New Requirements For DoD Consulting Contractors

Bottom Line Up Front

On October 24, 2025, the Department of Defense (DoD) DFARS Case 2024-D007 ("the final rule") goes into effect, which amends the Defense Federal Acquisition Regulation Supplement (DFARS) to address national security concerns that may arise when a company provides consulting services to both the DoD and a foreign adversary. Going forward, a company that is providing or seeking to provide management, scientific, and technical consulting services to the DoD must now certify that neither it, nor its affiliates or subsidiaries, are providing consulting services to covered foreign entities. If they cannot make this certification, the company will need to have an approved conflict-of-interest mitigation plan in order to be awarded a DoD contract. The final rule and the DFARS amendment are intended to ensure that contractors advising the DoD are not simultaneously involved in activities that could negatively impact U.S. national security interests.