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Enhanced Requirements for Cost-Reimbursement Contracting

Client Alert | 1 min read | 03.16.11

As required by the FY 2009 DOD Authorization Act, the Federal Acquisition Regulation has been amended effective March 16, 2011 (76 Fed. Reg. 14543), to add new provisions controlling the Government's decision to award cost-reimbursement contracts. The enhanced regulations focus on the Government's internal processes, but the provisions most likely to affect contractors directly are the requirement for appointment of a qualified contracting officer's representative (COR) or contracting officer's technical representative (COTR) prior to award of cost-reimbursement contracts and assignment on a non-delegable basis to the cognizant federal agency official (CFAO -- generally the ACO for DOD contractors) of responsibility for determining the adequacy of the contractor's accounting system during the entire period of contract performance, with no express limit in the regulation as to the type of contract covered by that provision.

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Client Alert | 13 min read | 06.12.26

EU Cyber Resilience Act Countdown: 11 September 2026 Incident/Vulnerability Reporting Deadline Less Than 100 Days Away

The EU Cyber Resilience Act (CRA) is an EU product cybersecurity law for connected products (formally, “products with digital elements” under the CRA) commercialized in the EU; it entered into force on 10 December 2024, with direct application across the EU. Full application begins 11 December 2027, but one of its most operationally demanding provisions takes effect in just under 100 days, on 11 September 2026: the mandatory vulnerability and incident reporting under Article 14 CRA....