For decades, the government built what it could have been buying. Custom systems, long timelines, development cycles that lagged the mission, even when commercial solutions already existed. That gap is no longer sustainable. Missions move faster. Data windows are shorter. The volume and complexity of information is higher, and data has to be usable in real time, inside operational workflows. The old acquisition models weren’t built for that.
Now they’re being forced to change.
On November 7, 2025, the Secretary of War made that explicit in a 70-minute speech at the National War College, declaring the end of the existing Defense Acquisition System. The expectation is no longer that the government funds every step of development. Industry is expected to invest its own capital and bring solutions that are ready to deploy. For companies unwilling to take on that risk, the message was clear: they won’t be part of where the Department is going.
The 2026 NDAA, signed into law on December 18, 2025, puts these changes into statute. Section 1825 creates a formal consumption-based solutions category in the DFARS — metered usage, fixed-price units, incremental funding, and the ability to add features up to 25% of contract value without triggering a new competitive procurement. Programs can pay for what they actually use instead of committing to a massive upfront buy and hoping it delivers.
Section 1822 goes further: before pursuing a new build, a program manager must document that no commercial solution exists — and that memo is signed by the portfolio acquisition executive. The default has flipped. The burden of proof now sits with the custom build, not the commercial option.
The implementation clock is also running. The November 7 speech directed DoW to publish new contracting guidelines and establish performance scorecards for portfolio acquisition executives within 180 days — a deadline that falls in early May 2026. That’s weeks away. That guidance will define how the new portfolio acquisition executives operate in practice and what accountability looks like going forward. Program offices that are still waiting on the sidelines are running out of time to treat this as a future problem.
The question is no longer whether commercial solutions belong in the acquisition conversation — that has been settled. The question is whether programs move fast enough to take advantage of it.
That’s the model Grist Mill Exchange was built around before any of this was policy. We made the early decision to invest private capital to build a commercial data layer with anonymous, metered APIs that warfighter programs can deploy in hours — fixed-price units and consumption-based acquisition built in from the start. That wasn’t driven by policy. It was driven by what the mission required.
What’s changed is that policy has caught up to reality. The old path of least resistance — build it, own it, wait for it — will no longer be tolerated.
The window is open. The only question is whether programs move fast enough to use it.