Time to Choose Act of 2025

This bill addresses concerns about conflicts of interest that arise when consulting firms simultaneously contract with the United States Government and certain foreign entities. Congress finds that such dual contracting can potentially undermine U.S. economic and national security by aiding foreign governments in efforts that may be contrary to American interests. The legislation seeks to prevent these conflicts by requiring firms to choose between aiding foreign governments or assisting the U.S. Government. To achieve this, the Federal Acquisition Regulatory Council must amend the Federal Acquisition Regulation within one year. These amendments will require consulting firms making offers for federal contracts to certify that neither they nor their subsidiaries or affiliates hold consulting contracts with any covered foreign entities . Federal contracts for consulting services, specifically those described under NAICS Industry Group code 5416, will be prohibited for firms that do not meet this certification requirement. A limited waiver process is established, allowing an executive agency head to grant exceptions on a case-by-case basis if determined to be in the national security interests of the United States and if no other entity can perform the work. Such waivers require consultation with the Secretary of Defense and Director of National Intelligence, notification to Congress, and public disclosure of the foreign entities involved, unless national security is directly harmed. Waivers are limited to 365 days, with a single 180-day extension, and only one waiver per entity across all agencies at a given time. The bill defines covered foreign entities broadly, including the Government of the People's Republic of China, the Russian Federation, state sponsors of terrorism, and entities on various Department of Commerce and Treasury sanction lists. Penalties for knowingly submitting false certifications include contract termination, suspension or debarment from future federal contracts, and liability under the False Claims Act. No additional funding is authorized for the implementation of this Act.