dfars/independent
DFARS Consultant-Lobbyist Ban Takes Effect With Rules Unresolved
The Section 851 prohibition on defense contractors using consultants who lobby for covered foreign entities took effect June 30 via a DFARS class deviation, not formal rulemaking, after DoD abandoned DFARS Case 2025-D0007. The deviation tracks the statutory text and provides no guidance on the safe harbor for legal, audit, and tax compliance services. Contractors must now self-certify under 252.209-7012 without knowing which consultant arrangements qualify.