# What A/E Firms Should Do Before FY2027 Starts

> Federal FY2027 starts October 1 under an enacted CR running to December 11. What the new-starts bar blocks, and how A/E firms position before it opens.

_By Oswald B. · Published 2026-08-14 · Updated 2026-09-09_

Federal fiscal year 2027 begins October 1, 2026, and agencies will start it under a continuing resolution. That is settled: the CR was signed into law on September 2 and runs through December 11. For A/E firms the practical meaning is narrow. The work available in October is work you were already positioned for.

This is a federal piece. If your practice is state, municipal, or private, most of what follows does not apply to you, and the last section says what does.

## Where FY2027 Funding Actually Stands

It is resolved. [H.R. 6500](https://www.govinfo.gov/content/pkg/BILLS-119hr6500enr/html/BILLS-119hr6500enr.htm), the Continuing Appropriations and Extensions Act, 2027, became **Public Law 119-103** on September 2, 2026. The Senate had passed it with an amendment 90-6 on August 8; the House agreed to that amendment on September 1.

Division A funds agencies at FY2026 levels. Under section 106(3), that authority runs until December 11, 2026, or until the applicable FY2027 appropriations act is enacted, whichever comes first. Division C separately extends surface transportation authorities.

So October is now predictable in operating condition, if not in detail. The question is no longer whether there is a CR. It is what a CR permits.

One caveat: the extension continues program authority, but the IIJA advance appropriations funding transit and passenger rail expire September 30 regardless. We covered [what that split does to a transit or rail pipeline](/blog/transit-rail-funding-cliff) separately.

## What a Continuing Resolution Does to A/E Work

A CR is not a shutdown. Agencies stay open and money keeps moving. What changes is what agencies are permitted to start.

The new-starts prohibition is no longer a general description of how CRs usually work. It is section 104 of the enacted law, and it reads: no funds "shall be used to initiate or resume any project or activity for which appropriations, funds, or other authority were not available during fiscal year 2026."

Agencies are also limited to taking, in the Congressional Research Service's summary of the standard language, ["only the most limited funding action"](https://www.everycrsreport.com/reports/RL34700.html) necessary to continue existing work. GAO case studies in the same report document the effect: delayed contract awards for non-recurring projects, and agencies splitting one annual action into several short ones.

**Three programs are exempted from section 104, and it is worth knowing what they are, because the shape of the list tells you not to go looking for a fourth.** They are not a category. They are named, free-standing sections that override the bar for specific prior-year defense work: section 126 covers Navy shipbuilding cost increases on named programs, section 127 covers Defense-Wide Procurement for National Security Systems at not more than $2,853,000,000, and section 130 keeps NNSA Weapons Activities funded to prevent project demobilization.

No civil A/E work is in there, and none could be. These are bespoke carve-outs written for individually named defense programs, not an exception a firm can argue its way into. If a contracting officer tells you a civil project is exempt from the new-starts bar, the burden is on the exemption.

That produces a clear split in your federal pipeline.

| Where the work comes from                 | What a CR does to it                                        | What that means for October                       |
| ----------------------------------------- | ----------------------------------------------------------- | ------------------------------------------------- |
| Task orders off vehicles you already hold | Least affected. Continues under existing contract authority | Your most reliable October work                   |
| Recompetes of continuing contracts        | Generally proceed, but awards slip                          | Be ready early and assume the date moves          |
| New solicitations for continuing programs | Proceed slowly under "most limited funding action"          | Expect thinner posting volume in October-November |
| Anything that is a genuine new start      | Prohibited for the duration of the CR                       | Not available until full-year bills pass          |

Under a CR, the difference between a firm with work in October and a firm waiting for postings is mostly whether it already holds a seat on a vehicle.

## The Year-End Surge Is Mostly Not Your Surge

Federal obligations rush at the end of the fiscal year. Liebman and Mahoney, analyzing federal procurement data, found that [spending in the last week of the fiscal year runs 4.9 times the rest-of-year weekly average](https://www.nber.org/papers/w19481), and that information technology projects bought in that window carried substantially lower quality ratings.

The surge is largely expiring funds obligated against arrangements that already exist, such as task orders, modifications, and options, because that is the only action an agency can finish in a few weeks. A qualifications-based selection does not fit: announcement, submission, evaluation board review, shortlisting, interviews, and negotiation take months.

The year-end surge is not a selling season. It is a settlement of decisions already made, and August and September are for becoming one of the arrangements that exists.

## What to Do in August and September

1. **Update your SF330 Part II in every agency file you are in.** Under [FAR 36.603](https://www.acquisition.gov/far/36.603), agencies maintain A/E qualifications data files and review each one at least once a year. A file carrying your 2024 staff list and project mix is representing you right now to people you will never meet.
2. **Pursue seats, not October awards.** [On-call, IDIQ, and MATOC vehicles](/blog/on-call-idiq-matoc-contracts) are the channel a CR leaves intact. A seat you hold in September is worth more than a solicitation you are watching for in October.
3. **Get recompete packages done before you think you need them.** Awards slip under a CR, but solicitation deadlines usually do not move with them. The asymmetry punishes teams that pace to the original date.
4. **Ask your contracting officers what is queued.** Which pending actions are new starts, and which continue prior-year work. That question separates the pursuits worth reserving capacity for from the ones that cannot legally proceed.
5. **Do not build the FY2027 revenue plan on a December number.** Full-year appropriations may land then, or the CR may be extended again. Plan the first quarter as flat and treat anything better as upside.

The constraint that makes step one hard is not knowing that it matters. It is that a firm in eight or ten agency files is maintaining eight or ten documents, each with its own last-updated date, each drifting further from who currently works there. Firms that keep staff and project records in [reusable shape](/blog/reusable-qualifications-library) treat that as an afternoon. Rebuilding each one from the last submitted PDF turns annual housekeeping into a project, and projects get scheduled rather than done. With the CR now in effect, here is [a ten-week plan for that work](/blog/cr-ten-weeks-qualifications-library).

## If Your Work Is Not Federal

Federal work is a minority of the market for most civil and multidiscipline firms. Two things set the calendar for the rest:

- **[State DOT prequalification](/blog/state-dot-prequalification)** runs on each agency's own cycle, unrelated to the federal fiscal year, and it is the gate on far more A/E revenue than federal selections are.
- **The IIJA's September 30 expiration** is the deadline that actually reaches state and local pipelines. Our [look at what an extension does to 2027 planning](/blog/iija-extension-2027-pipeline) covers it, and the [water funding picture](/blog/wrda-2026-water-pursuits) carries the same date.

The federal calendar is loud, and it is easy to let its deadlines set the tone of a planning conversation that should be about clients who do not share them.

## Frequently Asked Questions

### When does federal fiscal year 2027 start?

Federal fiscal year 2027 begins October 1, 2026 and ends September 30, 2027. It is unrelated to state and local fiscal years, most of which begin July 1, and to the calendar-year budgets most private clients run on. A firm working across all three is tracking three separate procurement calendars.

### Will the government shut down on October 1, 2026?

No. A continuing resolution was signed into law on September 2, 2026 as Public Law 119-103, funding agencies at FY2026 levels. That authority runs through December 11, 2026, or until the applicable FY2027 appropriations act passes, whichever comes first. A shutdown becomes a live question again only if nothing is enacted before that December date.

### What does a continuing resolution mean for A/E contracts?

Agencies keep operating at prior-year funding levels but generally cannot start new programs, projects, or activities under the "new starts" prohibition. Existing contracts and task orders continue normally, while new awards for non-recurring work tend to slip. Your contracting officer can tell you whether a specific pending action counts as a new start.

### Should A/E firms chase the federal year-end spending surge?

Not as a source of new selections. The September surge is concentrated in obligations against existing contracts and vehicles, because qualifications-based A/E selection takes months to run and does not fit in the closing weeks of a fiscal year. The useful work in August and September is positioning for the year that starts in October.

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