On February 17, 2026, the Federal Acquisition Regulatory Council (FAR Council) issued a Notice of Proposed Rulemaking to implement section 5949 of the 2023 National Defense Authorization Act for Fiscal Year 2023 (NDAA) restricting the U.S. government from purchasing “covered” products and services, which the Proposed Rule defines as products and services that use semiconductors designed, produced or provided by Semiconductor Manufacturing International Corporation, (SMIC), ChangXin Memory Technologies (CXMT) or Yangtze Memory Technologies Corp (YMTC) (collectively, “covered semiconductors”). The Proposed Rule will be open for public comment until April 20, 2026.1 Certification and Reasonable Inquiry Under the Proposed Rule, effective December 23, 2027, all solicitations for products, non-commercial services, and commercial information technology services and telecommunication services would require offerors to certify that they have conducted a reasonable inquiry and will not provide: any electronic products or electronic services that include covered semiconductor products or services to the Government under a resulting contact; and electronic products for use in critical systems (as identified by the Government) that include covered semiconductor products or services. The Proposed Rule places significant emphasis on pre-award and ongoing supply-chain due diligence, requiring offerors to conduct a “reasonable inquiry” to determine whether any electronic products or services offered to the Government include covered semiconductor products or services.