HKA Government Contracting Quarterly Regulatory Update
20th November 2025
Fall 2025

Revolutionary FAR Overhaul Update
As part of the comprehensive reform of the FAR, the FAR Council continued to publish model deviation guidance and released version 2.0 of the FAR Companion.

National Defense Authorization Act for Fiscal Year 2026
The Senate and House of Representatives passed their versions of the NDAA for FY 2026, which include provisions that are impactful to government contractors.

CAS Board Notice of Meeting Agendas
The CAS Board issued a notice of agenda identifying discussion topics from its June meeting and for upcoming meetings scheduled for July, August, and September.

CAS Board Notice of Proposed Rulemaking Related to Conformance of CAS to GAAP
The CAS Board released a notice of proposed rulemaking to eliminate some or all of CAS 404, 408, 409, and 411.

CAS Board Final Rule Addressing Operating Revenue & Lease Accounting
The CAS Board issued a final rule to address CAS’s conformance with GAAP regarding operating revenue and lease accounting.

Final Rule to Adjust Certain Thresholds to Account for Inflation
The FAR Council issued a final rule to implement statutorily required adjustments to certain acquisition-related thresholds to account for inflation.

DCAA MRD on Contractor Business System Audits
DCAA issued an MRD clarifying that auditors should apply “material weakness” terminology only when a contractor has a DFARS 252.242-7005-covered contract; otherwise, they should use “significant deficiency.”

DCAA MRD on Revisions to GAGAS
DCAA announced that recent GAGAS revisions, effective December 15, 2025, will introduce major quality management updates and a new Quality Management System launching in FY 2026.