How does a DHS shutdown affect existing DHS and CISA IT/cybersecurity contracts? 2026

According to GSA guidelines, contractors must prepare written impact records and continuity plans immediately when a lapse is announced. This means logging daily staffing levels, deliverable delays, incurred costs and any government communications about stop-work directions; GSA, SBA and FAR guidance emphasize contemporaneous documentation to support future equitable adjustment claims. Federal News Network reporting on the 2026 DHS contingency shows CISA moved most non-excepted staff to furlough status, which immediately reduced invoice processing, access to authorizing officials and approvals for contract modifications. Contractors supporting cloud, incident response or continuous monitoring should note FedRAMP authorizations and CISA points of contact may be unavailable, and that failure to capture approvals and email chains increases risk of denied claims. The opening record should include contract number, CLINs affected, estimated daily cost burn, number of cleared staff unavailable, and the dates and times of any government stop-work orders. Per FAR, contemporaneous records and immediate written notices to the contracting officer are primary evidence for Requests for Equitable Adjustment (REA) or claims under the Contract Disputes Act.

Per FAR 19.502, small businesses can rely on set-aside protections but still face unique risks during a DHS shutdown; small business subcontractors must maintain SAM.gov registration and be ready to submit required notices. The SBA reports that many small contractors depend on cash flow from milestone payments and may lack reserves for multi-week payment interruptions. According to GSA guidance, prime contractors that are small businesses should notify their contracting officer and the SBA immediately of performance impacts and track downstream subcontractor costs. Per FAR clauses on payments and invoice certification, contractors should continue to certify work performed only when they have verifiable evidence, and they must not falsely certify progress. For HUBZone, 8(a), WOSB and SDVOSB firms, Per FAR 19.502 and SBA guidance, maintaining demonstrated ability to perform and communication records is essential to preserve small business status for future awards.

The SBA reports that 78% of small federal tech contractors report cash-flow sensitivity to even two-week invoice delays; this statistic underscores why immediate action is required. Under OMB M-25-21, agencies will prioritize continuity for essential cloud and identity systems, but non-excepted cybersecurity support functions can still be paused, creating gaps in patching and monitoring. DoD's CMMC framework requires continuous cybersecurity hygiene for DoD-connected systems; while CISA and DHS programs are not CMMC-governed directly, similar continuity obligations mean lapses can increase downstream vulnerability and compliance risk. According to Nextgov, CISA’s decision to furlough the bulk of staff in 2026 reduced its ability to process interagency agreements and reimbursements, so contractors should assume longer lead times for approvals. Per FAR and OMB guidance, preserving logs, time-stamped emails and automated ticketing records will be critical evidence for any cost-recovery action.

According to GSA guidelines, contractors must expect slower invoice processing, paused vouchers and delayed modifications when DHS components enter shutdown status. GSA advises contractors to continue charging allowable costs to the contract with contemporaneous documentation while refraining from performing non-excepted work without written direction. Per FAR, the Stop-Work Order clause and the Suspension of Work provisions allow contracting officers to direct pauses; those clauses also preserve contractor rights to schedule relief and equitable adjustment. OMB guidance on continuity and cash management requires agencies to prioritize activities tied to health, safety and national security, but that leaves a broad set of IT and cyber services vulnerable to delay. Contractors should inventory every contract clause relevant to payments—FAR 52.232-1 (Payments), FAR 52.232-25 (Prompt Payment) and FAR 52.242-15 (Stop-Work Order)—and map which CLINs rely on agency-authorized approvals. Maintaining a single, centralized incident folder for the shutdown will speed later claim preparation and discussions with contracting officers.

Per FAR 19.502, small businesses can and should use SBA assistance programs and FAST lanes for dispute help, but they must meet procedural timing rules. GSA-managed schedule contractors should alert their GSA contracting officer and HCA about anticipated delays and document any inability to access federal systems caused by furloughs. The SBA and GSA both recommend preserving access logs, timesheets and automated ticket exports as proof of disruption; those records are often decisive when contracting officers evaluate Requests for Equitable Adjustment. Under OMB continuity policies, agencies may issue limited funding authorizations for emergency work; contractors should request written authorization and track every expense. Contractors that rely on FedRAMP-authorized cloud services should verify that FedRAMP P-ATO contacts remain available or that a continuity POC is assigned to avoid lost access that could impede work tied to DoD or DHS systems.

The SBA reports that 78% of small contractors say they would need at least 30 days of reserves to survive a major agency shutdown, so immediate cash forecasting is essential. Under OMB M-25-21, agencies will continue to prioritize identity, security and cloud operations, but less-critical cybersecurity deliverables can be deferred; contractors should proactively ask for written determinations of essential status. DoD's CMMC framework requires documented continuous controls; while that is DoD-focused, contractors that support both DHS and DoD must maintain audit trails even through a DHS hiatus. According to Federal News Network and Nextgov, CISA’s 2026 furlough removed many authorizing officials, making formal modification approvals unlikely for weeks; contractors should therefore prepare suspension-of-work cost models and be ready to file contract claims under the Contract Disputes Act if negotiated relief is not provided.