurement cultures. Now, a proposed Reciprocal Defense Procurement Agreement (“RDPA”) promises to open each country’s military marketplace to the other’s defense firms. But the road to…
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…
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On August 26, 2026, President Trump issued Executive Order 14421, Declaring a National Emergency to Secure the United States Bulk-Power System. The Order establishes a new national security regulatory framework for a broad range of equipment, software, services, and supply chain relationships associated with the U.S. electric grid. Although the Order is framed as…
