The Weekly Update recaps recent legislative and regulatory updates affecting
government contractors and commercial businesses.
If you have questions concerning this content, please email marketing@pilieromazza.com.
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Happy New Year from PilieroMazza!
PilieroMazza Promotes Eric Valle to Partner, Helping Government Contractors Navigate Compliance and Stay Competitive, PilieroMazza News
PilieroMazza is proud to announce that Eric Valle was promoted to Partner in the Firm’s Government Contracts Group effective January 1, 2026. Eric’s promotion reflects his deep experience in government contracting law and his commitment to helping clients reduce regulatory risk, win contracts, and grow their businesses. Read more here.
Fiscal Year 2026 NDAA Signed into Law: 6 Key Takeaways for Defense Contractors, PilieroMazza Client Alert, Jacqueline K. Unger
On Thursday, December 18, 2025, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2026 (2026 NDAA), which authorizes over $900 billion in funding for the Department of Defense (DOD) and other national security programs. The 2026 NDAA contains many acquisition reform provisions and other critical provisions impacting defense contractors. This client alert provides six key takeaways from these provisions. Read more here.
Warfighting at Warp Speed, Part 2: Tracking the 2026 NDAA and DOW’s Acquisition Overhaul, PilieroMazza Blog, Lauren Brier, Josie Farinelli
In December 2025, PilieroMazza explained some key highlights of the 3,000-page 2026 NDAA for defense contractors, tracking how these important updates will affect their ability to compete and how they align with DOW’s Acquisition Overhaul. In this blog, we dive deeper into one of these NDAA updates—Section 1826—which all small businesses, defense contractors, and prospective defense contractors need to understand, as it could significantly ease compliance burdens across the existing defense industrial base and invite new competitors into the space. Read more here.
SBA Data Call: Deadline Extended Until January 19, 2026, PilieroMazza Client Alert, Matthew E. Feinberg, Meghan F. Leemon
SBA announced, as part of a broader release of FAQs, that the deadline to respond to the December 5, 2025, data call, which we discussed here, has been extended until January 19, 2026. Read more here.
Small Business Administration (SBA):
- Final Rule: Small Business Investment Company (SBIC) Regulatory Amendments: On January 2, SBA revised the regulations for the SBIC program to modify or remove from the Code of Federal Regulations regulations that are obsolete, inefficient, or otherwise unnecessarily impede the licensing of SBICs and to remove certain barriers to investments in critical mineral extraction and processing and designated critical technologies. The final rule is available here. The rule is effective February 2.
- News Release: SBA Delivers First MARC Loans to Support Manufacturers: On December 17, SBA announced it has approved its first round of 7(a) Manufacturers’ Access to Revolving Credit (MARC) Loans. The loan program, launched prior to the federal shutdown, is the first-ever SBA loan offering dedicated to manufacturers—designed to provide maximum flexibility and minimal red tape for small businesses in NAICS 31-33. Read more here.
- News Release: SBA Launches Deregulation Strike Force to Support President Trump’s Affordability Agenda: On December 15, SBA announced the launch of a new Deregulation Strike Force to identify and eliminate regulations deemed “excessive” that were implemented during the Biden Administration. The strike force will be led by SBA’s Office of Advocacy to work across federal agencies to cut regulations in the following industries: housing and construction, healthcare and medical services, agriculture and food production, energy and utilities, transportation and logistics, and other goods and services. SBA applauds the effort to eliminate the following regulations: the FinCen Beneficial Ownership Rule, Biden-era energy efficiency regulations, and Green New Deal rules on diesel exhaust fluid. Read more here.
Government Accountability Office (GAO) Testimony: Coast Guard; Approaches to Autonomous Ship Regulation
On December 16, GAO released its testimony before the House Committee on Transportation and Infrastructure’s Subcommittee on Coast Guard and Maritime Transportation, which held a hearing on “Changes in Maritime Technology: Can the Coast Guard Keep Up?” This hearing was convened to examine the Coast Guard’s current and future uses of experimental maritime technologies and the Coast Guard’s efforts to regulate such technology to secure the Marine Transportation System. GAO identified a few factors that could constrain or complicate its ability as a regulator to enable these technologies to be developed and adopted. These factors include a lack of domestic examples demonstrating autonomous ship technologies and challenges in harmonizing international and domestic regulations. Read more here.
OMB Sets Procurement Guardrails for Buying AI Tools, Federal News Network
As more agencies jump on board the AI train, they will have to add new clauses and acquisition requirements to their contracts starting March 11. Under a new memo from the Office of Management and Budget, agencies have 90 days to update acquisition polices to ensure the LLMs they purchase are truth-seeking and ideologically neutral. Read more here.
Small Business Procurement Drops Following Changes, Bloomberg Government
Small business procurement slipped during an uneven year for federal contracting as companies navigated policy changes under the Trump administration. Read more here (subscription required).
Office of the United States Trade Representative Notice: Procurement Thresholds for Implementation of the Trade Agreements Act of 1979
On January 2, the U.S. Trade Representative released the U.S. dollar procurement thresholds to implement certain U.S. trade agreement obligations, as of January 1, 2026, for calendar years 2026 and 2027. The notice is available here.
Upcoming Presentations
SEMINAR: 2026 Procurement Realities, January 14, 2026, Isaias “Cy” Alba, IV
WEBINAR: Nuts, Bolts, and Beyond: To Be a Government Contractor, January 15, 2026, Eric Valle
WEBINAR: From Partner to Powerhouse: Building High-Impact Teams in the OTA Ecosystem, January 20, 2026, Isaias “Cy” Alba, IV
CONFERENCE: Warfighting at Warp Speed: Why Defense Contractors Must Track the DOW’s Acquisition Overhaul, January 20, 2026, Josie Farinelli
PM WEBINAR: Warfighting at Warp Speed: Why Defense Contractors Must Track the DOW’s Acquisition Overhaul, January 28, 2026, Lauren Brier, Josie Farinelli
PM WEBINAR: PilieroMazza Annual Review: 2025 GovCon Year in Review, January 29, 2026, Jon Williams, Lauren Brier, Meghan F. Leemon, Eric Valle
PilieroMazza Annual Review: 2025 CBCA and ASBCA Annual Reports Highlight Critical Contract Dispute Trends for Government Contractors, PilieroMazza Blog, Lauren Brier, Kelly A. Kirchgasser
The Civilian Board of Contract Appeals (CBCA) and the Armed Services Board of Contract Appeals (ASBCA) recently published their annual reports (the Reports), providing updates on personnel, decision statistics, and other relevant developments over Fiscal Year 2025 (FY2025). As the primary forums for federal contract appeals, the CBCA and ASBCA serve as critical resources for federal contractors. In this blog, attorneys in PilieroMazza’s REAs, Claims, and Appeals Group offer key insights from the Reports that could affect how government contractors submit or respond to CBCA or ASBCA cases in 2026 and beyond. Read more here.
How a Fair Protest Process Enhances Federal Procurement Integrity, PilieroMazza Blog, Antonio R. Franco, Katherine B. Burrows, Jacqueline K. Unger, Ryan Boonstra
This year, the federal government has seen an unprecedented level of scrutiny aimed at cutting waste and inefficiencies. While trimming waste and striving for greater efficiency are admirable pursuits, it is important not to take an overly broad approach and overlook the intent behind federal processes that may seem burdensome. Federal procurement is designed to serve the public interest, not private advantage. The bid protest process, set forth in Federal Acquisition Regulation (FAR) Subpart 33.1, plays a vital role in maintaining that interest. Too often, protests are criticized as costly or obstructive. In reality, our current system is one of the most effective mechanisms for ensuring accountability, fairness, and efficiency in the expenditure of taxpayer funds. This blog explores several benefits of the protest process and serves as a reminder of why this system is in place as the FAR undergoes various re-writes. Read more here.
General Services Administration (GSA) News Release: GSA Achieves Historic Deregulatory Reform, Delivering Nearly $1 Billion in Cost Savings
On December 22, GSA announced the completion of a comprehensive regulatory reform initiative that will save taxpayers nearly $1 billion over the next decade, while streamlining federal operations and eliminating outdated requirements. Read more here.
Department of Labor (DOL)
- Final Rule Rescission: Nondisplacement of Qualified Workers Under Service Contracts: On December 22, DOL published a final rule rescission implementing President Trump’s Executive Order revoking nondisplacement of qualified workers under Federal service contracts and directing federal agencies to take immediate steps to effectuate the revocations listed. In accordance with this directive, the DOL issued this final rule to rescind the regulations on nondisplacement of qualified workers under service contracts, which were promulgated solely pursuant to the authority provided by the revoked Executive Order. The rule is available here and is effective as of December 22, 2025.
- News Release: DOL Announces Availability of Resources to Assist Contractors with Davis-Bacon Act (DBA) Payroll Reporting Requirements: On December 16, DOL announced the availability of two important updates designed to improve compliance and reporting for contractors required to submit weekly payrolls. The new resources include an online, fillable version of Form WH-347 that provides contractors and subcontractors with an efficient way to submit accurate weekly payroll records and will help reduce common reporting errors by allowing users to enter required information directly into the form. The division also developed an annotated Form WH-347 to provide contractors, subcontractors, consultants, labor unions, and compliance professionals with a better understanding of the form and to give clear, visual guidance on how to fill out the form. Read more here.
- News Release: DOL to Conduct Targeted Review of Potential Fraud in Minnesota’s Unemployment Insurance (UI) Program: On December 15, DOL announced that it will conduct a targeted review of Minnesota’s Unemployment Insurance Program using an on-site specialized UI strike team following recent discoveries of widespread fraud in the state’s benefits programs. In a letter sent to the Minnesota Department of Employment and Economic Development, the department noted concerns that recent reports of fraud, waste, and abuse might compromise the integrity of their UI program. Read more here.
Office of Personnel Management (OPM)
- Memoranda: On December 18, OPM issued the following memoranda, authorizing the pay raise of 1% pursuant to President Trump’s Executive Order, Adjustments of Certain Rates of Pay: January 2026 Pay Adjustments; Fiscal Year 2026 Prevailing Rate Pay Adjustments; and 2025 Annual Review of Special Rates.
- Memorandum: Building the AI Workforce of the Future: On December 15, OPM issued a memorandum outlining the strategy to introduce the following programs and initiatives: (a) U.S. Tech Force to deploy fellows who are experts in AI, cybersecurity, and data science for one- to two-year terms; (b) Project Management and Data Science Fellows Programs to target fellows who are experts in project management and data science; and (c) “Semester of Service” Student Volunteer Service Program to expand internships for technology students. OPM will also implement programs to provide career opportunities for youth from foster care and expand early-career recruitment nationwide. Read more here.
Upcoming Presentations
CONFERENCE: 2026 Employment Law Rescue Guide for Contractors, January 28, 2026, Nichole D. Atallah
PM WEBINAR: You’re Hired! Restrictions on Hiring Former Government Employees for Government Contractors, February 3, 2026, Sara Ryan, Abigail “Abby” Finan
PM WEBINAR: PilieroMazza Annual Review: Workforce Updates for Multijurisdic-tional Employers—What to Watch in 2026, February 11, 2026, Nichole D. Atallah, Sarah L. Nash
Upcoming Presentations
TRAINING: Mergers & Acquisitions in Government Contracting: Novations and Recertification, January 15, 2026, Daniel Figuenick, III, Emily A. Reid
TRAINING: Insights on the Regulations Pertaining to Novations and How It Impacts Company Value, February 11, 2026, Isaias “Cy” Alba, IV, Abigail “Abby” L. Baker
Revised Privacy Laws Cast Wider Net for Corporate Compliance, Bloomberg Government
A handful of states are updating their data protection laws rather than passing new ones to get more companies to comply with stricter requirements. Read more here (subscription required).
Government Accountability Office (GAO) Report: Science & Tech Spotlight, Malicious Use of Generative AI
On December 15, GAO released a report highlighting risks associated with the use of generative AI. Attackers can manipulate these systems to produce dangerous content, disclose sensitive information, or execute malicious instructions, often bypassing safeguards through techniques like roleplaying, gradual prompt escalation (“crescendo”), and automated attacks. Despite ongoing security efforts, no generative AI system is fully secure, and misuse can significantly reduce the cost and complexity of cyberattacks, such as phishing. The report raises policy questions about creating benchmarks, guidelines, and mitigation strategies as generative AI becomes integrated into critical IT systems, emphasizing the need for proactive oversight and evolving countermeasures. Read more here.
National Aeronautics and Space Administration (NASA) Proposed Rule: Implementation of the Administrative False Claims Act
On December 30, NASA published a proposed rule and request for comments proposing to amend its regulations in order to fully implement the Administrative False Claims Act (AFCA), as amended by the Fiscal Year 2025 National Defense Authorization Act. This updated rule establishes clear and comprehensive administrative procedures for investigating, evaluating, and imposing civil penalties and monetary assessments on individuals or entities that knowingly make, submit, or present false claims, representations, or misleading statements to NASA. The AFCA offers a streamlined, agency-level enforcement remedy that enables NASA to more effectively address smaller, lower-dollar fraud cases, safeguard critical Federal funds, and strongly deter fraudulent conduct. The proposed rule is available here. Comments are due February 13, 2026.
Government Accountability Office (GAO) Report: Government Auditing Standards (Yellow Book): Frequently Asked Questions: Establishing and Maintaining a System of Quality Management
On December 15, GAO released the questions and answers to the Yellow Book to serve as a practice aid and additional guidance for audit organizations. The Yellow Book practice aid is intended to help audit organizations understand and meet the quality management requirements as they develop the design, implementation, and operation of their system of quality management for engagements conducted in accordance with the Yellow Book. It contains three sections: Section I, The Quality Management Risk Assessment Process; Section II, The Quality Management Monitoring and Remediation Process; and Section III, Engagement Quality Reviews. Read more here.
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