How Are Regulatory Risks Evolving from 2025 into 2026

The regulatory risks of 2025 set the stage for heightened challenges in 2026, reshaping how contractors and grant recipients must approach compliance and strategic planning. According to an article by Melissa Taylormoore and Todd Rouse of White & Case, sweeping revisions to the Federal Acquisition Regulation (FAR), the DoD’s formal adoption of CMMC 2.0, and rising “Buy American” content thresholds have forced organizations to confront new obligations while anticipating how these requirements will evolve next year. Legal, compliance, and operational teams now face the task of translating lessons from 2025 into forward-looking strategies that address both enforcement and industrial-policy expectations.

The implementation of CMMC 2.0 highlighted the risks of conditional certifications, mandatory SPRS registration, and annual compliance affirmations, exposing contractors to greater False Claims Act liability. These 2025 challenges underscore the need in 2026 for ongoing cybersecurity readiness, continuous monitoring, and early engagement with third-party assessors to maintain contract eligibility. Similarly, the FAR Council’s proposed extension of NIST SP 800-171 Rev. 2 safeguards for CUI demonstrates that 2025’s growing cybersecurity expectations will continue to demand robust incident-response programs and financial accountability for lapses in 2026.

Procurement and supply chain reforms in 2025 also foreshadow 2026 pressures. Streamlined FAR rules and discretionary contracting models provide flexibility but increase the risk of bespoke clauses and unexpected obligations. Rising Buy American thresholds and domestic sourcing priorities suggest that supply chain planning and compliance documentation will be central to mitigating regulatory risks next year. DEI-related certification ambiguities further reinforce the importance of proactive internal governance and documentation to reduce potential FCA exposure.

Looking ahead, contractors and grant recipients must integrate lessons from 2025 into a strategic compliance framework for 2026. This includes aligning cybersecurity, procurement, DEI, supply chain, and industrial-capital strategies to anticipate regulatory expectations, reduce risk exposure, and effectively leverage federal investment opportunities. Firms that embed compliance into operational and strategic planning will be best positioned to navigate evolving regulatory risks.