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Part 1: Summary of 13 Sections of the 2026 NDAA Small GovCons Need to Understand

  • Writer: Shirley
    Shirley
  • Jul 16
  • 3 min read

Updated: Aug 13


The House version of the 2026 National Defense Authorization Act contained several changes to procurement practices that are relevant to small GovCons. Changes made by the Senate Armed Forces Committee were advanced to the full Senate for debate and modifications the week of 7/14/25 but were not discussed before the August recess. Those modifications will be summarized when available. This is the House's Chairman's Mark. And this is a summary of the changes in plain language:


 

1.    Section 816: If an incumbent protests a re-compete that they lost and the protest is deemed without merit, all fees and profits for the contract extension could be clawed back.

2.    Section 822: Establishment of public-private partnerships to develop the advanced manufacturing workforce and incentives for both government and industry to ensure success in recruiting, training, and retaining individuals in advanced manufacturing.

3.    Section 825: Requires the Comptroller General to examine the management, training, and development of the acquisition workforce and current acquisition processes to enable the Department to maintain an acquisition workforce that can meet mission requirements

4.    Section 826: Requires the Secretary of Defense, acting through the Director of the Acquisition Innovation Research Center (AIRC), to conduct a comprehensive assessment of the Defense Acquisition University (DAU), to enhance its operations and performance in training and developing the defense acquisition workforce.

5.    Section 833: Requires the Secretary of Defense to establish minimum qualifying criteria for supply chain illumination software for contractors of the Department of Defense.

6.    Section 835: Requires the Secretary of Defense to establish and maintain a publicly available online repository to allow suppliers to submit a self attestation of compliance of their products. Product vendors are encouraged to register covered products and to use supply chain illumination software to assist in meeting the registration requirements. The committee believes this improved visibility of compliant products will increase demand by the DoD for such products.

7. Section 1821: Allows increases the threshold for justification and approvals non-competitive awards up to $500,000,000 from the previous maximum threshold of $75,000,000. The Simplified Acquisition Threshold (SAT) has increased from $250,000 to $500,000. The micro-purchase threshold has increased from $10,000 to $25,000. In addition, cost and price data is only required to be submitted on prime contracts or subcontracts exceeding $10,000,000, an increase from $2,000,000.

8.    Section 1822: Clarifies that a payment under a contract for the acquisition of services provided in accordance with a "commercially utilized acquisition strategy" shall not be considered an advance payment. Authorizes the head of an agency to pay in advance for commercially available content and for certain charges for information and communication technologies subscriptions, reservations, or tenancy (including cloud environments).

9.    Section 1825: Requires the Secretary of Defense, not later than 120 days after the date of the enactment of the NDAA, to conduct a comprehensive review of the Department’s approach to commercial buying and the implementation of the Federal Acquisition Streaming Act of 1994 (FASA, Public Law 103-355) and within 180 days, to provide the congressional defense committees with a report that describes corrective actions.

10.    Section 1831: Amends the OTA to remove limitations on how a firm is categorized. DoD officials can now assess demonstrated performance and the alignment of capability with needs of the Department as the primary determinants of the financial structure of an award.

11. Section 1841:Enhances the purpose of the Procurement Technical Assistance Cooperative Agreement Program to include creating Centers of Excellence, mitigating the cost of entry for new technologies, accelerating innovation, fostering ingenuity and establishing resilient supply chains.

12. Section 1842: Establishes the Defense Industrial Resilience Consortium (IRC) under the authority of the Secretary of Defense to enhance the resilience, innovation, and competitiveness of the U.S. defense industrial base. The IRC would serve as a collaborative forum for cutting-edge manufacturers, technology developers, supply chain stakeholders, and research institutions to address critical challenges related to parts obsolescence, diminishing manufacturing and sources of supply, and single-source dependencies within the defense industrial base.

13. Section 1843: Requires the Secretary of Defense to establish a working group in the Defense Industrial Resilience Consortium (IRC referenced above), to develop recommendations for improving the policies and procedures of the DoD for the qualification, acceptance, and management of the supply chains of products manufactured using advanced manufacturing, and to supply a report to Congress within 1 year.


 
 
 

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