Advocacy Update

Virginia first. We continue our efforts to (re)conform R&D tax credits in Virginia to the Federal standard. In short, federal policy allows the expenses to be claimed in their entirety for the applicable filing period, while Virginia now requires they be amortized over a five-year period. We are mustering a coalition and appealing to have the amortization requirement removed.

[Understatement alert!] There has been a lot to follow at the national level. Here we’ll highlight two.

While AIA Virginia will not be taking a position or engaging directly in these matters, we want you to know about them. And then you can decide whether and how you might engage.

The U.S. Small Business Administration (SBA) is proposing new size standards for 338 industry groups and industries. For architecture, the proposed threshold increases from $12.5 million to $135 million in average annual receipts. SBA will receive comments on this proposed rule until September 21, 2026. Additional information, including protocol for providing comments, can be found here:

https://www.federalregister.gov/documents/2026/08/20/2026-17042/small-business-size-standards

You should be aware that while this policy is not likely to impact (set a precedent) here in Virginia (e.g., it will not automatically change Virginia’s SWaM size criteria), it could affect firms participating in programs that use federal SBA standards (e.g., MDOT, VDOT’s Small Business Enterprise program).

This next item has been the focus of AIA advocacy efforts at the national level. FAR Case 2026-003 is a proposed rule published on September 18, 2026, as part of the FAR Council's Revolutionary FAR Overhaul (RFO) under Executive Order 14275 and OMB Memorandum M-25-26, which seeks to amend the Federal Acquisition Regulation (FAR). The FAR sections under consideration pertain to required sources of supplies and services (Part 8), acquisition of commercial products and services (Part 12), simplified acquisition procedures (Part 13), contracting by negotiation (Part 15), Federal Supply Schedule contracting (Part 38), subcontracting policies and procedures (Part 44), contractors’ use of government supply sources (Part 51), and associated solicitation provisions and contract clauses (Part 52). Additional information and a link to provide public comment, which will be accepted until October 19, 2026, is available here: https://www.federalregister.gov/documents/2026/09/18/2026-19162/federal-acquisition-regulation-revolutionary-far-overhaul-parts-8-12-13-15-38-44-and-51