What changed between these versions
A substantive modification. The short title year was updated from 2025 to 2026. More significantly, v2 narrows the application of the "Rule of Two" by explicitly excluding delivery orders and task orders from the definition of "covered contract," thereby limiting the types of contracts that must be reserved for small businesses.
Overview
A handful of changes concentrated in two sections. · The overall direction is a narrowing of the scope of contracts subject to the "Rule of Two" reservation for small businesses.
The most significant change in v2 is the narrowing of the "Rule of Two" application. While v1 applied the rule to "contract, task order, or delivery order," v2 introduces the term "covered contract" and explicitly excludes delivery orders and task orders from its definition. This means that only prime contracts, and not subsequent orders, will be subject to the small business reservation requirement. Additionally, the short title of the Act was updated to reflect the year 2026 instead of 2025.
Major additions
This new subparagraph defines the term "covered contract" for the purpose of the "Rule of Two" provision. It explicitly states that "covered contract" does not include a delivery order or a task order.
This addition is highly significant as it fundamentally alters the scope of the "Rule of Two." By excluding delivery and task orders, it limits the types of procurement vehicles that contracting officers must reserve for small business concerns, potentially reducing opportunities for small businesses in these specific contract types.
Modifications
This is a minor, administrative change with no operative policy impact on small businesses or contracting processes. It simply reflects a change in the legislative session or reporting year.
Before
The Act was cited as the "Protecting Small Business Competitions Act of 2025."
After
The Act is now cited as the "Protecting Small Business Competitions Act of 2026."
This modification significantly impacts small business concerns by removing delivery orders and task orders from the mandatory reservation requirement under the "Rule of Two." Contracting officers will no longer be required to reserve these specific types of orders for small businesses, potentially reducing the pool of opportunities available to them for these contract vehicles.
Before
The "Rule of Two" applied to "Each contract, task order, or delivery order for the purchase of goods or services..."
After
The "Rule of Two" now applies to "Each covered contract for goods or services..." where "covered contract" is subsequently defined to exclude delivery orders and task orders.
Scope
Meaningful expansion or narrowing — Changes are concentrated in the short title and the core operative provision of the bill, specifically the definition and application of the "Rule of Two." — V2 represents a meaningful narrowing of the policy direction regarding the mandatory reservation of contracts for small businesses. While the core "Rule of Two" principle remains, its application to specific contract vehicles is significantly restricted. — The change to the definition of "covered contract" directly interacts with and limits the scope of the "Rule of Two" provision itself, which is the central operative mechanism of the bill.
Impact analysis
Small business concerns seeking federal contracts
This group loses potential mandatory set-aside opportunities for delivery orders and task orders.
In v1, small businesses could expect that "contracts, task orders, or delivery orders" above the simplified acquisition threshold would be reserved for them if two or more responsible small businesses were expected to offer a fair market price. In v2, this expectation is removed for "delivery orders" and "task orders."