Insights

The Federal Acquisition Regulation (FAR) is getting a plain-language rewrite under Executive Order 14275, removing most non-statutory rules and introducing practical buying guides. These updates will have far-reaching impacts across all federal contracting activities.

Congress has not passed funding bills to keep key parts of the government funded for the remainder of Fiscal Year 2026—including the Departments of Defense, State, Treasury, Labor, Health and Human Services, Transportation, Housing and Urban Development, and Homeland Security, as well as independent agencies, the judiciary, and national security and foreign operations functions. As Congress continues to negotiate a deal in advance of the expiration of funds on January 30, parts of the government may still face a short shutdown, given the time needed for both the Senate and the House to consider and approve legislation. In anticipation of that possibility, agencies whose funding is uncertain are preparing for a shutdown; contractors, grant recipients, and companies that work with those agencies should do the same. Our team is ready and available to advise through the shutdown process.

Congress has not passed crucial funding bills for the start of Fiscal Year 2026.  If Congress fails to act by September 30, the government may be forced to shut down for lack of funding.  In anticipation of that possibility, agencies government-wide are preparing for a shutdown, and contractors and companies that work with the government should do so as well.  Our team is ready and available to help advise companies through the shutdown process.

On January 15, 2025, the Federal Acquisition Regulatory Council issued a Proposed Rule that would implement changes to the Federal Acquisition Regulation (FAR) Organizational Conflict of Interest (OCI) rules as required by the 2022 Preventing Organizational Conflicts of Interest in Federal Acquisition Act (P.L. 117-324).  Comments on the Proposed Rule are due on March 17, 2025.  (Note that pursuant to President Trump’s January 20, 2025 “Regulatory Freeze Pending Review” Executive Order, the Proposed Rule is subject to further review, which may result in revisions and an extension of the 60-day comment period.)

This special edition of the Fastest 5 Minutes podcast covers common questions—and answers—about a potential government shutdown. Crowell & Moring's "Fastest 5 Minutes" is a biweekly podcast that provides a brief summary of significant government contracts legal and regulatory developments that no government contracts lawyer or executive should be without.