ARTICLE · 01 OCTOBER 2025

Government Shutdown Advisory: Summary Of Possible Lapse In Appropriations

Holland & Knight

Explore more from Holland & Knight

Much of the federal government is funded by 12 annual appropriations bills. Federal fiscal year (FY) 2026 begins on Oct. 1, 2025, and, if appropriations bills have not been enacted before that date...

United StatesGovernment, Public Sector

Holland & Knight

Author LinkedIn connections

Highlights

Much of the federal government is funded by 12 annual appropriations bills. Federal fiscal year (FY) 2026 begins on Oct. 1, 2025, and, if appropriations bills have not been enacted before that date or a temporary funding measure – known as a continuing resolution (CR) – has not been enacted, a gap (or lapse) in appropriations will occur.
Federal government shutdowns have a wide range of effects, the severity of which can depend on the shutdown's length and how the Office of Management and Budget (OMB) directs agencies to operate (or not operate) during a shutdown.
As of this writing, no FY 2026 appropriations bills have been enacted. Bicameral, bipartisan negotiations had begun on full-year appropriations for the Agriculture-FDA, Legislative Branch and Military Construction-Veterans Affairs bills. Though any final agreement on those bills will not be ready in time for Oct. 1, 2025, it could be enacted as part of a future CR.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Related Articles

DEI-Fined: Court Clarifies Scope Of Government Contractor DEI Executive Order To Reach Only Intentional Discrimination

United StatesGovernment, Public Sector

Arnold & Porter

ASBCA Rejects Government’s Attempt To Divide An Interrelated Delay Claim For Sum-Certain Purposes

United StatesGovernment, Public Sector

Peckar & Abramson, P.C.

US Targets Iranian Financial And Charity Networks Under Operation Economic Outcast

GlobalGovernment, Public Sector

Herbert Smith Freehills Kramer LLP

Treasury Proposes Expanded Rule On U.S. Outbound Investment

GlobalGovernment, Public Sector

Kelley Drye & Warren LLP

Democrats Win Big: What Companies Should Know Now About Coming Congressional Oversight – And What To Watch In The Weeks Ahead

United StatesGovernment, Public Sector

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

See more popular content from

Government, Public Sector

A Political Shakeup: Key Takeaways From The 2026 Midterms

Republicans entered the 2026 midterms defending narrow majorities in both the House and Senate. Democrats won commanding majorities in both chambers, expanding their electoral map...

United StatesGovernment, Public Sector

SBA Extends Deadline For Comments On Historic Overhaul Of Size Standards

The Small Business Administration has extended the comment period for two proposed rules that could dramatically reshape federal government contracting by significantly expanding the pool of entities eligible for small business set-aside procurements. With some size standard thresholds proposed to increase as much as tenfold, these changes would fundamentally alter the makeup of the small business contractor base.

United StatesGovernment, Public Sector

Crowell & Moring LLP

Tennessee 2026 Midterm Election Results: Blackburn Wins Governor’s Race Amid Congressional And Legislative Upsets

Tennessee's 2026 midterm elections brought unexpected shifts to the state's political landscape, with Marsha Blackburn winning the governorship by the narrowest margin in over a century and Democrats flipping six House seats despite Republican supermajority retention. The results set the stage for significant leadership changes and new policy priorities when the 115th General Assembly convenes in January 2027.

United StatesGovernment, Public Sector

Bass, Berry & Sims PLC

D.C. Circuit Rules Pentagon Can Exclude Anthropic From Supply Chain

The U.S. Court of Appeals for the D.C. Circuit has ruled that the Department of War can exclude Anthropic from its supply chain under the Federal Acquisition Supply Chain Security Act, finding that the AI company's ability to manipulate its Claude model creates a supply chain risk. This decision contrasts with an earlier California district court ruling that blocked a similar designation under a different statute, creating a complex legal landscape for AI providers and government contractors.

United StatesGovernment, Public Sector

Taft, Stettinius & Hollister LLP

When Can Congress Refuse To Seat A Duly-Elected Candidate?

Never. In 1969, the U.S. Supreme Court ruled that the Speaker of the House could not exclude a duly-elected candidate for the U.S. House of Representatives.

United StatesGovernment, Public Sector

Holland & Knight

State AG News: Consumer Fraud And Deceptive Practices (October 1-7, 2026)

State attorneys general across the nation are taking decisive legal action on multiple fronts, from challenging federal fuel economy rollbacks to pursuing pharmaceutical companies over misleading drug claims. This week's enforcement activities reveal coordinated multistate efforts alongside individual state actions targeting consumer protection, national security concerns, and social media platform accountability.

United StatesGovernment, Public Sector

Crowell & Moring LLP

BIOSECURE Act Update: Court Enjoins WuXi AppTec’s 1260H Designation, but Strategic and Compliance Clocks Keep Running

The U.S. District Court for the District of Columbia has preliminarily enjoined the Department of War from enforcing WuXi AppTec's Section 1260H designation, finding the agency misread its evidence on state and military affiliation. However, this ruling does not close alternative pathways to biotechnology company of concern (BCC) designation under the BIOSECURE Act, and earlier supply-chain restrictions continue to drive near-term compliance decisions with a critical June 30, 2027 deadline for sub-tier supp

United StatesGovernment, Public Sector

Greenberg Traurig

Sanctions Update: October 19, 2026

This comprehensive sanctions update examines the US delisting of Venezuelan politician Jorge Rodriguez amid diplomatic negotiations and energy sector expansion, while tracking global sanctions developments including new US restrictions on Iranian banks, UK measures targeting hostile Iranian activities, EU designations for sanctions circumvention, and China's proposed export controls on advanced technologies.

GlobalGovernment, Public Sector

Cannabis And The Midterm Elections

The vast majority of Americans support legalizing marijuana in some way, which has been the case for years now. Whether that general support translates into ballot measure victories and wins for cannabis-friendly candidates, remains to be seen. Below are some notes on our coming elections, from U.S. Senate seats on down.

United StatesGovernment, Public Sector

Harris Sliwoski

FMCSA MOTUS Implementation – Common Motor Carrier Concerns

The Federal Motor Carrier Safety Administration launched MOTUS in May 2026, replacing legacy registration platforms and fundamentally changing how motor carriers, freight brokers, and surface freight forwarders handle operating authority applications and license maintenance. While designed to combat fraud and streamline registration activities, the transition has created significant user experience challenges that threaten operating authority status and customer relationships for transportation service prov

United StatesGovernment, Public Sector

Benesch, Friedlander, Coplan & Aronoff LLP