EO 14173 revoked EO 11246 Equal Employment Opportunity, which required covered federal contractors to practice affirmative action, develop written Affirmative Action Plans (AAPs) and implement compliant programs directed towards equal opportunities for women and minorities. This major change left contractors with a choice: set aside all efforts previously made toward compliance with EO 11246, or continue with employment analytics under a framework acceptable under EO 14173. In this article, we explain why we encourage you to consider the continuation of these efforts.

Topics: Contracts & Subcontracts Administration, Human Resources, Government Regulations, Office of Federal Contract Compliance Programs, Service Contract Act

Well, our friendly DCAA auditors are back after the Government shutdown. On December 2, 2025, Defense Contract Audit Agency (DCAA) issued a memorandum to their auditors titled, “Actions Required for Assignment Due Dates Following Furloughs.”

Topics: Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE), Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations

On November 26, 2025, the Office of Management and Budget (OMB) issued the 2025 Compliance Supplement. The Supplement outlines the compliance requirements to assist auditors in understanding the Federal program’s objectives, procedures and requirements when performing a Single audit for fiscal years beginning after June 30, 2024. The Compliance Supplement is normally issued in the spring of each year; however, OMB delayed its issuance to incorporate significant updates to 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, in October 2024. In order to assist auditors with the different requirements, Part 3 Compliance Requirements of the Supplement was divided into two Parts for audit testing as follows:

• Part 3.1 for awards subject to 2 CFR 200 prior to October 2024 and
• Part 3.2 for awards after October 1, 2024

Topics: Accounting System Compliance, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Grants & Cooperative Agreements (2 CFR 200)

The Department of Defense (DoD) issued a final rule on September 10, 2025, amending the Defense Federal Acquisition Regulation Supplement (DFARS) to incorporate the requirements of the Cybersecurity Maturity Model Certification (CMMC) for FAR-based contracts and subcontracts, effective November 10, 2025.

Topics: Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR), Cybersecurity, Grants & Cooperative Agreements (2 CFR 200)

September 2026 Update

Since this article was published, OFCCP has finalized additional regulatory changes affecting government contractors. On August 21, 2026, DOL published final rules revising the regulations implementing Section 503 and VEVRAA and rescinding the regulations that implemented EO 11246. Most Section 503 and VEVRAA changes take effect September 21, 2026. Read our latest Client Alert for a breakdown of the updated requirements and key compliance dates.

Topics: Small Business Compliance, Contracts & Subcontracts Administration, Human Resources, Government Regulations, Office of Federal Contract Compliance Programs, Service Contract Act

On October 21, 2025, the Small Business Administration (SBA) released a state-level analysis or estimate of the impact of a government shutdown on small business lending. The shutdown has frozen the SBA’s core 7(a) and 504 small-business lending programs. These lending programs are designed to support small businesses’ access to funds to acquire or improve long-term fixed assets such as real estate, machinery, and equipment.

Topics: Accounting System Compliance, Small Business Compliance, Government Regulations

Department of Defense (DoD) issued a final rule on September 10, 2025, amending Defense Federal Acquisition Regulation Supplement (DFARS), incorporating contractual requirements under the Cybersecurity Maturity Model Certification (CMMC) program as part of the National Defense Authorization Act for FY 2020 to enhance cybersecurity for the US defense industrial base. The final rule is effective November 10, 2025.

Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR), Cybersecurity

The U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) has finalized a significant set of amendments to the International Traffic in Arms Regulations (ITAR), effective September 15, 2025, which expand the U.S. Munitions List (USML) and introduce new definitions and a licensing exemption. These changes mark the first time in years that DDTC has expanded the USML’s coverage more than it has reduced it. The final rule amends 15 of the 21 USML categories, representing a substantial increase in the number of controlled items.

Topics: Contracts & Subcontracts Administration, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Material Management & Accounting System (MMAS), Manufacturing Operations Consulting

The federal government has shut down again. It happens. With fiscal year 2025 funding lapsed and in our rearview mirror, how can government contractors mitigate the risk of potential stop-work orders and financial hardship? In this article, we discuss areas to consider not only to mitigate your risk but also to avoid significant financial hardship.

Topics: Contracts & Subcontracts Administration, Government Regulations, REAs, Claims & Terminations

Six months after the Defense Contract Audit Agency (DCAA) made its major reorganization, it made another one: the elimination of its Field Detachment (FD) as a separate entity within DCAA. The Field Detachment was a separate entity within DCAA that handled DCAA’s classified audit work. It was a separate and distinct DCAA entity from the current Land, Air, and Sea Directorates of DCAA.

Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations