Federal Pipeline Watch: Q1 2026 Signals
Is your capture strategy built for 2025—or the market that's actually moving in 2026?
The defense contracting landscape shifted significantly in December. New legislation, enforcement deadlines, and billion-dollar programs are reshaping where opportunities are—and who's positioned to win them. Here's what small business executives need to know right now.
FY26 NDAA: The Most Contractor-Friendly Reforms in Decades
President Trump signed the FY2026 NDAA in December, authorizing over $900 billion for DoD. For small businesses, the signal is clear: barriers are dropping.
Key changes:
- Past performance flexibility — Section 824 now allows agencies to consider commercial and non-government project experience, opening doors for contractors with strong private-sector track records but limited federal history
- TINA threshold raised — Certified cost or pricing data now required only above $10 million (up from $2.5 million), reducing compliance burden for growing contractors Mondaq
- CAS threshold raised — Cost Accounting Standards now exempt contracts below $35 million (up from $2.5 million), eliminating a major compliance hurdle
- Commercial solutions expanded — Section 1823 allows Commercial Solutions Openings for general acquisition, not just "innovative" solutions, with sole-source follow-on authority
- Best value over lowest cost — DoD GSA Schedule purchases now prioritize best value instead of lowest overall cost
The decision: Are you updating your capture approach to leverage these reforms—or competing under old assumptions?
CMMC 2.0: Phase 1 Is Live—Phase 2 Is Coming
CMMC enforcement began November 10, 2025. Phase 1 runs through November 2026, requiring Level 1 and Level 2 self-assessments with affirmations in SPRS. ERP Today Phase 2 begins November 10, 2026 with mandatory C3PAO assessments for Level 2.
More than 220,000 contractors and subcontractors are now directly impacted. Accorian C3PAO capacity is constrained—even contractors ready today may not get assessed until well into 2026.
The decision: Are you CMMC-ready and in the C3PAO queue—or still treating this as a future problem?
Golden Dome: $151 Billion in Play
The Missile Defense Agency has approved over 2,440 companies to compete under the SHIELD contract vehicle, worth up to $151 billion through 2035. Defense One Cost estimates for the full Golden Dome program range from $175 billion (White House) to over $800 billion (CBO).
Work areas include hypersonic defense, space-based sensors and interceptors, command-and-control, and directed energy. Gen. Michael Guetlein indicated Golden Dome will have some operational capability by mid-2028 Potomac Officers Club, meaning development contracts are accelerating now.
The decision: Are you positioned on SHIELD or teamed with a prime who is—or watching from the sidelines?
SBIR/STTR: Frozen but Not Dead
SBIR and STTR authority lapsed September 30, 2025. Agencies cannot issue new solicitations or awards until Congress reauthorizes. Ebhoward Reauthorization is expected to attach to appropriations legislation, with the January 30 funding deadline creating potential movement. Ebhoward
Competing bills remain unresolved—ranging from a clean one-year extension to major structural reforms. NSBA If you've relied on SBIR/STTR for R&D funding, build contingencies.
The decision: Are you tracking alternative R&D funding paths—or waiting on Congress?
What This Means for Your Q1 Strategy
- Leverage the NDAA reforms — Update your past performance narratives to include commercial work; reassess pricing strategies given higher TINA thresholds
- Accelerate CMMC — Phase 2 third-party assessments start in November; the queue is already building
- Monitor Golden Dome task orders — SHIELD is active; position now or team with primes building their benches
- Diversify R&D funding — Don't wait on SBIR/STTR; explore BAAs, OTAs, and agency-specific programs
The signals are clear. The question is whether you're reading them.
— Miranda Bouldin Defense Signals: Intel for Better Decisions
Short Page Description:
Federal Pipeline Watch: Q1 2026 Signals
Preview: NDAA reforms. CMMC enforcement. Golden Dome contracts. SBIR limbo. The signals shaping Q1—and we are tracking!
