The defense acquisition system has changed more in the past 12 months than it did in the previous 12 years. If you are a government contractor still operating on your 2024 playbook, you are competing in a market that no longer exists.
A year ago, I wrote about President Trump’s Executive Order, “Modernizing Defense Acquisitions and Spurring Innovation in the Defense Industrial Base,” calling it the defense EO the industry had been waiting for. The EOs of 2025 set aggressive timelines for acquisition reform, workforce restructuring, legacy program reviews, regulatory streamlining, and requirements modernization. One year later, nearly every commitment made in those EOs has been acted on. Some have exceeded expectations, but others have created unintended consequences. Several developments not in the original EO have also compounded the pace of change in ways that few companies were prepared for. Here is a look at what the EOs of 2025 look like 1 year after that article.
CSOs and OTAs Are Now the Default
The 2025 defense EO required a plan to be submitted within 60 days to reform DoD’s acquisition processes, with a first preference for commercial solutions and a general preference for OTAs.
Secretary Hegseth’s March 2025 software acquisition memorandum directed all DoD components to use CSOs and OTAs as the default under the Software Acquisition Pathway, and his November 2025 Acquisition Transformation Strategy expanded that direction department-wide. The FY2026 NDAA codified it into statute with section 1823 expanding CSO authority to cover all commercial products and services, not just innovative ones, and authorized follow-on production contracts. Section 1826 exempted nontraditional defense contractors, including all small businesses, from FAR Part 31 cost principles and TINA requirements.
OTAs and CSOs are no longer alternative pathways. They are becoming the default, and an increasing share of new DoD work is flowing through non-FAR channels rather than traditional SAM.gov solicitations. If your BD strategy still starts and ends with SAM.gov keyword searches, you are seeing your share of the available market shrink. I encourage companies to invest the time in understanding how OTAs and CSOs actually work, how pricing differs from FAR-based contracts, and where the legal and protest landscape is still evolving. Companies that understand how to position for and perform under these mechanisms will have a durable competitive advantage. Those that treat them as a niche they can learn later will find that later has already passed.
The Revolutionary FAR Overhaul (RFO)
The most structurally significant development of the past year may not have come from the defense EO at all. Executive Order 14275, “Restoring Common Sense to Federal Procurement,” initiated the Revolutionary FAR Overhaul (RFO), the most comprehensive rewrite of the FAR in over 40 years.
The objective is to strip the FAR of non-statutory rules, rewrite it in plain language, and return it to its statutory roots across the federal government. So far hundreds of pages have already been removed. The DoD followed with 31 DFARS deviations effective February 1, 2026. The ten-for-one deregulation rule is being applied, and the Acquisition Transformation Strategytargets a transition from CAS to GAAP. For those of us who have watched the FAR grow more bloated with each bad procurement outcome over 40 years, this is long overdue.
The opportunity for contractors is real, but class deviations have created uncertainty around which provisions apply to current versus upcoming solicitations. While GSA and OFPP have stripped pages from the FAR, the FY2026 NDAA simultaneously added new mandates. (The executive branch removes rules while Congress adds them.) Contractors need to prepare to educate their government customers on how to engage under the updated guidance and develop new approaches to delivering mission-driven outcomes at speed. Waiting for the dust to settle is not a strategy. The companies that learn the new rules first will shape how the rules are applied.
Workforce Reductions: The Unintended Consequence?
The 2025 defense EO called for a plan to be developed within 120 days to “reform, right-size, and train the acquisition workforce.” The goal was to help acquisition professionals embrace OTAs, CSOs, and the Adaptive Acquisition Framework(AAF). What has actually happened is a broader workforce reduction that hit the acquisition community especially hard.
DOGE-aligned reductions resulted in the loss of over 317,000 federal employees governmentwide by the end of 2025. The DoD targeted a 5% to 8% cut in its civilian workforce of more than 900,000, and the acquisition workforce did not receive a carve-out. DISA reported a 10% staff-reduction, with internal memos warning of “extreme risk for loss of service.” Air Force program executive officers have reported an exodus of senior talent. While the EO envisioned an empowered, risk-taking acquisition workforce, the workforce received buyout offers, hiring freezes, and organizational uncertainty. Contractors should acknowledge this challenge and show extra empathy toward their government customers. They are being asked to do more with less, and there are no signs of relief on the horizon.
Contractors should expect longer timelines from a system that is simultaneously being asked to move faster and implement new processes, with less capacity than ever. I urge companies to be proactive about reducing friction in every government interaction. Submit cleaner proposals, anticipate information requests, and make it easy for an overworked contracting officer to say yes. The companies that treat government capacity constraints as their problem to help solve will move faster than those waiting for the bureaucracy to catch up to the policy.
Program Accountability with Teeth
A 90-day review of all MDAPs, with any program more than 15% over budget or behind schedule, evaluated for potential cancellation, was also required by the 2025 defense EO. That review was completed on schedule.
The January 2026 follow-on EO (E.O. 14372) extended the framework by directly targeting contractor underperformance, including provisions restricting dividends and stock buybacks. The FY2026 NDAA added Section 875, authorizing contracting officers to withhold up to 5% of payments from incumbents who file bid protests, with forfeiture if the protest is dismissed by GAO. Program performance now directly affects future eligibility, and using recompetes as a delay tactic carries real financial risk. For small and mid-size contractors positioning against incumbents, this shift is creating competitive leverage that didn’t exist a year ago. Now is the time to go unseat incumbents.
RIP JCIDS
A review of JCIDS within 180 days of the release of the 2025 defense EO was also mandated. Instead of streamlining JCIDS, the administration killed it. Is anyone mourning the loss of JCIDS?
In August 2025, Secretary Hegseth and Deputy Secretary Feinberg directed the immediate disestablishment of JCIDS and ordered the JROC to stop validating service-level requirements. After 22 years of adding layers to the requirements process, they terminated the system. In its place, the DoD established a problem-focused model built around Key Operational Problems (KOPs), a Requirements and Resourcing Alignment Board (RRAB) that ties requirements directly to funding, and a Mission Engineering and Integration Activity (MEIA) designed to engage industry earlier through experimentation. The 2021 JCIDS instruction mentioned industry once in 118 pages. The nine-page replacement memo mentions industry 15 times. This is a huge win from the industry perspective.
I encourage companies, especially those with mature capabilities in areas identified as KOPs, to shift from responding to requirements to helping shape them. If you are waiting for a solicitation to tell you what the government needs, you are already behind the companies that helped define the problem.
System Transitions Are Reshaping BD Operations
GSA decommissioned FPDS.gov on February 24, 2026 and eSRS four days earlier, consolidating both into SAM.gov. Contract award data searches now require a SAM.gov account through Login.gov. The ATOM feed retires later in FY2026, and CPARS is next. Having experienced the beta.sam.gov transition firsthand, I can tell you these platform shifts always take longer to stabilize than anyone plans for.
The Navy’s SeaPort NxG Portal is scheduled to begin decommissioning by June 30, 2026, with contract actions migrating to ePS and the PIEE Solicitation Module. Effective October 1, 2026, PIEE will be required for unclassified solicitations across DoD. Anyone who has worked within PIEE understands the frustration. I suspect there is a sizable audience that wishes PIEE were on the retirement list as well.
With all the changes happening across the procurement portal landscape, now is the time to reevaluate your BD tool stack. If your competitive intelligence process relies on tools that pull from FPDS or eSRS feeds, confirm with your vendors that they have adapted to SAM.gov and that they also pull from PIEE. Operating with degraded market intelligence is how you miss the opportunity you should have seen coming.
Where It All Stands
The companies gaining traction are tracking where funding sits rather than where attention is focused. They are building fluency in OTA and CSO mechanisms, investing in infrastructure to support 90-day turnarounds (rather than 12-month procurement cycles), engaging across FY26 execution, FY27 congressional shaping, FY28 Pentagon programming, and building relationships with the acquisition workforce that remains. In-person meetings are more important than ever, and relationships are worth more now than they were a year ago. The companies that are winning are getting smart on how to educate their government customers on the new rules. They are comfortable navigating the new norm and helping their government customers do the same. The companies that are successful are getting smart on the best acquisition route for them. They’re educating their government customers and using the new FAR references while doing the groundwork for their customers.
In terms of the major EO commitments, the 60-day acquisition reform plan was implemented through EOs, memos, the Acquisition Transformation Strategy, and the FY2026 NDAA. CSOs and OTAs are now the default, and the DFARS review is underway with 31 deviations in effect. The broader FAR Overhaul is stripping the regulation back to its statutory core. The 90-day MDAP review was completed, and a cancellation list was submitted to OMB. The 120-day workforce plan was submitted, but DOGE-driven reductions have undermined the goals the EO articulated.
The 180-day JCIDS review resulted in the complete elimination of the system. Although the transitions of FPDS, eSRS, SeaPort NxG, and eventually CPARS were not part of the original EO, they are still reshaping the operational environment in parallel.
THe changes that we’ve seen are not about the policy or the legislation. They’re not even about the politics behind the pen. These changes impact the entire acquisition framework, from how requirements are defined to how contracts are competed, how performance is evaluated, and how data is accessed. Not to mention how the workforce that manages all of it. The defense demand signal is still strong, and the structural barriers to entry are lower than they have been in a long time. The rules are being rewritten in favor of companies that can deliver outcomes at speed, but none of that matters if you are still operating on last year’s playbook.