FY 2026 National Defense Authorization Act: A Comprehensive Holland & Knight Analysis

President Donald Trump on Dec. 18, 2025, signed into law the fiscal year (FY) 2026 National Defense Authorization Act (NDAA). It was passed by wide bipartisan margins in both the U.S. House of Representatives and Senate by votes of 312-112 and 77-20, respectively.

The law authorizes $900.6 billion for the U.S. Department of War (DOW), nuclear security programs at the U.S. Department of Energy (DOE) and related national security activities, roughly $8 billion above the presidential budget request. Spanning more than 3,000 pages, the legislation shapes procurement priorities and strengthens the defense industrial base.

The final agreement between the House and Senate Armed Services Committees strikes a balance between the Senate's $925.8 billion proposal, which was $33.2 billion higher than the presidential budget request, and the House's $892.6 billion measure, which largely tracked the administration's request. Signing this bill into law marks the 65th consecutive annual authorization and underscores one of the last enduring bipartisan efforts in Washington.

The theme and basis for the FY 2026 NDAA was defense acquisition reform. At the center of this policy debate was the Streamlining Procurement for Effective Execution and Delivery (SPEED) Act announced on June 9, 2025, by House Armed Services Committee (HASC) Chairman Mike Rogers (R-Ala.) and Ranking Member Adam Smith (D-Wash.) to restructure, streamline and modernize the DOW's acquisition system. In the Senate, the basis for the beginning point on defense acquisition reform was the Fostering Reform and Government Efficiency in Defense (FoRGED) Act, which was introduced in December 2024 by Senate Armed Services Committee (SASC) Chairman Roger Wicker (R-Miss.).

Tied to defense acquisition reform were other notable themes reflecting the current state of the U.S. armed forces and defense industry's technological innovations, including emerging technologies, drone and counter-drone legislation, shipbuilding and maritime reform, munitions production and modernization, defense industrial base investments and major weapons programs, including Golden Dome and hypersonics.

In addition to these more specific modernization priorities, improving service member quality of life remained a constant focus of the HASC and SASC and is reflected in the final bill. As such, the bill touched on all quality-of-life programs including healthcare, military pay, housing, and transition assistance.

Notable provisions were also omitted – namely, reauthorization of the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs, which are used by many in the defense industry.

Defense Acquisition Reform

The FY26 NDAA implements SPEED and FoRGED acts provisions to fix the slow and rigid defense acquisition system by prioritizing rapid delivery of cost‑effective capabilities. The NDAA reforms focus on accelerating requirements, centralizing program management and embedding sustainment planning early to avoid costly readiness gaps and overruns. Many of these provisions codify President Trump's Executive Order (EO) 14265, "Modernizing Defense Acquisitions and Spurring Innovation in the Defense Industrial Base," and DOW Secretary Pete Hegseth's acquisition reform strategy, "Transforming the Warfighting Acquisition System."

• Section 801 – Assumption of Uninsurable Risk on Certain Contracts: Requires the DOW to ensure that classified, fixed‑price contracts do not bear uninsurable losses for work‑in‑process when commercial insurance is unavailable. The government's assumption of loss is limited to amounts not covered by insurance and does not apply in cases of gross or willful misconduct.
• Section 802 – Changes to Certain Documents: Requires that any document in a DOW procurement contract include the applicable version and indicate whether a change was made after the initial solicitation.
• Section 811 – Repeals of Existing Law to Streamline the Defense Acquisition Process: This process amends or repeals 86 provisions in prior year NDAAs to streamline the defense acquisition process.
• Section 812 – Modifications to Current Defense Acquisition Requirements: Revises acquisition rules to prioritize "best value" instead of "lowest overall cost" and emphasizes "price competition." Furthermore, as assessment of alternative sources is required when sole-source awards are made.
• Section 813 – Modification to Award Amount for Program to Accelerate the Procurement and Fielding of Innovative Technologies: Raises the minimum award for the Accelerate the Procurement and Fielding of Innovative Technologies program to ensure awards are at least $10 million.
• Section 1801 – Alignment of the Defense Acquisition System with the Needs of Members of the Armed Forces: Requires the defense acquisition system to expeditiously provide the Armed Forces the capabilities needed to operate in the most cost‑effective manner possible. It also requires validation through direct engagement with service members. Civilian managers and executives focused on acquisition are instructed to balance cost and performance, relying on data analytics and prototypes to make informed decisions.
• Section 1802 – Establishment of the Role of Portfolio Acquisition Executive: Creates the position of Portfolio Acquisition Executive (PAE), a senior official to whom program managers report directly. The role is broad, with responsibilities that include streamlining accountability for defense acquisition objectives, engaging end users, conducting market research and integrating emerging technologies. This provisions transitions Program Executive Officers into PAEs, shifting DOW acquisition from program‑by‑program oversight to portfolio management.
• Section 1804 – Adjustments to Certain Acquisition Thresholds: Updates the statutory dollar thresholds for defining major defense acquisition programs, raising the cost levels that trigger requirements for competitive procedures or cost and pricing data submissions. The higher thresholds mean fewer programs will be subject to stringent requirements, reducing compliance burdens for smaller contractors.
• Section 1806 – Matters Related to Cost Accounting Standards: Raises threshold for full cost accounting standards coverage from $50 million to $100 million and restructures the Cost Accounting Standards (CAS) Board. It also requires the DOW to review and reduce CAS compliance requirements when Generally Accepted Accounting Principles can serve as a viable commercial accounting standard.

Defense Industrial Base

The FY26 NDAA fortifies the defense industrial base by deepening allied integration, expanding funding and hiring authorities for critical supply chains, and streamlining cybersecurity and technology‑transfer. A key provision requires the DOW to build a digital inventory of weapon‑system technical data to prevent sustainment gaps – representing a compromise from earlier "right to repair" language that would have mandated contractor disclosure of technical data for in‑house military repairs.

• Section 805 – Addressing Insufficiencies in Technical Data: This provision addresses the "right to repair" issue that the U.S. Congress and the administration have debated over the past few years. This provision requires the DOW to build a digital system that inventories the technical data and software needed to sustain major weapon systems. The legislative intent is to ensure that the DOW can effectively address sustainment problems by identifying where required data is insufficient and pursuing remedies (whether commercial or customized licenses) to prevent sustainment gaps. More specifically, the DOW is instructed to create an electronic platform that tracks what technical data was required to operate major weapon systems, whether the DOW possesses that data, and whether any missing or unusable data makes it harder or more expensive to operate a system. To remedy insufficiencies, the DOW must work with contractors by pointing out contractual requirements or requesting access agreements and negotiating direct licenses. The DOW must report to Congress every 90 days on the progress of this database. Note that this section explicitly states that the bill does not change intellectual property law or alter existing legal rights or government license authorities.
• Section 864 – U.S.-Israel Defense Industrial Base Working Group: Creates a U.S.-Israel Defense Industrial Base Working Group to study deeper integration and potential inclusion of Israel in the national technology and industrial base, with protections for sensitive information.
• Section 866 – Cybersecurity Regulatory Harmonization: Directs the DOW to harmonize cybersecurity rules for the defense industrial base by June 1, 2026.
• Section 867 – Modifications to Defense Industrial Base Fund: Authorizes use of the Defense Industrial Base for supply chain efforts regarding unmanned vehicles, power sources, batteries and other materials.
• Section 1086 – Framework for Reforming Technology Transfer and Foreign Disclosure Policies: Requires the War Secretary to produce a technology framework to revise transfer and foreign disclosure policies for artificial intelligence (AI), counter-unmanned aircraft systems (c-UAS), missile defense and other topics.
• Section 1108 – Definition of Defense Industrial Base Facility for Purposes of Direct-Hire Authority: Amends the FY17 NDAA direct‑hire definition to include supporting units of a facility at an installation or base, broadening which defense industrial base entities qualify for expedited hiring.
• Section 1112 – Modification of Direct Hire Authority for Domestic Defense Industrial Base Facilities: Expands direct‑hire authority for domestic defense industrial base facilities to include U.S. Navy Supervisor of Shipbuilding, Conversion and Repair positions.
• Section 1253 – Partnership for Indo-Pacific Industrial Resilience: Creates the Partnership for Indo‑Pacific Industrial Resilience to coordinate U.S. and allied efforts to strengthen defense industrial base capacity, supply‑chain resilience, R&D, co‑production and workforce in the Indo‑Pacific until 2031.
• Section 1844 – Collaborative Forum to Address Challenges to and Limitations of the Defense Industrial Base: Creates a DOW‑led collaborative forum to tackle defense industrial base supply‑chain, manufacturing, workforce and policy challenges, with annual briefings.
• Section 1847 – Report on Surge Capacity in the Defense Industrial Base: Requires DOW to report by March 1, 2026, on policies that discourage defense industrial base contractors from maintaining or investing in surge capacity and steps to address them.
• Section 2805 – Modification to Assistance for Public Infrastructure Projects and Services: Expands Military Base Reuse Studies and Community Planning Assistance authority to cover healthcare, housing and defense‑critical infrastructure projects and extends support to the defense industrial base, its workers and military installations.

Emerging Technology

The FY 2026 NDAA strengthens U.S. resilience in emerging technologies by securing critical materials, modernizing supply chains and expanding advanced manufacturing capacity. These provisions focus on rapidly deploying innovative, new technologies that service members need to prevail on future battlefields.

Advanced and Additive Manufacturing

• Section 849 – Prohibition on Procurement Related to Certain Additive Manufacturing Machines: Prohibits the DOW from contracting for additive manufacturing machines made by certain foreign or restricted companies, beginning one year after enactment. The ban applies to entities on the U.S. Department of Commerce Consolidated Screening List, civil‑military fusion list, or those domiciled in or controlled by a "covered nation" under Title 10.
• Section 871 – Modification to Demonstration and Prototyping Program to Advance International Product Support Capabilities in a Contested Logistics Environment: Requires demonstration and prototyping programs to incorporate advanced manufacturing facilities that can rapidly produce parts closer to where they are needed.
• Section 1841 – Civil Reserve Manufacturing Network: Establishes a Civil Reserve Manufacturing Network to quickly convert commercial manufacturing into defense production. DOW must identify barriers, build a national registry of capabilities and submit a plan to Congress, followed by an interim progress report at 540 days.
• Section 1842 – Transition to Advanced Manufacturing for Certain Critical Readiness Items of Supply: Requires project support managers to assess which critical readiness items can be produced with advanced manufacturing within 24 months, boosting supply and enabling rapid scaling.
• Section 1843 – Working Group on the Advanced Manufacturing Workforce: Directs the DOW to establish a working group on the advanced manufacturing workforce within 180 days to combat shortages in industrial base career fields.
• Section 1846 – Improvements Relating to Advanced Manufacturing: Instructs that the Joint Additive Manufacturing Working Group will be co-chaired by the Under Secretary of Defense for Acquisition and Sustainment and Under Secretary of Defense for Research and Engineering. This section also requires new guidance and testing for advanced manufacturing parts in the future.
• Section 2887 – Pilot Program on use of Advanced Manufacturing Construction Technologies at Military Installations: Launches a pilot program to test advanced manufacturing construction technologies (including 3D printing) on specific military installations, requiring an interim report and recommendations if the program should continue.
• Section 8802 – Alignment of Timing of Updates of Strategic Plan with Updates to National Strategy for Advanced Manufacturing: Requires that the strategic plan for advanced manufacturing be updated at least once every four years, instead of three, to ensure alignment with other planning cycles.

Critical Materials

• Section 867 – Modification to Defense Industrial Base Fund: Expands the Defense Industrial Base Fund for domestic production capacity, equipment, modernization and critical materials projects. This expansion now authorizes the fund to be used for microelectronics, machine tools, castings and forgings, unmanned and manned systems, ships and submarines, defense space systems, batteries, workforce and related infrastructure.
• Section 1411 – Modifications to Strategic and Critical Materials Stock Piling Act: Establishes a Stockpile Manager and strengthens the DOW's ability to acquire and store critical materials.
• Section 1412 – Recycling for Critical Minerals: Expands the Strategic Materials Recovery and Reuse Program for shortfall materials, including recycling and recovery of critical minerals. This provision promotes reuse of materials from defense systems to support long-term strategic supply security and reduce reliance on foreign sources.

Supply Chains

• Section 832 – Enhancement of Defense Supply Chain Resilience and Secondary Source Qualification: Strengthens the DOW's supply‑chain resilience by prioritizing production of critical readiness items, particularly those with long lead times or high prices. The bill also aims to speed up the qualification process for secondary suppliers to reduce overreliance on a single source. This provision now allows for civil aviation authority approvals for certain aircraft spares. Practically, this section creates Expedited Qualification Panels in each military department to fast‑track alternate supplier approvals. This panel should decide within 14 days whether to grant conditional approval (up to one year), full approval or disapproval, using tiered risk criteria. This provision generally accepts civil aviation authority approvals for many aircraft parts. The goal is to field alternate suppliers quickly to reduce single‑source risk while preserving full qualification for mission‑critical items.
• Section 834 – Strategy to Eliminate Acquisition of Optical Glass from Certain Nations: Requires the DOW to come up with a strategy as to how it will eliminate its reliance on optical glass manufactured by covered nations, including China, by 2030.
• Section 835 – Strategy to Eliminate Sourcing of Computer Displays from Certain Nations: Requires strategy to eliminate reliance on covered nations, including China, for computer displays by 2030.
• Section 836 – Voluntary Registration of Compliance with Covered Sourcing Requirements for Covered Products: This section establishes a voluntary online registry of suppliers compliant with U.S. sourcing laws, granting them procurement preference as trusted U.S. suppliers.
• Section 837 – Acceleration of Qualification of Compliant Sources: DOW must identify programs relying on noncompliant suppliers.
• Section 844 – Prohibition of Procurement of Molybdenum, Gallium or Germanium from Non-Allied Foreign Nations and Authorization for Production from Recovered Material: Adds molybdenum, gallium and germanium to the list of restricted strategic materials that cannot be sourced from adversary nations, including China. It allows exceptions for recycled material processed in the U.S. or allied countries.

Drones and Counter-Drones

The FY 2026 NDAA advances U.S. defenses against emerging unmanned threats by expanding training and testing infrastructure and establishing task forces and partnerships to strengthen c-UAS resilience across the armed services. At the same time, the bill enhances protections for critical facilities and integrates drones and counter‑drone measures into public safety and homeland security frameworks.

• Section 345 – Technology Enhancement for Surface Ship Maintenance: Requires the secretary of the Navy to investigate and adopt advanced technologies that improve Navy surface ship maintenance and prioritize drone-based inspection for uncrewed structural surveys.
• Section 817 – Review of DOW Instruction Relating to Conventional Ammunition Management: Requires the War Secretary to assess whether to modify "conventional ammunition" to include unmanned aerial vehicles and systems.
• Section 912 – Joint Interagency Task Force 401: Adds "Joint Interagency Task Force 401" to 10 USC Chapter 8, Subchapter 1 (Defense Agencies and DOW Field Activities – Common Supply and Service Activities), a task force to manage c-UAS efforts. The director of the task force will report to the Deputy Secretary of War and Chairman of the Joint Chiefs on counter-small, unmanned aircraft system matters. The task force will also be responsible for integrating c-UAS solutions at the DOW and coordinating interagency efforts for the developing, testing, evaluating and procuring counter-small unmanned aerial systems (sUAS).
• Section 914 – sUAS Industrial Base Working Group: Establishes a working group to analyze the sUAS supplier base and recommend investments. sUAS components include battery systems. This also includes the development of investment plans for the SkyFoundry initiative for the Army Materiel Command.
• Section 1048 – Authorization of Eastern Regional Range Complex for Multi-Domain Operations and Robotic Autonomous Systems Training, Testing and Experimentation: Authorizes the development of an Eastern Regional Range Complex to train, test and experiment with UAS and c-UAS capabilities.
• Section 1088 – Pilot Program on Enhanced Use of Advanced Sensor Networks to Improve Air Force c-UAS Capabilities for Base Defense: Establishes the ''Enhancing Cooperation for Counter-Unmanned Aircraft Systems Program'' to incorporate the use of civilian airspace sensor networks into U.S. Air Force data systems.
• Section 1089 – Pilot Program and Other Requirements for Accelerating Protection of Certain Facilities and Assets from Unmanned Aircraft: Establishes a pilot program to accelerate the protection of critical DOW facilities and assets from threats posed by UAS.
• Section 1232 – Extension and Modification of U.S.-Israel Cooperation to Counter Unmanned Systems in All Warfighting Domains: Extends and amends the existing U.S.-Israel defense cooperation program to address unmanned systems threats across all warfighting domains.
• Section 1707 – Protection of Certain Facilities and Assets from Unmanned Aircraft: Directs the DOW to implement measures to protect critical facilities and assets from UAS threats and authorizes c-UAS measures to mitigate unmanned aircraft threats.
• Section 3114 – Protection of Certain Nuclear Facilities and Assets from Unmanned Aircraft: Amends the Atomic Energy Defense Act to protect nuclear facilities from unmanned aircraft.
• Section 6502 – Improvements to Security of CIA Installations: Authorizes response and action for mitigating UAS threats to CIA installations.
• Section 7336 – Medium UAS Capabilities Study: Requires a study and report from the commandant on the feasibility of expanding the National Security Cutter's medium UAS capabilities to medium endurance cutters and offshore patrol cutters.
• Section 7338 – UAS: Amends the U.S. Coast Guard's (USCG) functions and power by authorizing UAS operations within the USCG.
• Section 8602 – Drone Countermeasures to Protect Public Safety and Critical Infrastructure: Amends the Homeland Security Act of 2002 to include drone protection measures for critical infrastructure and public safety.
• Section 8603 – Use of Grant Funds for UAS and c-UAS: Amends the Omnibus Crime Control and Safe Streets Act of 1968 by authorizing UAS and c-UAS as eligible programs for federal funding.
• Section 8604 – Use of Grant Funds for Unmanned Aircraft: Amends the Omnibus Crime Control and Safe Streets Act of 1968 to authorize federal grant money to purchase and operate UAS to benefit public safety.
• Section 8606 – Rulemaking and Implementation: Requires the U.S. Department of Homeland (DHS) secretary to establish standards for training programs on the safe and lawful interception of drones.

Munitions

The FY 2026 NDAA authorizes more than $25 billion to rebuild the U.S. munitions arsenal and directs the U.S. Army to expand robotic automation in manufacturing for safety, efficiency and workforce training. The bill strengthens planning by requiring out‑year reporting, adding missile defense systems to requirements and assessing critical stockpiles for simultaneous conflicts. Finally, the bill grants multiyear procurement authority for key missile systems and blocks Army restructuring of munitions commands until Congress receives a detailed plan.

• Section 225 – Advanced Robotic Automation for Munitions Manufacturing: Directs the Army to expand robotic automation in munitions manufacturing to boost safety and secure factory integration and also requires workforce training through coordination by Army offices.
• Section 361 – Reporting Requirements for Out-Year Unconstrained Total Munitions Requirements and Out-Year Inventory Numbers: Requires the DOW to include adversary operational plans and allied demand in out‑year munitions planning and align production levels with future defense programs.
• Section 362 – Inclusion of Air and Missile Defense in Out-Year Unconstrained Total Munitions Requirement and Out-Year Inventory Numbers: Adds air and missile defense systems to the out‑year unconstrained munitions requirements.
• Section 363 – Reports on Munitions Response Projects at Sites Formerly Used by the DOW: Mandates regular reports on munitions response projects at former DOW sites, detailing contracts, delays and challenges.
• Section 364 – Report on Critical Munitions Required for Simultaneous Conflicts: Directs the DOW to report and plan for critical munitions stockpiles and production needed to fight simultaneous conflicts.
• Section 804 – Multiyear Procurement Authority for Covered Systems and Certain Munitions: Relatedly, the bill includes multiyear procurement authority for key munitions programs, allowing the armed forces to enter long‑term contracts for missiles and interceptors such as Patriot PAC‑3, THAAD, Tomahawk, JASSM, LRASM, SM‑3, AMRAAM and others so that the services can prepare for out-year investment.
• Section 917 – Limitation on Availability of Funds for the Army Pending Submittal of Plan on the Proposed Integration of the Joint Munitions Command and Army Sustainment Command: Blocks funds from being allowed to restructure the Joint Munitions Command and Army Sustainment Command until a Congressional report is submitted that includes a justification, an implementation plan and assessment of readiness effects.
• Section 4101 – Procurement: Authorizes more than $25 billion to rebuild America's arsenal, funding procurement of key missiles, torpedoes and artillery rounds including PrSMs, JAGMs, Naval Strike Missiles, Javelins, Stingers, Tomahawks, GMLRS, AMRAAMs, Sidewinders, LRASMs, JDAMs, MK‑48 torpedoes and more.

Shipbuilding and Maritime

The FY26 NDAA authorizes more than $26 billion for naval shipbuilding and $1.1 billion for the Maritime Administration. The bill strengthens the maritime industrial base by accelerating automated shipbuilding, expanding hiring and workforce authorities, and making adjustments in procurement.

• Section 1019 – Strategy for Navy Investment in and Support for the Maritime Industrial Base: Requires the Navy to develop a strategy within 180 days to strengthen the maritime industrial base and address shipbuilding cost and schedule challenges.
• Section 1021 – Pilot Program on Use of Automated Shipbuilding Technologies and Capabilities: Creates a three-year pilot program using automatic shipbuilding technologies to cut construction time and ease workforce strain.
• Section 1022 – Modification of Authority to Purchase Used Vessels Under the National Defense Sealift Fund: Increases the cap on the number of used vessels that may be purchased under the National Defense Sealift Fund, raising the limit from 10 to 12.
• Section 1045 – Limitations on Use of Funds to Relocate or Otherwise Remove the Maritime Industrial Base Program: Prohibits the use of funds to relocate or remove the Maritime Industrial Base Program from the jurisdiction of the Assistant Secretary of the Navy for Research, Development, and Acquisition.
• Section 1104 – Revisions to Limitations on Pay for Officers and Crews of Maritime Vessels Operated by or for the U.S.: Revises pay limits for officers and crews of U.S. maritime vessels, capping compensation at the vice president's rate.
• Section 1112 – Modification of Direct-Hire Authority for Domestic Defense Industrial Base: Expands direct-hire authority for domestic defense industrial base facilities to include Navy Supervisor of Shipbuilding, Conversion and Repair positions.
• Section 3501 – Authorization of Appropriations for Maritime Administration: The measure would authorize $1.1 billion for the Maritime Administration, a $145.5 million increase above the president's budget request.
• Section 4101 – Procurement: Authorizes over $26 billion for naval construction, including Columbia‑class and Virginia‑class submarines, DDG‑51 destroyers, the Ford‑class aircraft carrier, one anti‑submarine warfare auxiliary ship and two Ship‑to‑Shore Connector landing craft.
• Section 7218 – Procurement of Tactical Maritime Surveillance Systems: DHS must install maritime surveillance systems in key USCG sectors, but deployment from DOW property requires a joint DHS-DOW study confirming no national security risks.
• Section 7262 – Policy on Methods to Reduce Incentives for Illicit Maritime Drug Trafficking: Directs the USCG Commandant, in coordination with the U.S. Drug Enforcement Agency, U.S. Department of State and DOW, to develop within one year a policy to deter and interdict illicit maritime trafficking of controlled substances and precursors for synthetic drugs, consistent with U.S. and international law.
• Section 7263 – Plan for Joint and Integrated Maritime Operational and Leadership Training for U.S. and Taiwan Coast: Requires the USCG Commandant, with the State Department and DOW, to develop within 180 days a plan to expand joint training with the Taiwan Coast Guard Administration.
• Section 7331 – Pilot Program for Governance and Oversight of Small Uncrewed Maritime Systems: Establishes a pilot program within the DOW to create governance and oversight mechanisms for small uncrewed maritime systems.

Healthcare

The FY26 NDAA lowers barriers to care and strengthens medical governance. The bill protects medical manning, streamlines credentialing and deepens DOW‑U.S. Department of Veterans Affairs collaboration to better support veterans. There are also provisions that pilot supplemental cancer coverage and drives studies on health impacts from aviation and unmanned systems.

• Section 701 – Reimbursement for Travel Expenses Relating to Specialty Care for Certain Members of the Armed Forces and Dependents: Reduces the mileage threshold for travel reimbursement from 100 to 75 miles for active‑duty members and their dependents.
• Section 711 – Codification of Position of Director of the Defense Health Agency: Codifies the Director of the Defense Health Agency as a statutory position.
• Section 712 – Military-Civilian Medical Surge Program: Establishes a program of record to enhance medical surge capability by partnering the DOW with the U.S. Department of Health and Human Services (HHS) and civilian medical centers, designating at least eight strategic locations.
• Section 713 – Modification of Limitation on Reduction of Military Medical Manning End Strength: Extends the period covered by limits on reductions to military medical manning from five to 10 years.
• Section 716 – Licensure Requirement for Healthcare Professionals of Partner Countries: Expands the definition of authorized credentialing agencies to include official agencies of partner countries and defines "partner country" to include Five Eyes members and others designated by the Secretary of War.
• Section 720 – Review of Disclosure Requirements Under Processes and Forms Relating to Healthcare Provider Credentialing and Privileging of the Department: Requires the DOW to review and streamline credentialing and privileging processes, create a centralized credential system with seven‑day verification targets.
• Section 731 – Improvement of Availability of Care for Veterans from Facilities and Providers of the Department: Directs the DOW and VA to develop action plans to share resources, increase use of excess military medical capacity for enrolled veterans, enable cross‑credentialing through Sept. 30, 2028.
• Section 734 – Pilot Program to Assist Certain Members of the Armed Forces and Dependents with Additional Supplemental Coverage Relating to Cancer: Creates a pilot allowing eligible service members and dependents to enroll in fixed‑indemnity supplemental cancer coverage.
• Section 736 – Study on Prevalence and Mortality of Cancer Among Military Rotary-Wing Pilots and Aviation Support Personnel: Requires a two‑phase study to assess cancer prevalence and mortality among rotary‑wing pilots and support personnel.
• Section 737 – Study on Psychological Effects of and Mental Health Effects of UAS in Combat Operations: Requires DOW to study mental‑health impacts on military and civilian UAS operators and imagery analysts, compare them to crewed and nonflying roles, and assess unique stressors and support services.

Major Weapon Systems

The FY 2026 NDAA strengthens major weapon systems by requiring dedicated product support managers, regular sustainment reviews, and corrective action plans to ensure readiness. The bill advances missile defense by enforcing the Golden Dome policy, mirroring President Trump's EO 14186, "The Iron Dome for America." On hypersonics, the bill expands testing corridors, authorizes multiyear procurement for low‑cost strike systems and invests in R&D to accelerate development and deployment.

• Section 1803 – Amendments to Lifecycle Management and Product Support: Requires that every major weapon system have a designated product support manager responsible for sustainment, planning and readiness outcomes. This section also mandates regular sustainment reviews and congressional reporting to ensure weapon systems meet readiness objectives, with corrective action plans required when systems fail to achieve availability targets.

Golden Dome and Missile Defense

• Section 1651 – Modification to National Missile Defense Policy to Reflect Golden Dome for America Policy: Sets the policy of the U.S. to deploy and maintain a "next-generation missile defense shield" that is capable of defending against complex ballistics, hypersonic and cruise missile threats.
• Section 1652 – Golden Dome Missile Defense System: The Secretary of War must submit annual reports to Congress detailing threats, system architecture and funding for the next‑generation air and missile defense architecture until full capability is achieved.
• Section 1654 – Prohibition on Privatized or Subscription‑Based Missile Defense Intercept Capabilities: Bars the Pentagon from outsourcing missile intercept capabilities to private or subscription models. This section requires the Secretary of War to develop and operate a missile defense system with kinetic missile compatibilities that is "owned and operated" by the armed forces.
• Section 1657 – Iron Dome Short-Range Rocket Defense System and Israeli Cooperative Missile Defense Program Co-Development and Co-Production: Authorizes U.S. funding for Israeli missile defense programs, including up to $60 million for Iron Dome, $40 million for David's Sling and $100 million for the Arrow 3 interceptor, with requirements for co‑production in America.

Hypersonics

• Section 226 – Evaluation of Additional Test Corridors for Hypersonic and Long-Range Weapons: Directs the DOW to evaluate additional airspace and range options to expand testing and training for hypersonic and long‑range weapons, including safety, infrastructure and launch requirements.
• Section 804 – Multiyear Procurement Authority for Covered Systems and Certain Munitions: Grants multiyear procurement authority for low‑cost hypersonic strike systems, ensuring stable production and long‑term investment.
• Section 4201 – Research, Development, Test and Evaluation: There is significant authorization for funding dedicated to research, development, testing and evaluation to advance hypersonic weapons, focusing on new materials, prototyping and expanded test infrastructure to accelerate fielding and readiness.

Space

The FY 2026 NDAA strengthens the U.S. Space Force by refining leadership structures, expanding training roles and requiring oversight before new commands are created. The bill also accelerates satellite development through streamlined acquisition and ensures next‑generation systems include key payloads.

• Section 349 – Limitation on Use of Funds to Establish or Expand Space Force Special Operations Component Command: The provision bars obligating or expending Major Force Program 11 funds to establish a Space Force Special Operations Component Command until 30 days after a report is submitted to the armed services committees. The report must articulate the requirement and provide a future‑years defense program funding profile delineating Major Force Program 2 and Major Force Program 11 and address mission requirements.
• Section 502 – Redistribution of General Officers on Active Duty from the Air Force to the Space Force: Transfers general officer billets from the Air Force to the Space Force to balance leadership.
• Section 559 – Detail of Members of the Space Force as Instructors at Air Force Institute of Technology: Authorizes Space Force members to serve as instructors at Air Force Institute of Technology, strengthening acquisition and technical training.
• Section 1604 – Use of Middle Tier Acquisition Program for Proliferated Warfighter Space Architecture of Space Development Agency: Extends the Space Development Agency's authority to use the streamlined middle tier acquisition process for the Proliferated Warfighter Space Architecture. This allows rapid prototyping and fielding of satellite tranches beyond the first three, now explicitly covering Tranches 4, 5 and 6.
• Section 1607 – Study on Establishing a Tactical Surveillance, Reconnaissance and Tracking Program of Record: The Secretary of the Air Force must study the feasibility of a DOW program of record for tactical surveillance, reconnaissance and tracking. This study is tied to a Space Force pilot that provides combatant commands with space products from commercial providers.
• Section 1609 – Auxiliary Payload for Next Generation Polar Overhead Persistent Infrared Satellites: Directs the Secretary of War to revise the acquisition strategy for the Next Generation Polar Overhead Persistent Infrared satellite program to formally include the auxiliary payload in the program of record.

Notable Provisions Omitted

Several high‑profile proposals debated during the NDAA process ultimately did not make it into the final legislation. This included R&D funding for small businesses, efforts to confront the affordable housing crisis and in vitro fertilization (IVF) coverage for service members.

• SBIR and STTR Programs: On Oct. 1, 2025, authorizations for the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs lapsed. These initiatives provide competitive federal funding to small firms with cutting-edge R&D commercialization potential. The conferenced bill did not include provisions to reauthorize these programs. There is an ongoing legislative fight over how best to reauthorize the SBIR and STTR, including debate over imposing more restrictions on companies that win multiple awards year after year.
• ROAD to Housing: Earlier this year, the Senate Banking, Housing, and Urban Affairs Committee unanimously advanced the ROAD to Housing Act of 2025, introduced by Chair Tim Scott (R‑C.) and Sen. Elizabeth Warren (D‑Mass.). The bill directed the U.S. Department for Housing and Urban Development (HUD) to establish new homeowner grant and loan programs and develop best‑practice frameworks for land‑use policy. Though language to improve housing affordability and access was initially incorporated into the NDAA, it was ultimately dropped in the conference bill. House Financial Services Chair French Hill (R‑Ark.) opposed inclusion, citing insufficient support among House Republicans.
• IVF TRICARE Coverage: The bill did not include language that would have expanded IVF coverage for all military families under TRICARE. The provision had been adopted by the HASC earlier in the year.
• ROTOR Act: The bipartisan ROTOR Act, led by Senate Commerce Committee Chairman Ted Cruz (R-Texas) and Ranking Member Maria Cantwell (D-Wash.), seeks to require certain aircraft to transpond Automatic Dependent Surveillance–Broadcast (ADS–B) and restrict exceptions for military aircrafts. Section 373 of the NDAA failed to address this ADS-B loophole for military aircraft (which contributed to the Jan. 29, 2025, midair collision between a military helicopter and a passenger jet). Section 373 has received bipartisan criticism but was still included in the final defense bill without the ADS-B provision that ROTOR Act sought to fix.

For more information or questions, please contact the authors.

Information contained in this alert is for the general education and knowledge of our readers. It is not designed to be, and should not be used as, the sole source of information when analyzing and resolving a legal problem, and it should not be substituted for legal advice, which relies on a specific factual analysis. Moreover, the laws of each jurisdiction are different and are constantly changing. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. If you have specific questions regarding a particular fact situation, we urge you to consult the authors of this publication, your Holland & Knight representative or other competent legal counsel.