PilieroMazza has been covering the Department of War’s (DOW) acquisition overhaul since Secretary Hegseth’s November 2025 memorandum: “Transforming the Warfighting Acquisition System to Accelerate Fielding of Capabilities.” Now, the Department of the Army (Army), via Army Directive 2026-19, Enabling Modern Software Acquisition Practices (the Directive), has taken a concrete step to implement the DOW’s policy of focusing on acquiring and delivering weapons and business systems at speed and scale. Under the July 22, 2026 Directive, Army Secretary Driscoll announced the Army will move away from its longstanding preference for custom-built software and instead prioritize commercial products that can be configured for military use and delivered more quickly. For software suppliers and defense contractors, the Directive signals new opportunities and reinforces the overhaul’s longstanding push to have industry adapt to faster, less traditional acquisition methods.
Commercial Solutions Becomes the Starting Point
The new policy adopts the DOW’s Software Acquisition Pathway (SWP) framework as the primary pathway for all software development efforts. The DOW’s SWP has two phases: planning and execution. The Directive focuses on the planning phase, instructing Army program managers to consider commercial solutions first, followed by commercial solutions configured for Army use. When a product can address needs across multiple organizations, the Army is expected to pursue an enterprise contract rather than separate, program-specific purchases.
CSOs and OTAs Move to the Forefront
In addition to mandating a preference for commercial solutions, it’s no surprise the Directive’s also adopts Secretary Hegseth’s DOW acquisition reform stance that the use of Commercial Solutions Openings (CSOs) and Other Transaction Authorities (OTAs) should be the default solicitation and award approaches for acquiring capabilities under the SWP. The current Administration has pushed for the broader use of non-FAR-based procurements whenever possible (for more information, see our Rise of OTA in Defense Contracting series). As we previously explained, greater use of CSOs and OTAs can give early adopters a competitive advantage and may offer contractors more flexibility to negotiate data rights and intellectual property terms outside the traditional FAR framework.
Cybersecurity and Testing Must Support Speed
The policy also calls for continuous authorization to operate processes, reciprocity across Army organizations, automated testing, parallel testing and development, and acceptance of vendor test data when feasible. The message is clear: cybersecurity and testing remain essential, but they should enable rapid delivery rather than become sequential bottlenecks.
Key Takeaways:
- Lead with an existing product. Contractors should frame proposals around proven commercial capabilities and explain how those capabilities can be configured quickly for Army users. Contracts should also be ready with concise concept papers, working demonstrations, pilot plans, and evidence of successful deployment.
- Learn the nontraditional acquisition landscape. Companies accustomed to FAR-based contracts should develop familiarity with CSOs and OTAs, including the implications on data and intellectual property rights, as these non-FAR processes are necessarily increasing in popularity to keep up with the current Administration’s preference for and directives to utilize them.
- Build security into the product lifecycle. Contractors should be prepared to support continuous authorization, automated testing, reusable security evidence, and rapid remediation.
What Comes Next
The DOW acquisition overhaul is unfolding in real time, with related regulatory and policy changes continuing across the defense acquisition system. The Directive is specific to software, but it demonstrates what implementation may look like at the service level: commercial-first buying, broader use of flexible acquisition authorities, shorter delivery cycles, and greater emphasis on results. Contractors should assess now whether their products, proposal strategies, and internal processes are positioned to meet these evolving expectations. Those that adapt early will be better prepared to pursue emerging opportunities and compete effectively as future reforms take hold.
If you have questions on working with DOW, CSOs, OTAs, or the Government in general, please contact Lauren Brier, Josie Farinelli, Krissy Crallé, or another member of PilieroMazza’s Government Contracts practice group.
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