News & Analysis as of

Rule of Two

PilieroMazza PLLC

Weekly Update for Government Contractors and Commercial Businesses – October 2025 #2

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Long-Awaited Release of FAR Part 19: New Rule of Two and More - On September 26, 2025, the Federal Acquisition Regulatory Council released the much-anticipated rewrite of Federal Acquisition Regulation (FAR) Part 19,...more

PilieroMazza PLLC

Long-Awaited Release of FAR Part 19: New Rule of Two and More

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On September 26, 2025, the Federal Acquisition Regulatory Council released the much-anticipated rewrite of Federal Acquisition Regulation (FAR) Part 19, formerly titled Small Business Programs, as part of the broader...more

Bass, Berry & Sims PLC

FAR Part 19 Rewrite: Key Developments for Small Business Contracting

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The Federal Acquisition Regulatory (FAR) Council recently released its long-awaited overhaul of FAR Part 19, the section governing small business programs. While the rewrite is part of the Trump administration’s broader...more

Holland & Knight LLP

A New Era for Small Business: Key Takeaways from the FAR Part 19 Rewrite

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As part of its Revolutionary FAR Overhaul (RFO), the Federal Acquisition Regulation Council (FAR Council) on Sept. 26, 2025, issued its long-awaited update to FAR Part 19, which governs the small business program. FAR Part 19...more

Schwabe, Williamson & Wyatt PC

FAR Part 19 Revisions Released: Updates to Small Business Programs

The FAR Council is undertaking a systematic approach to revising the FARs. On September 26, 2025, it released its revisions to FAR Part 19, Small Business Programs. ...more

PilieroMazza PLLC

Weekly Update for Government Contractors and Commercial Businesses – September 2025 #3

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CMMC Is Here—What It Means for Defense Contractors - The Cybersecurity Maturity Model Certification (CMMC) Program is finally here. A final rule establishing the CMMC Program at Title 32 of the Code of Federal Regulations...more

PilieroMazza PLLC

OMB Seeks to Revise the Small Business Act – Another Shot at the Rule of Two

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Concerns are mounting that the Revolutionary FAR Overhaul will eliminate the regulatory “Rule of Two” found in FAR Part 19. Now, the Office of Management and Budget (OMB) is going further—seeking to narrow the reach of the...more

Pillsbury - Bid Protest Debrief

Risk Too High? GAO Says You Don’t Have to Bid

In Protection Strategies Etc. International, LLC, B-423539 (Aug. 25, 2025), Protection Strategies, a service-disabled veteran-owned small business (SDVOSB), filed a pre-award protest challenging the terms of a solicitation...more

Bass, Berry & Sims PLC

Small Business Alert – Possible End for the Rule of Two?

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The federal government’s commitment to supporting small businesses through procurement remains strong, but the shape and scale of that support may soon look very different. In accordance with recent executive orders, sweeping...more

PilieroMazza PLLC

FAR Part 6 Rewrite: What It Means for Small Business Set-Asides, Socioeconomic Programs, and the Rule of Two

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The recent rewrite of the Federal Acquisition Regulation (FAR) Part 6—governing “Competition Requirements”—is prompting questions about whether the changes may signal a shift in federal small business contracting policy. In...more

PilieroMazza PLLC

Weekly Update for Government Contractors and Commercial Businesses – July 2025 #4

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A True Path to Making America Great: Supporting Small Businesses and the Rule of Two - Recently, there has been a good deal of speculation about whether the so-called “Rule of Two” will continue to exist after the Federal...more

PilieroMazza PLLC

A True Path to Making America Great: Supporting Small Businesses and the Rule of Two

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Recently, there has been a good deal of speculation about whether the so-called “Rule of Two” will continue to exist after the Federal Acquisition Regulation (FAR) overhaul that is currently ongoing. Specifically, whether FAR...more

Schwabe, Williamson & Wyatt PC

Potential Impacts of Trump’s DEI Executive Order on SBAs, Alaska Native Corporations, ‎and Tribes

On January 20, President Donald Trump issued an executive order titled “Ending Radical and Wasteful Government DEI Programs and Preferencing.” The order states that it ends “all discriminatory and illegal preferences,...more

Schwabe, Williamson & Wyatt PC

SBA’s Rule-of-Two Proposal Targets Increased Small-Business Set-Asides

On October 25, the Small Business Administration proposed a rule intended to increase small business participation in multiple-award contracts. The rule would apply the “Rule of Two” to task and delivery orders issued under...more

Maynard Nexsen

SBA Issues Proposed Rule to Require "Rule of Two" for Orders Under Multiple Award Contracts

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Today, the Small Business Administration issued a proposed rule that would expand the application of the "rule of two" (for small business) to orders under multiple award contracts. The proposed rule is welcome news for small...more

Sheppard Mullin Richter & Hampton LLP

What Are the 2022 Small Business Set-Aside Thresholds?

As we head into the new year, it seems like a good time to check-in on the adjusted small business set-aside thresholds for 2022. As you may recall, the threshold are tied both to the micro-purchase threshold and the...more

Bass, Berry & Sims PLC

COFC: “Rule of Two” Must Be Analyzed Before “Any” Acquisition

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The Court of Federal Claims (COFC) recently affirmed that agencies are required to apply the “Rule of Two” to all federal acquisitions in its decision of Tolliver Grp., Inc. v. United States. Further, agencies must give a...more

Morrison & Foerster LLP - Federal Circuitry

Last Week in the Federal Circuit: Waiver and Constitutional Avoidance

The Federal Circuit issued just one precedential opinion last week.  But it’s an interesting one:  The Court exercised its discretion to reach (or rather, avoid) a constitutional issue not pressed or passed upon by the trial...more

Holland & Knight LLP

February 2020 Small Business Roundup

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Veteran-Owned Business Priority - In 2016, the U.S. Supreme Court surprised many by hearing a bid protest concerning the application of the "Rule of Two" for veteran-owned small businesses in procurements run by the U.S....more

Bradley Arant Boult Cummings LLP

Protest Sustained: VA Based “Rule of Two” Determination on Canceled Set-Aside Solicitation

The Government Accountability Office (GAO) recently sustained a protest that challenged the Department of Veterans Affairs’ (VA) failure to set aside an acquisition for Service-Disabled Veteran-Owned Small Businesses (SDVOSB)...more

Holland & Knight LLP

GAO Rules That Kingdomware "Rule of Two" Does Not Govern Leasehold Acquisitions Conducted by GSA on Behalf of VA

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The U.S. Government Accountability Office (GAO) ruled on Dec. 20, 2019, that the "Rule of Two" of the Veterans Benefits, Health Care, and Information Technology Act of 2006 (VBA) does not require the U.S. General Services...more

Pillsbury Winthrop Shaw Pittman LLP

Government Fails Again to Apply the VA Rule of Two

GAO has decided that the Rule of Two is mandatory and universal, and that it applies even when the VA seeks to acquire goods and services through other government agencies. Another attempt by the VA to limit the...more

Sheppard Mullin Richter & Hampton LLP

Veterans Are First at the VA Following New Class Deviation Implementing Recent Federal Circuit Mandate

In its most recent attempt to strike the appropriate balance between the Veterans First and AbilityOne programs, the U.S. Department of Veterans Affairs (“VA”) issued on May 20, 2019 a class deviation to the VA Acquisition...more

Bradley Arant Boult Cummings LLP

The 3 Most Important Bid Protest Decisions Of 2018 - Law360

In 2018, three particularly important decisions were issued that will have a significant impact on bid protest law for years to come: Dell Federal Systems LP v. United States, PDS Consultants Inc. v. United States, and Oracle...more

Sheppard Mullin Richter & Hampton LLP

Federal Circuit Affirms Veteran-Owned Small Businesses Are the VA’s First Priority

The U.S. Court of Appeals for the Federal Circuit recently affirmed a May 2017 Court of Federal Claims decision requiring the U.S. Department of Veterans Affairs (“VA”) to give veteran-owned small businesses first priority...more

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