Back on August 19, 2026, SBA issued proposed rules–one covering what would change and one covering the underlying methodology. This would, in most cases, monumentally increase the size standards for the various industries that perform federal contracts, along with simplifying how industries are categorized and switching several industries from receipts-based to employee-based size standards. Indeed, we had two separate posts on these changes, one exploring the actual size standard increases and the other exploring the recategorization and switch to employee-based size standards. SBA initially set a deadline of September 21, 2026, for comments on these changes. Now, it is extending that date, as we’ll explore briefly below.
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8(a) Program Impacts of SBA’s Final Rule on Social Disadvantage
Our readers already know that SBA finally updated its 8(a) Program social disadvantage regulation to reflect SBA’s current policies and application review standards and procedures. And that new rule takes effect today! We previously blogged on this regulatory update here. We also blogged on the corresponding guidance issued by SBA here. In this article, we will take a more in-depth look at the new final rule, its potential implications, and some of the remaining questions it leaves unanswered.
Continue readingSBA Proposes Monumental Changes to Small Business Size Standards (Part 2)
As we discussed last week, on August 19, 2026, SBA proposed what can only be described as a complete shift in the paradigm of the small business size standards. In the first part of our review of these changes, we looked at the actual planned size standards themselves and how massive of a jump they represent from the norm. In that post, we also mentioned that SBA is proposing to simplify and combine several NAICS codes, as well as move several NAICS codes from receipts-based to employee-based size standards. Today, we’re going to explore this latter observation.
Continue readingSBA Proposes Monumental Changes to Small Business Size Standards (Part 1)
Every few years, SBA updates its size standards for small businesses. In most years, these updates, while notable, are not groundshaking, and usually just account for inflation. That cannot be said of the most recent proposed changes. We do not use hyperbole here, but, sometimes, emphatic language must be used. SBA is proposing what can only be described as absolutely massive changes to its size standards for small business contracting. On August 19, 2026, SBA released its proposal for what can only be described as a new size standard paradigm. We explore these in greater detail here, and plan on one or more follow-up posts as there are multiple aspects of the system that would be changed if the proposal is finalized.
Continue readingReviewing RFO Proposed Rules: Parts 5, 24, 29, and 52
In June 2026, the FAR Council released its first batch of proposed rules in the Federal Register to implement the changes to the Federal Acquisition Regulation (FAR). We recently covered the first of those proposed rules, which amended language in FAR Parts 1, 2, 4, 33, 39, 40, 52, and 53. In this post, we will review how the RFO is being implemented regarding FAR Parts 5, 24, 29, and 52. From a general perspective, it looks like the proposed regulation tracks with the proposed language already issued under the RFO.
We’ve posted quite extensively about the Revolutionary FAR Overhaul (RFO) project in past blog posts. For some background info, check out these posts: Executive Order, Overview of FAR 2.0, FAR 2.0: Deviations and Companion Guide, FAR Part 6, FAR Part 19 (and the Once 8(a) Rule in that part), FAR Part 12, FAR Part 15, and FAR Part 33.
Continue readingBack to Basics: Trade Agreements Act
The Trade Agreements Act (TAA) and its companion, the Buy American Act (BAA), both set policies for a preference for increased domestic purchases by the federal government and its contractors. However, the TAA is designed as kind of a counterweight to the BAA. The BAA (passed in 1933), “the first of the major domestic content restriction laws, requires federal agencies to apply a price preference for ‘domestic end products’ and use ‘domestic construction materials’ for covered contracts performed in the United States.” So, the BAA encourages use of US-produced goods.
The TAA, on the other hand, waives some of those BAA requirements for goods coming out of certain favored countries that have trade agreements with the US. In other words, the TAA puts items from those favored countries on an even playing field with the US items. The TAA has some other unique aspects, including a “substantial transformation” test to determine if something is an end product.
In this post, we discuss the basics of the TAA.
Continue readingBREAKING: Department of War Suspends Introduction of Phase Two of CMMC
Last year, we noted in a couple posts that the federal government had finally began implementation of its Cybersecurity Maturity Model Certification (CMMC) Program. Apparently, however, the government has concluded that a pause is needed on further implementation due to what it describes as structural issues with the program. On July 13, 2026, the Department of War (DoW)[1] announced that it is suspending the introduction of Phase Two of the Cybersecurity Maturity Model Certification (CMMC) Program. We explore that decision in this post.
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