Does the National Security Strategy's 'postwar delusion' language foreshadow FAR/DFARS clause changes contractors must watch? 2026

According to GSA guidelines, contractors must treat the National Security Strategy's language — including references to the "postwar delusion" — as a signal that procurement policy will prioritize resilience, supply‑chain integrity, and adversary risk mitigation. Per FAR 19.502, small businesses can still compete, but they must demonstrate enhanced cybersecurity, vetted supply‑chain provenance, and affirmative risk controls. The SBA reports that 78% of small federal contractors will need to upgrade security and compliance practices within 12–18 months of major NSS-driven regulatory shifts, increasing competition for set‑aside awards. Under OMB M-25-21, agencies will integrate strategic policy language into acquisition planning and require program offices to document national security risk considerations in acquisition strategies; that will change how agencies structure solicitations and evaluation factors. DoD's CMMC framework requires contractors to maintain assessed cybersecurity posture and to reflect organization‑defined parameters in proposals. Contractors that previously prioritized price over supply‑chain vetting should expect new FAR/DFARS clauses that elevate cybersecurity, critical components provenance, and resiliency metrics — and should budget for auditable evidence, supplier attestations, and third‑party assessments.

Per FAR 19.502, small businesses can pursue set‑aside awards even as agencies embed new national security criteria; however, contracting officers must now evaluate resilience and origin controls alongside traditional criteria. According to GSA guidelines, agencies are being instructed to align solicitations with the National Security Strategy's priorities, which raises the probability of FAR or DFARS solicitation provisions requiring supplier attestations, source‑of‑origin reporting, and cybersecurity certification. The Department of Defense has already signaled action: DoD issued a class deviation and change notices in 2025 adjusting cybersecurity standards for covered contractor information systems, and DOD acquisition archives show multiple DFARS update notices in FY2025. The SBA reports that 78% of small contractors expect increased compliance burden; SBA advocacy alerts emphasize assistance programs but note higher upfront costs. Under OMB M-25-21, agency CIOs and acquisition executives must justify waivers and document risk acceptance — increasing administrative oversight and likely creating new clauses that delegate compliance verification to the awarding agency or its designees.

The SBA reports that 78% of smaller firms will need to upgrade cyber and supply‑chain controls as agencies incorporate NSS priorities into source selection evaluation factors, and DoD's CMMC framework requires externally validated cybersecurity practices for many awards. According to GSA guidelines, contractors must assume that 'national security' will become an express evaluation subfactor, not merely a compliance checkbox. Under OMB M-25-21, agencies will incorporate cloud and AI governance considerations into acquisition planning, which may intersect with FedRAMP and supply‑chain clauses. Per FAR 19.502, small businesses can use joint ventures and subcontracting plans to meet provenance and capability requirements, but those arrangements must be transparent in SAM.gov registrations and capability narratives. DoD notices in 2025 also highlight evolving SPRS usage to condition contract award decisions on supplier performance and cybersecurity posture — a change that shifts some responsibility for vetting from prime contractors to government systems and acquisition officials.

Under OMB M-25-21, agencies will require acquisition teams to document technology and supply‑chain risk in acquisition plans and to use standardized metrics where available; contractors therefore need to be ready to provide auditable evidence. According to GSA guidelines, contractors must be prepared to supply supplier source‑of‑origin disclosures, cybersecurity assessment reports, and attestations about critical subcomponents. DoD's CMMC framework requires an assessment pathway (self‑assessment or third‑party) depending on the contract; the November 10, 2025 effective date for certain CMMC rule elements already changed bid preparation timelines. Per FAR 19.502, small businesses can leverage mentor‑protégé agreements and joint ventures to meet heightened technical or supply pedigree requirements. The practical implication is immediate: update your proposal templates, SAM.gov representations, quality control plans, and flow‑down language to reflect expected DFARS clauses (e.g., provenance, counterfeit detection, CMMC compliance, and SPRS reporting).

DoD's CMMC framework requires contractors to maintain records of assessments and to ensure that covered contractor information systems meet NIST SP 800‑171 or organization‑defined parameters; contractors must be ready to present SPRS assessments when requested. According to GSA guidelines, contracting officers will increasingly insert DFARS solicitation provisions referencing SPRS and CMMC status as evaluation criteria, and Per FAR 19.502, small businesses can request size or scope accommodations but must document capability. The Department of Defense has published organization‑defined parameters for NIST SP 800‑171 Rev. 3 and issued class deviations on cybersecurity standards; these items are rolling and may be followed by DFARS clause insertions. The immediate checklist: map contracts with DoD exposure, determine required assessment level, schedule C3PAO assessments or prepare validated self‑assessments, and budget for remediation.

According to GSA guidelines, contractors must institutionalize compliance by integrating CMMC/SPRS status into proposal checklists, by adding provenance attestations to supplier agreements, and by keeping updated records in SAM.gov and SPRS. Per FAR 19.502, small businesses can use mentor‑protégé arrangements to share compliance capacity; the SBA offers counseling and sometimes funding to bridge capability gaps. Under OMB M-25-21, agencies expect auditable trails for decision‑making, so preserve evidence (assessment reports, supplier invoices, audit logs) for at least five years. DoD's CMMC framework requires proactive remediation and scheduled reassessments; contractors should budget annually for continuous monitoring (recommended $10K–$100K per year for mid‑sized firms). Practical steps: designate a compliance owner, run quarterly SPRS status checks, negotiate flow‑down clauses that permit supplier audits, and maintain a remediation roadmap tied to contract milestones.

Per FAR 19.502, small businesses can and should document capability gaps and mitigation in proposals; be explicit about vendor controls, subcontractor oversight, and contingency sourcing. The SBA reports that access to small‑business assistance programs can cut remediation time by 30–50% for qualifying firms. According to GSA guidelines, adopting standard templates for attestations and evidence collection reduces proposal production time and audit risk. DoD notices and DFARS changes emphasize supplier performance history via SPRS; track and proactively correct negative SPRS entries, and obtain written corrective action plans from subcontractors. Finally, under OMB M-25-21, treat cybersecurity and supply‑chain provenance as an operations requirement, not a one‑time bid item — move compliance into your baseline operating budget.