SEPTEMBER 2026 EDITION

The fiscal year ends, and the money does not.

The shutdown that suppliers spent August planning around did not happen. Congress passed a continuing resolution and the President signed it on September 2, funding the government through December 11. What replaces the October 1 cliff is quieter and easier to misread: an October that is thin by law rather than by weak demand, a set of defense-specific limits on what can be bought at all, and a CMMC pause that is now firmly in place while the liability underneath it is not.

October will be quiet, and that is statutory.

September 30 is your customer's deadline, not DLA's.

The Part 13 rewrite closes for comment on October 19.

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October will be quiet, and that is statutory.

Three provisions of the continuing resolution suppress early-year obligations. A quiet board in the first weeks of October is the law working as written, not demand disappearing.

September 30 is your customer's deadline, not DLA's.

DLA buys through a revolving fund that carries no fiscal year limitation. The rush comes from the services whose money does expire.

The Part 13 rewrite closes for comment on October 19.

The Federal Register batch published September 18 rewrites the simplified acquisition rules that DIBBS quotes run under.

Regulatory and policy watch

The CMMC Phase 2 pause is settled for this fiscal year. Class Deviation 2026-O0025, Revision 3, signed by John M. Tenaglia on September 3, 2026, carries forward the direction first made binding in Revision 2 on July 16: contracting officers are to work with requiring activities to remove or revise CMMC requirements in new and existing solicitations and contracts. Active solicitations are to be amended as soon as practicable, and existing contracts are to have the requirements removed by modification before the next option is exercised. The Department of War CIO page still displays the July 13 announcement of the immediate suspension of Phase 2, originally scheduled for November 10, 2026.

What survives the pause is the part that costs a small shop real work. The deviation permits requiring activities to keep Level 1 and Level 2 self-assessments. Baseline compliance with NIST SP 800-171 Revision 2 still applies under DFARS 252.204-7012, and offerors generally still need a current status and affirmation in the Supplier Performance Risk System to be eligible for award. The relief is the paid third-party assessment, not the homework.

That distinction has a price attached. On June 18, 2026 the Justice Department announced a $507,144 False Claims Act settlement with LOGZONE, Inc. of Huntsville, Alabama, over allegations of non-compliance with NIST SP 800-171 on Navy contracts, where the Defense Contract Management Agency assessed a score of negative 170. Vendors should treat the self-assessment as the enforceable document it is.

The 60-day CMMC reform review that began in July reached its deadline on September 11. Its report goes to the Department of War CIO, and as of September 21 it had not been made public.

The larger structural item is the FAR Council's overhaul of the regulation itself, the effort the Council tracks as the RFO. Four more proposed rules published on September 18, 2026, with comments closing October 19: 91 FR 59406, 91 FR 59476, 91 FR 59534 and 91 FR 59584. The first of those matters most to a DIBBS vendor, because it reaches FAR Parts 12 and 13. It proposes removing the omnibus provisions 52.212-3 and 52.212-5 from commercial acquisitions, and in the Council's words the changes "would also shift the burden of determining which provisions and clauses listed in 52.212-3 and 52.212-5 are applicable" toward the Government. It also proposes to "Transfer from FAR part 13 and streamline at FAR 12.201-1 the procedures for acquiring supplies and services" at or below the simplified acquisition threshold. Part 13 is the procedure most automated DIBBS quotes run under.

One correction to the August edition. The SAM.gov registration rewrite, FAR Case 2026-001, is not taking effect on October 1. The Defense Acquisition Regulations System open-cases list dated September 18 shows it still in process, so it will not touch FY2027 awards on that date.

On trade, a Presidential Memorandum signed September 16 and published September 21 directs the Office of Management and Budget and the United States Trade Representative to identify Canadian-origin items for removal from the federal procurement system. The memorandum does not itself change Canada's designated-country status, and suppliers with Canadian content should watch for the implementing guidance rather than act on the memorandum alone. Separately, a Bureau of Industry and Security temporary final rule effective August 27 requires sellers of tungsten waste and scrap and black mass to allocate their monthly sales to United States persons.

No DLA supplier-facing document changed this month. The Master Solicitation still reads Revision 105, dated May 20, 2026.

Budget and funding outlook

H.R. 6500 became Public Law 119-103 on September 2, after the Senate passed it 90 to 6 on August 8 and the House 370 to 48 on September 1. It funds all twelve regular appropriations bills from October 1 through December 11, 2026 at rates based largely on FY2026 enacted amounts. The Congressional Budget Office puts the annualized discretionary total at $1.701 trillion.

Three provisions explain why October is always slow. Section 104 bars starting or resuming programs not funded in FY2026. Section 109 bars obligations for accounts that would otherwise run at a high initial rate of operations. Section 110 requires agencies to take, in the statute's words, "only the most limited funding action" necessary to continue existing activities. Section 102 adds defense-specific limits: no new production of items not funded for production in FY2026 or earlier, and no acceleration of production rates above those sustained with FY2026 funds.

No FY2027 defense appropriations bill has passed either chamber. Any FY2027 defense figure in circulation is a proposal. The date to plan cash and delivery schedules around is December 12, when a funding gap would begin absent further action.

DIBBS market activity

The most useful thing a DIBBS vendor can know this week is that DLA's own buying money does not expire on September 30. DLA buys through the Defense-Wide Working Capital Fund, a revolving fund under 10 U.S.C. 2208, which the Congressional Research Service describes as generally operating without fiscal year limitation. The year-end surge is driven by DLA's customers, the military services, whose annual appropriations do expire.

The surge is real and it is measurable in public data. Computed from USAspending.gov on September 22, 2026, DLA obligated $10.24 billion on prime contracts in September of FY2025, against a full-year total of $55.94 billion. DLA's own Fiscal 2025 Annual Report puts contract obligations at $55.8 billion, within a third of a percent of the same figure. Roughly one dollar in six of DLA's contract obligations lands in a single month.

Actionable opportunities this month

Vendors should quote through the first half of October expecting a thin board, and should not read that thinness as lost demand. Vendors holding a solicitation that still carries a CMMC third-party requirement should expect an amendment and may reasonably ask the contracting officer about it. Vendors should confirm their Supplier Performance Risk System status and affirmation are current, and that the score behind them is defensible. Vendors quoting items tied to a program that was ramping in FY2027 should size quantities to FY2026 rates through December 11. Vendors with a view on how simplified acquisitions should work have until October 19 to say so on the record.

Contract award snapshot

September is DLA's heaviest obligation month by a wide margin, at $10.24 billion in FY2025 against a $55.94 billion year. The fourth quarter as a whole carries a disproportionate share. Awards placed in late September are frequently funded by customer money that had to be obligated before the year ended, which is why delivery schedules negotiated this month tend to be firm.

Looking ahead to October

Three dates. October 1 starts FY2027 under the continuing resolution, with the new-start and rate limits in force. October 19 closes the comment period on the four overhaul proposed rules, including the Part 13 rewrite. December 12 is when the current funding runs out, which is the date worth putting in a cash plan. The CMMC reform report may also surface, and if it does it will shape what replaces the current pause.