New FAR Part 40 to Address Supply Chain and Information Security Requirements
Client Alert | 1 min read | 04.15.24
On April 1, 2024, the Department of Defense (DoD), General Services Administration (GSA), and the National Aeronautics and Space Administration (NASA) issued a final rule updating the Federal Acquisition Regulation (FAR) to add Part 40 on information security and supply chain security. This first action did not implement any new requirements; however, separate rulemakings will follow to relocate existing information security and supply chain security policies and procedures to the new Part 40. Additionally, new related regulations will be housed in Part 40. These actions suggest that the flow of information security and supply chain regulations is likely to continue unabated for at least the next few years.
As noted, Part 40 will consolidate the various information security and supply chain security regulations currently distributed throughout the FAR. It ultimately will include regulations concerning prohibitions, exclusions, supply chain risk information sharing, safeguarding information, and supply chain security requirements. For example, the Section 889 prohibition and policies would be placed in Part 40, as would provisions implementing Federal Acquisition Supply Chain Security Act exclusion and removal orders.
Supply chain and information risks that are not considered to be related to security, such as labor restrictions, climate risks, and human trafficking, will not be in Part 40 and will continue to be covered in other parts of the FAR.
Contacts
Insights
Client Alert | 7 min read | 11.05.26
2026 State Attorney General Elections: What Businesses Should Expect
As of November 4, 2026, the state attorney general elections point to increased enforcement in 2027, particularly in consumer protection, antitrust, AI, health care, and data centers.[1] Businesses should prepare for more investigations under existing laws and proposals for new legislation or rules. Campaign commitments indicate priorities, but their timing and implementation remain uncertain.[2]
Client Alert | 3 min read | 11.05.26
Federal, State, and Local Regulators Sue Toast Over B2B Advertising and Subscriptions
Client Alert | 3 min read | 11.04.26
CMS Proposal Would Overhaul Eligibility Rules for ACA Exchanges
Client Alert | 7 min read | 11.04.26
FDA Issues Guidance on Prescription Drug Use-Related Software



