As part of the Revolutionary FAR Overhaul (“RFO”), the FAR Council issued a proposed rule that would implement — with some notable changes — the Council’s model deviation for FAR Part 15, Contracting by Negotiation.
A number of those proposed
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A Comparison of the EU Cloud and AI Development Act Requirements Against the U.S. FOCI Regime and FedRAMP
As governments increasingly focus on cloud security and sovereignty, the European Commission (“EC”) is, through its proposal for a Cloud and AI Development Act (“CADA Proposal”), attempting to create a regime establishing “sovereignty” requirements on cloud computing service providers that
GSAR Class Deviation on Safeguarding Government Data in Large Language Models Takes Effect
On September 28, 2026, the General Services Administration (GSA) announced the final version of a new class deviation, titled “Basic Safeguarding of Data within Large Language Model Artificial Intelligence Systems,” that applies compliance requirements to contracts involving the use of
GSA Previews Significant Changes Planned for Upcoming Multiple Award Schedule Refresh
On October 5, 2026, the General Services Administration (GSA) Federal Acquisition Service previewed its plan to issue Multiple Award Schedule (MAS) Refresh 34 in November 2026. The announcement of Refresh 34 comes just days after the release of Refresh 33
GAO Finds Conflict Investigation Unreasonable Where Agency Failed to Ask Awardee About Business Relationship
In Viderity Inc. – Costs, GAO found an agency’s investigation into a potential conflict of interest to be unreasonable where the agency “failed to inquire with” the awardee-intervenor “as to whether the firm had a business relationship with” an
Presidential Memorandum Tasks Agencies with Removing Canadian Origin Items from Federal Procurement System
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
SBA Extends Comment Period on Proposed Small Business Size Standards to November 20
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
Right to Repair or Rewrite of DoW Data Rights? Five Questions for Defense Contractors
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
CMMC Reform Task Force Updates September 2026
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
Department of War Issues Memorandum Aimed at Strengthening the Industrial Base Through Acquisition Reform
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