Time to Choose Act of 2025
Summary
What This Bill Does
The Time to Choose Act targets consulting firms that seek U.S. government work while also advising covered foreign entities. Within one year, the Federal Acquisition Regulatory Council must amend the Federal Acquisition Regulation so firms offering consulting services to executive agencies certify that they, their subsidiaries, and affiliates do not hold consulting contracts with covered foreign entities. Covered foreign entities include the PRC government, Chinese Communist Party, People's Liberation Army, Ministry of State Security, Russian government, certain Treasury-sanctioned Russia-related entities, state sponsors of terrorism, Commerce restricted-list entities, Defense-identified Chinese military companies, and OFAC Non-SDN Chinese Military-Industrial Complex companies. Agency heads can grant only limited national-security waivers after consultation with DOD and DNI, notice to OMB, notice and briefing offers to Congress, public disclosure unless harmful to national security, and a management oversight plan. False certifications lead to contract termination, possible suspension or debarment, and False Claims Act liability including treble damages.
Who Benefits and How
Federal agencies buying consulting services benefit from a clearer conflict-of-interest screen for contractors tied to covered foreign entities. U.S. national security officials benefit because waiver review requires Defense Department and intelligence-community consultation. Consulting firms without covered foreign-entity contracts benefit from a competitive advantage in federal advisory contracts. Congressional oversight committees benefit from waiver notices, briefing offers, and contractor foreign-relationship details. Department of Defense procurement officials benefit from a statutory tool to identify consulting conflicts tied to foreign adversary work.
Who Bears the Burden and How
Consulting firms with PRC, Russian, sanctioned, terrorism-linked, or restricted-list clients may lose access to federal consulting contracts. Executive agency procurement offices must collect certifications, administer waivers, publish disclosures, and enforce penalties. FAR Council members must amend federal acquisition rules within one year. Contractors receiving waivers must disclose ownership, foreign real estate, employee clearance details, contract values, work subject matter, risks, and oversight plans.
Key Provisions
- Requires FAR Council to amend federal procurement rules within one year.
- Prohibits federal consulting contracts for firms that also consult for covered foreign entities absent a waiver.
- Limits waivers to national-security cases with OMB notice, congressional notice, briefing offers, public disclosure rules, and oversight plans.
- Requires termination and consideration of suspension or debarment for knowingly false certifications.
- Applies False Claims Act penalties, including treble damages, to hidden or misrepresented covered foreign contracts.
Evidence Chain:
This summary is generated from the full bill text using AI analysis. Expand "Detailed Analysis" below for identified beneficiaries/burden bearers with clause-level evidence links.
At a Glance
What This Bill Does
Bars federal consulting contracts for firms that also consult for covered foreign entities unless a tightly limited national-security waiver is granted, and imposes termination, suspension, debarment, and False Claims Act exposure for false certifications.
Key Policy Areas
Federal Procurement, National Security, Foreign Influence
Primary Purpose
Bars federal consulting contracts for firms that also consult for covered foreign entities unless a tightly limited national-security waiver is granted, and imposes termination, suspension, debarment, and False Claims Act exposure for false certifications.
Policy Domains
Resolution provisions
Identified Gains
- Federal agencies buying consulting services
- Department of Defense procurement officials
- Director of National Intelligence
- Consulting firms without covered foreign-entity contracts
- Congressional oversight committees
Identified Costs
- Consulting firms with covered foreign clients
- Executive agency procurement offices
- FAR Council administrators
- OMB waiver reviewers
- Contractors receiving waivers
- Contractors with security-clearance staff
Legislative Progress
In CommitteeMr. Bresnahan introduced the following bill; which was referred to …
Referred to the House Committee on Oversight and Government Reform.
Introduced in House
Stakeholder Effects
cui bono?How this legislation distributes effects. Mention counts reflect frequency, not effect magnitude.
Congressional oversight committees, Department of Defense procurement officials, Executive agency procurement offices
Positive-direction: Congressional oversight committees, Department of Defense procurement officials, Federal agencies buying consulting services
Negative-direction: Executive agency procurement offices, FAR Council administrators, OMB waiver reviewers
Consulting firms with covered foreign clients, Consulting firms without covered foreign-entity contracts
Positive-direction: Consulting firms without covered foreign-entity contracts
Negative-direction: Consulting firms with covered foreign clients
Bill Structure & Actor Mappings
Who is "The Secretary" in each section?
We use a combination of our own taxonomy and classification in addition to large language models to assess meaning and potential beneficiaries. High confidence means strong textual evidence. Always verify with the original bill text.
Learn more about our methodology