On February 17, 2026, the Federal Acquisition Regulatory Council (FAR Council) released a Proposed Rule (Proposed Rule) to implement Section 5949(a) of the James M. Inhofe National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2023 (Section 5949), following the FAR Council’s May 3, 2024 Advanced Notice of Proposed Rulemaking (ANPR). Comments on the proposed rule are due by April 20, 2026.Continue Reading Section 5949 Proposed Rule Puts the FAR Council’s Chips on the Table
The FY 2026 National Defense Authorization Act
On December 18, 2025, the Fiscal Year 2026 National Defense Authorization Act (FY 2026 NDAA) (P.L. 119-60) was signed into law. The Act makes significant changes to defense acquisition, sourcing restrictions, and interactions between the Defense Industrial Base (DIB) and the Department of Defense (DOD). Continue Reading The FY 2026 National Defense Authorization Act
Off the (Supply) Chain: Director of National Intelligence Issues First Exclusion and Removal Order Under the Federal Acquisition Supply Chain Security Act
On September 18, 2025, the Director of National Intelligence (DNI) issued the first order under the authority conferred by the Federal Acquisition Supply Chain Security Act (FASCSA), requiring exclusion and removal of products and services by an identified source.[1]
Continue Reading Off the (Supply) Chain: Director of National Intelligence Issues First Exclusion and Removal Order Under the Federal Acquisition Supply Chain Security Act
Final Rule Implements Restrictions on Simultaneous Consulting Work for DOD and Covered Foreign Entities
On August 25, 2025, the Department of Defense (DoD) issued the Final Rule implementing Section 812 of the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2024 (P.L. 118-31). The Final Rule will take effect on October 24, 2025 via a new solicitation provision, DFARS 252.209-7012 (Prohibition Relating to Conflicts of Interest in Consulting Services – Certification).Continue Reading Final Rule Implements Restrictions on Simultaneous Consulting Work for DOD and Covered Foreign Entities
P-R-C You Later! GSA Previews Final Transition to Transactional Data Reporting for Schedule Contract Pricing
On June 9, 2025, the General Services Administration (GSA) Federal Acquisition Service (FAS) quietly announced that Transactional Data Reporting (TDR) would be exiting “pilot” status; under Refresh 27 to the Multiple Award Schedule (MAS), TDR will be mandatory for all eligible Special Item Numbers (SINs), effective beginning in the next sales reporting quarter after each contractor accepts the modification, with remaining SINs to be added in future refreshes. Continue Reading P-R-C You Later! GSA Previews Final Transition to Transactional Data Reporting for Schedule Contract Pricing
New SF-328 Released and Embedded Guidance Seeks More Information Up Front
On May 12, 2025, the Defense Counterintelligence and Security Agency (DCSA) released a new SF-328[1] consisting of 9 questions and 6 pages of instructions that detail the types of supporting documentation requested and identify information required by different responding entities (e.g., corporate, non-profit, academic, etc.). With this SF-328, DCSA is seeking certain frequently requested information and documents with initial SF-328 submissions rather than obtaining these documents through communications or revised SF-328 submissions. Additionally, when completed, the new SF-328 is considered Controlled Unclassified Information (CUI).Continue Reading New SF-328 Released and Embedded Guidance Seeks More Information Up Front
New SF-328 for Foreign Ownership, Control, and Influence Assessments Approved, Publication Imminent
On May 7, 2025, the Defense Counterintelligence and Security Agency (DCSA or the “Agency”) announced the approval[1] of a revised and expanded Standard Form (SF) 328, Certificate Pertaining to Foreign Interests. Contractors and subcontractors engaged in work involving classified information use the SF-328 for disclosures relating to foreign ownership, control, or influence—and the form will soon be required for contractors and subcontractors in the unclassified space for certain covered contracts. Publication of the updated form has not yet occurred but is expected as soon as this weekend (May 10-11). New SF-328 forms will be required for initial and changed condition packages initiated on or after May 12 according to a National Industrial Security System (NISS) communication today.Continue Reading New SF-328 for Foreign Ownership, Control, and Influence Assessments Approved, Publication Imminent
Trump’s Government Contracts Rebrand: From “Government” Procurement to “Just-GSA” Procurements
On March 20, 2025, the White House issued Executive Order (“EO”), “Eliminating Waste and Saving Taxpayer Dollars by Consolidating Procurement,” to consolidate domestic civilian contracting for “common goods and services” within one agency—the General Services Administration (“GSA”). The EO defines “common goods and services” as those described in the Category Management system first developed as part of a previous effort, dating back to 2014, to coordinate spending across the government.Continue Reading Trump’s Government Contracts Rebrand: From “Government” Procurement to “Just-GSA” Procurements
New Year, Updated List: The U.S. Department of Defense Updates Its List of Chinese Military Companies with Ancillary Supply Chain and USG Contracting Impacts
On January 2, 2025, the U.S. Department of Defense (DoD) updated the 1260H List of entities identified as “Chinese military companies” (CMC) operating in the United States, as required by section 1260H of the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2021 (Section 1260H), adding new entities and removing others. The updated 1260H List now includes 76 entities. Continue Reading New Year, Updated List: The U.S. Department of Defense Updates Its List of Chinese Military Companies with Ancillary Supply Chain and USG Contracting Impacts
Special Edition of the Fastest 5 Minutes
New Administration – Domestic Preferences and Supply Chain Security
This week’s special edition focuses on what contractors can expect from the incoming administration relating to domestic preferences, supply chain security and sourcing, and evolving requirements and enforcement, and is hosted by Yuan Zhou, Addie Cliffe, and Alex Barbee-Garrett. Crowell & Moring’s “Fastest 5 Minutes” is