- Potential benefitReduces risk of foreign influence and intelligence leakage via consulting contractors.
- Potential benefitAligns contractor incentives to prioritize U.S. national and economic security.
- Potential benefitCreates clearer compliance expectations and disclosure requirements for consulting firms.
Time to Choose Act of 2025
Referred to the House Committee on Oversight and Government Reform.
The Time to Choose Act of 2025 would amend the Federal Acquisition Regulation to bar executive-branch consulting contracts with firms that simultaneously provide consulting services to specified ‘‘covered foreign entities’’ (including Chinese and Russian government or listed entities), unless an agency head grants a limited waiver for national security reasons subject to interagency consultation, reporting, and publicity. The bill requires pre-award self-certification, creates reporting and disclosure requirements for waivers, imposes penalties for false certifications including termination and False Claims Act exposure, defines covered entities and consulting services (NAICS 5416), and authorizes no new appropriations.
Degree of concern about waiver use and oversight
Relative to its intended legislative type, this bill is a well-specified statutory prohibition that combines substantive changes to contracting eligibility with detailed procedural and definitional elements.
The Time to Choose Act of 2025 would amend the Federal Acquisition Regulation to bar executive-branch consulting contracts with firms that simultaneously provide consulting services to specified ‘‘covered foreign entities’’ (including Chinese and Russian government or listed entities), unless an agency head grants a limited waiver for national security reasons subject to interagency consultation, reporting, and publicity.
The bill requires pre-award self-certification, creates reporting and disclosure requirements for waivers, imposes penalties for false certifications including termination and False Claims Act exposure, defines covered entities and consulting services (NAICS 5416), and authorizes no new appropriations.
Moderately scoped national-security measure with industry compliance costs; waiver and transparency help, but legal and procurement opposition lower chances.
Relative to its intended legislative type, this bill is a well-specified statutory prohibition that combines substantive changes to contracting eligibility with detailed procedural and definitional elements. It clearly identifies problem and mechanisms, integrates with existing law, and includes a detailed waiver and accountability structure, while leaving some implementation particulars and resourcing to regulation and existing agency processes.
Degree of concern about waiver use and oversight
Who stands to gain, and who may push back.
These are examples from the analysis, not a ranked list of the most-affected groups.
- Potential burdenShrinks the pool of eligible contractors, potentially raising procurement costs and delays.
- Potential burdenImposes compliance and disclosure burdens on firms, increasing administrative costs.
- Potential burdenCould disadvantage U.S. subsidiaries of foreign-owned firms, affecting jobs and competitiveness.
Why the argument around this bill splits.
Degree of concern about waiver use and oversight
Likely broadly supportive because the bill aims to prevent conflicts of interest and protect national security.
Progressives would welcome limits on firms aiding adversarial states, but expect stronger transparency, civil liberties safeguards, and human-rights considerations in implementation.
Generally favorable in principle for managing procurement risk and national security, but cautious about implementation complexity, compliance costs, and legal defensibility.
Would want precise definitions, phased implementation, and metrics to avoid procurement disruption.
Overall supportive because the bill restricts U.S. contracting ties to adversarial foreign governments and entities.
Conservatives will favor its national security focus but may press for even stricter enforcement and fewer waivers.
The path through Congress.
Reached or meaningfully advanced
Reached or meaningfully advanced
Still ahead
Still ahead
Still ahead
Moderately scoped national-security measure with industry compliance costs; waiver and transparency help, but legal and procurement opposition lower chances.
- Absent cost estimate for compliance and procurement impacts
- Potential legal challenges to extraterritorial or affiliate-based prohibitions
Recent votes on the bill.
No vote history yet
The bill has not accumulated any surfaced votes yet.
Go deeper than the headline read.
Degree of concern about waiver use and oversight
Moderately scoped national-security measure with industry compliance costs; waiver and transparency help, but legal and procurement opposit…
Relative to its intended legislative type, this bill is a well-specified statutory prohibition that combines substantive changes to contracting eligibility with detailed procedural and definitional elements. It clearly…
Go beyond the headline summary with full stakeholder mapping, legislative design analysis, passage barriers, and lens-by-lens tradeoff breakdowns.