Under a newly enacted law, beginning June 30, 2026, defense contractors risk losing all future contracts with the Defense Department if they engage outside consultants that lobby for certain Chinese companies. On December 23, 2024, President Biden signed the National Defense Authorization Act (“NDAA”) for Fiscal Year (“FY”) 2025, which sets annual spending and policy for the Pentagon. While media coverage has largely focused on other provisions of the FY 2025 NDAA, buried within its 794 pages is a short provision governing defense contractors’ use of outside consultants.
In this alert, we summarize Section 851 of the bill, titled “Prohibition on Contracting with Covered Entities that Contract with Lobbyists for Chinese Military Companies.”