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  The new fiscal year opened on a stopgap. Here is what still gets awarded.
  https://offra.cc/blog/bidding-under-a-continuing-resolution
  By Philippe Dallaire (Founder, Offra)
  Published: 2026-10-12 · Updated: 2026-10-12
  Language: en · Category: Bidding strategy
  © Consuly Pte. Ltd. — republished with attribution and a link to the canonical URL.
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September is the busiest month in federal contracting. Agencies rush to obligate money that expires
on the 30th. October is the reverse. The new fiscal year opens, the pipeline thins, and many firms
read the quiet as a signal to stop looking.

This year the quiet has a cause you can read. Fiscal 2027 opened on a continuing resolution, signed
in early September, that funds the government through **December 11, 2026**. Agencies are spending
at roughly their fiscal 2026 rates under fiscal 2026 conditions until Congress passes full-year bills
or another stopgap. A CR does not stop contracting. It changes which contracts move.

## What a continuing resolution allows

Work that already exists keeps going. Under a CR, an agency can generally:

- exercise options on contracts that are already running,
- award recompetes and follow-ons for programs funded last year,
- buy the recurring supplies and services it was already buying.

If the work you chase is a recompete of something the agency bought in fiscal 2026, the CR is
mostly a timing question. The solicitation may slip a few weeks. It is unlikely to disappear.

## What it holds back

A CR bars agencies from starting projects or activities that were not funded the year before. Those
are the "new starts". Defense carries extra limits: no production of items not already in
production, no production-rate increases above fiscal 2026 levels, and no new multiyear
procurements.

So the new program announced at a spring industry day, the expansion an agency has budgeted for
fiscal 2027, or the follow-on at a much larger scope will usually wait for full-year
appropriations. You can still see the work, in forecasts, Sources Sought notices and draft RFPs. It
just cannot be awarded yet.

## "Subject to the availability of funds" is still worth bidding

Some solicitations will go out anyway, with a clause saying the government's obligation depends on
funds being appropriated. Firms sometimes read that as a reason to pass. It usually is not.

The clause lets the agency run the competition now and award when the money lands. The evaluation
is real, and so is the award. What changes is your exposure between submission and notice to proceed.
Check three things before you price:

1. **How long your price has to hold.** Bid acceptance periods can stretch past the CR. Price the
   materials and labor that will apply when the work starts, not the ones that apply today.
2. **Whether the start date floats.** A performance period that begins "upon award" can begin in
   January rather than November. Staffing and mobilization plans should not assume otherwise.
3. **What happens after December 11.** If the government shuts down on December 12, open
   solicitations can be paused and due dates moved. Watch for amendments, and
   [acknowledge every one](/blog/acknowledge-every-amendment).

## What to do with the quiet weeks

The firms that win the spring awards are usually doing their work now, while competitors wait. Four
things pay off during a CR:

- **Answer the Sources Sought notices.** New starts that cannot be awarded can still be shaped.
  This is when an agency decides whether the work is a set-aside and how it is described.
  [A Sources Sought notice is the bid before the bid](/blog/how-to-answer-a-sources-sought-notice).
- **Read the agency forecasts.** Most agencies publish procurement forecasts for the new year.
  Mark the ones that match your NAICS codes and set-aside status, and check
  [what a set-aside actually excludes](/blog/what-a-set-aside-actually-excludes) before you count
  yourself in.
- **Fix your registrations.** An expired SAM.gov registration or a stale representation is a
  disqualification waiting for a deadline. [Registered in SAM.gov is not one
  thing](/blog/registered-in-sam-is-not-one-thing).
- **Make your bid/no-bid calls early.** When the money lands, the solicitations land together.
  Deciding in advance which ones you will chase is what keeps a January surge from becoming a
  January scramble. [The bid/no-bid call takes twenty
  minutes](/blog/bid-no-bid-decision-in-twenty-minutes) if you have done the reading.

## The date to watch

December 11 is the next decision point. Congress can pass full-year bills, pass another stopgap or
let funding lapse. The first starts the new-start pipeline. The second extends the current
situation. The third pauses most of it.

You cannot control which happens. You can control whether, when the money arrives, you have already
read the work, shaped what you could, and decided what you are bidding.
