Defense Issues

Europe has switched to a wartime mindset and is surging defense spending to levels not seen since the Cold War: 20% growth in 2024 and in 2025, and a total of around $450 billion across the EU. Europe is also ramping up defense production locally, and seeking to accelerate this process through preferential funding schemes. Ukraine has become a military powerhouse and a global leader in defense tech, such as drones and counter-drone systems. And the tech Ukraine has other countries need, particularly in the Middle East. The upcoming NATO summit in Ankara in July and the prospective EU-GCC summit later this year in Saudi Arabia will continue to shape investment priorities across EMEA. For private equity firms, technology companies, prime defense contractors, and scale-ups operating in the defense sector, this shift creates opportunities to meet rising demand, while also introducing additional regulatory complexity that must be navigated carefully to secure market access and long-term strategic positioning.

Continue Reading Future of Defense Across EMEA

On March 13, 2026, President Trump issued an Executive Order (EO) titled “Adjusting Certain Delegations Under the Defense Production Act.”  As we have covered in prior blog posts, the Defense Production Act (DPA) has traditionally been considered the primary federal means to manage and support defense production. 

The March 13th EO seeks to clarify and define certain aspects of two prior DPA-related EOs—EO 13603, “National Defense Resources Preparedness,” dated March 16, 2012, and EO 14156, “Declaring a National Energy Emergency,” dated January 20, 2025.  As such, the new EO is best understood in light of these two prior, related EOs.

Continue Reading “Adjusting Certain Delegations”:  New Executive Order Aims to Streamline and Clarify Delegated Authorities Under the Defense Production Act

Massachusetts aims to be the “cornerstone of the defense industry,” with Governor Maura Healey announcing nearly $47 million in government funding for defense-related projects.  Last year, the Department of Defense ranked Massachusetts ninth out of the top ten states in total Defense spending in FY2023, and the state is aiming

Continue Reading Massachusetts Seeks to Expand Defense Footprint with Nearly $47 Million in New Projects

Two cornerstone authorities for federal contracting quietly expired on September 30, 2025, creating ripple effects that contractors—small and large—cannot afford to overlook.  The Small Business Innovation Research/Small Business Technology Transfer (“SBIR/STTR”) programs, commonly known as “America’s Seed Fund” for their role in fueling early-stage innovation, and the Defense Production Act (“DPA”), the backbone of the government’s ability to prioritize contracts and strengthen the industrial base, both lapsed at the close of the fiscal year.  Although lawmakers have floated temporary or long-term fixes in pending legislation, nothing has yet been enacted.  The simultaneous government shutdown further complicates the picture, making new awards unlikely in the near term and magnifying uncertainty for contractors who rely on these authorities.

Continue Reading Expired:  SBIR/STTR and DPA Authorities in Limbo

This is the sixth blog in a series of Covington blogs on cybersecurity policies, executive orders (“EOs”), and other actions of the Trump Administration.  The fifth blog is available here and our initial blog is available here.  This blog describes key cybersecurity developments that took place in July 2025. 

Continue Reading July 2025 Cybersecurity Developments Under the Trump Administration

On May 29, 2025, the European Union established its new €150 billion defense fund through the Security Action for Europe (SAFE) regulation.  The European Commission will soon launch a call for interest for SAFE loans and EU Member States will have up to two months to submit their

Continue Reading Launching 150 billion euro for defense and technology
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The Government Accountability Office (“GAO”) released a report on the Defense Contract Audit Agency’s (“DCAA”) past and future use of private-sector, independent public accountants to augment its auditor workforce. The initiative—approved under Section 803 of the Fiscal Year (“FY”) 2018 National Defense Authorization Act (“NDAA”)—began in fiscal year 2020 and

Continue Reading GAO: DCAA Built a Valuable Bench of Independent Public Accountants, Now What?

In March 2025, the European Union published a white paper for European Defense Readiness 2030, which identifies defense needs and envisions a massive €800 billion four-year “ReArm Europe” investment plan. This initiative is a significant step change from the EU’s prior defense industrial strategy and earlier funding programs.

Rearming Europe would be financed by €150 billion in EU common debt made available as loans to Member States and €650 billion in national spending that EU fiscal rules would not constrain. This new package is intended to support EU Member State efforts to ramp-up defense capabilities and, if implemented, it would effectively double the overall amount of defense spending in Europe. Covington is working with clients in defense industry sectors across the wider West to maximize business opportunities created by this new funding.

Unleashing Europe’s Defense Potential

Given the “rapid deterioration of the geopolitical context and rising tensions,” the white paper pledges to unleash the EU’s resources and latent industrial and technological power on defense. It aims to swiftly increase support for Ukraine and deter Russia’s further aggression, while reducing dependency on U.S. military support. Further, it paves the way to tackle long-term security threats such as the “systemic” challenge posed by China and growing hybrid threats.

The EU seeks to support collaborative capability development among Member States, to enhance coordination and generate economies of scale.  Here, joint procurements will be a privileged tool, notably by setting up a European Military Sales Mechanism. This mechanism will support manufacturing capabilities and deliver more complex projects through aggregated demand and increasing predictability for the sector. To do so, it will incentivise long-term common procurements, as envisioned also by the European defense common procurement act.

In the near-term, investments and procurements on defense industrial capabilities will focus on rebuilding Europe’s depleted stocks of military hardware and equipment. Key capability domains include air and missile defense, artillery systems, ammunition and missiles, drones and counter-drone systems, military mobility, artificial intelligence, quantum, cyber & electronic warfare, strategic enablers and critical infrastructure protection.

To quickly expand its defense capabilities, Europe is also exploring strengthening its defense industrial collaboration with trusted partners such as the Republic of Korea, Norway, and Japan (with which the EU signed Security and Defence Partnerships last year), as well as its traditional allies and partners, such as the United Kingdom and the United States.

Continue Reading Rearming Europe with Trusted Partners

On April 9, 2025, President Trump issued an Executive Order (“EO”), “Modernizing Defense Acquisitions and Spurring Innovation In the Defense Industrial Base,” that may have significant implications for federal government contractors doing business with the Department of Defense (“DoD”), and particularly those with touchpoints to Major Defense Acquisition Programs (“MDAPs”).

The EO requires DoD to take a number of actions, including:

  • Within 60 days (i.e., June 8th), the Secretary of Defense must submit to the President a plan to reform the DoD acquisition process to eliminate inefficiencies.  The plan must prioritize commercial solutions and the use of Other Transactions Authority (“OTA”) agreements and Rapid Capabilities Office mechanisms.  The plan must also eliminate redundant tasks and approvals, centralize decision-making, and incorporate effective risk management for all acquisition programs through a governance structure referred to as a Configuration Steering Board. 
  • Under no specified timeline, DoD is generally directed to revise internal regulations and implementation guidance — including the DoD Financial Management Regulation and the Defense Federal Acquisition Regulation Supplement — utilizing the principle from the “Unleashing Prosperity Through Deregulation” EO (Jan. 31, 2025) that for every new regulation proposed, ten existing regulations should be repealed.
  • Within 90 days (i.e., July 8th)the Secretary of Defense must review all MDAPs and consider for “potential cancellation” programs that are: (1) more than 15% behind schedule; (2) more than 15% above cost; (3) “unable to meet key performance parameters”; or (4) otherwise not aligned with DoD mission priorities.  Following this review of MDAPs, the Secretary of Defense will conduct a similar review for all remaining major systems.
  • Within 120 days (i.e. August 7th)the Secretary of Defense, in collaboration with the Military Departments, must propose a plan to overhaul the defense acquisition workforce by restructuring performance metrics, assessing workforce sizing requirements, and deploying expert-led field training teams to enhance familiarity with innovative acquisition authorities.  These reforms are intended to incentivize prudent risk-taking and expand the workforce’s fluency in commercial solutions and adaptive acquisition strategies.  
  • Within 180 days (i.e., October 6th), the Secretary of Defense, acting through the Deputy Secretary of Defense, the Secretaries of the Military Departments and the Joint Chiefs of Staff, must complete a comprehensive review of the Joint Capabilities Integration and Development System (“JCIDS”), with the aim of streamlining and accelerating acquisition.[1] 

We address the EO’s directives for acquisition process reform and MDAP review in greater detail below. 

Continue Reading Trump Administration Issues Executive Order Aimed At Modernizing Defense Acquisitions And Spurring Innovation