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5.27.26
Proposed Department of Defense Rule Requires FOCI Mitigation for Unclassified Contracts Valued at More than $5 Million
On May 7, 2026, the Department of Defense (DoD) proposed changes to the Defense Federal Acquisition Regulation Supplement (DFARS) that, when finalized, will impact nearly 38,000 defense contractors and subcontractors. The proposed changes will require companies to disclose foreign ownership, control, or influence (FOCI), which they must mitigate before the contracting officer can award, modify, or extend a contract.
Client Advisories
5.21.26
SBIR and STTR Contracts: Not for Just Any Small Business
On April 13, 2026, President Trump signed into law the Small Business Innovation and Economic Security Act, reauthorizing the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs. See our prior alert here. Because of the significance of these programs to small businesses and their ability to sell new and innovative solutions to the federal government, here is a refresher on some of the rules small companies should be aware of before applying for an SBIR or STTR contract.
Alerts
5.15.26
Fixing the Federal Acquisition System: Firm-Fixed-Price Contracting the New Norm
On April 30, 2026, President Trump issued an executive order (EO), Promoting Efficiency, Accountability, and Performance in Federal Contracting, that makes firm-fixed-price contracts the default federal government agencies must use when buying products and services from private sector companies. The EO represents the latest effort by the Trump administration to reform federal acquisitions and reduce costs to taxpayers. This alert discusses impacts companies may experience when doing or seeking to do business with the federal government.
Alerts
4.17.26
SBIR/STTR Program Restarted with New Features
On April 13, 2026, the Small Business Innovation and Economic Security Act (the Act) was signed into law, reauthorizing the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs through September 30, 2031. First and foremost, this ends the six-month program pause in new awards. But it also introduces several important changes aimed at improving the effectiveness of the SBIR program and at strengthening national security. Some of the key provisions are detailed here.
Alerts
3.17.26
New AI Terms and Conditions Coming Soon to GSA MAS Contracts
On March 6, 2026, the U.S. General Services Administration (GSA) posted a proposed clause setting forth terms and conditions for artificial intelligence (AI) under GSA multiple award schedule (MAS) contracts. The clause, General Services Acquisition Regulation (GSAR) GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systemsx, may impact contractors with GSA MAS contracts who not only sell AI to the federal government but also use AI during contract performance. GSA is asking for public comment on the proposed clause through March 20, 2026. After considering any public comments, GSA will modify MAS contracts and add the clause, and contractors will have 60 days to accept the modification. This alert provides an overview of some of the clause’s more notable requirements.
Client Highlights
3.06.26
Wilson Sonsini Advises Cognito Therapeutics on Oversubscribed $105 Million Series C
On March 5, 2026, Cognito Therapeutics, a late clinical-stage neurotechnology company pioneering non-invasive neuroprotective therapies in neurodegenerative diseases, announced the closing of an oversubscribed $105 million Series C financing round. Wilson Sonsini Goodrich & Rosati advised Cognito Therapeutics on the transaction.
Alerts
3.04.26
Proposed FAR Rule on Semiconductors: Will the Federal Government Buy Contractors’ Technology?
On February 17, 2026, the Federal Acquisition Regulation (FAR) Council proposed a new rule that will impact technology companies that sell electronic products and services to the federal government, should those products and services include certain semiconductor products or services.
Alerts
8.22.25
The FAR Part 12 Rewrite: Making Commercial Acquisitions More Streamlined
The Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) continues, with rewrites to FAR Parts 4, 8, 12, and 40 issued August 14, 2025. For our previous alerts on the RFO, see here and here. This alert focuses on the FAR Part 12 rewrite: Acquisition of Commercial Products and Commercial Services. Commercial acquisitions look to be a priority for the federal government, and the Part 12 rewrite provides guidance to streamline commercial procurements while also lessening compliance requirements for contractors.
Alerts
7.29.25
FAR Part 35 Update: Making R&D Contracting More Accessible and Attractive
On July 24, 2025, the Office of Federal Procurement Policy (OFPP) and Federal Acquisition Regulation (FAR) Council published its latest rewrite to the FAR. We previously discussed this rewrite initiative—the Revolutionary FAR Overhaul—and post updates when they occur in this Alert. This latest update includes a rewrite to FAR Part 35, Research and Development (R&D) Contracting. We wanted to highlight this update because OFPP and the FAR Council believe the rewrite “makes the federal R&D environment more attractive to innovative commercial firms.” As discussed below, the rewrite ostensibly provides greater flexibility in the types of procurement methodologies and structures employed by the government procuring R&D, which should make participation in R&D by more commercial-focused firms more accessible.
Alerts
7.21.25
Streamlining Innovation in Space-Related Acquisitions: OMB Proposes a Broadening of NASA’s Procurement Tools
In July 2025, the U.S. Office of Management and Budget (OMB) proposed legislative changes to current procurement laws that include a recommendation to provide the National Aeronautics and Space Administration (NASA) with permanent statutory authority to utilize Commercial Solutions Openings (CSOs) and Other Transaction agreements (OTAs). These acquisition tools, long used by the U.S. Department of Defense (DoD), are designed to reduce procurement barriers, accelerate timelines, and enable engagement with innovative commercial vendors, particularly those that do not traditionally contract with the federal government. Together, these changes are intended to substantially enhance NASA’s ability to access cutting-edge technologies and support complex mission needs by enabling NASA to engage in faster, more agile procurement, reduce administrative overhead, and broaden participation by start-ups, research institutions, and commercial technology providers.
Client Highlights
6.06.25
Firm Advises IonQ on Acquisition of Lightsynq Technologies
On May 30, 2025, IonQ, a leading commercial quantum computing and networking company, completed its acquisition of Lightsynq Technologies Inc., a Boston-based startup founded by former Harvard University quantum memory experts. The addition of Lightsynq’s team and intellectual property is expected to significantly accelerate IonQ’s quantum networking and quantum computing roadmaps. Wilson Sonsini Goodrich & Rosati advised IonQ on the transaction.