Ending Double Dealing Act of 2026

This bill aims to prevent organizational conflicts of interest within the Department of Defense (DoD) by prohibiting contracts with consultancies that also serve foreign adversaries. Congress finds it imperative that consultants providing mission support services to the DoD, especially concerning national security, do not simultaneously provide services to foreign adversaries that run counter to U.S. interests. The legislation defines a covered consultancy as one that has failed to disclose information, submitted false information, or failed to disclose conflicts of interest related to specified foreign entities.

Under this Act, the Secretary of Defense is prohibited from entering into or renewing contracts with a covered consultancy. Any individual or entity bidding for DoD consulting services must disclose information regarding contracts, grants, or financial awards from a covered entity within the preceding five years, and whether such ties will persist during the DoD contract. Failure to make the required disclosures will result in the termination of the DoD contract for cause and initiation of debarment proceedings, with a maximum debarment period of five years.

A company deemed a covered consultancy can regain eligibility by submitting a written certification to the Secretary of Defense, affirming that it has severed all financial ties with covered entities and will not re-engage during its DoD contract. The bill defines covered entities to include the governments and associated entities of China, Russia, North Korea, Iran, Cuba, and other state sponsors of terrorism, as well as entities on various U.S. sanctions and export control lists, particularly those involved in national security industries like semiconductors, AI, and biotechnology. The Secretary of Defense is mandated to issue implementing policies and revise the Defense Federal Acquisition Regulation Supplement within specific timelines.