The Executive Order on Commercial Solutions is a presidential directive requiring federal agencies to prioritize the acquisition of commercially available off-the-shelf (COTS) products and services when fulfilling operational, technical, or administrative needs. The order reflects a strategic shift in federal procurement policy, emphasizing the use of existing commercial technologies and services over developing custom-built solutions from scratch.
This directive aligns with ongoing efforts to modernize government operations, reduce procurement costs, and shorten acquisition timelines by leveraging proven, market-ready commercial offerings.
Purpose of the Executive Order
The primary objective of the Executive Order is to encourage federal agencies to adopt commercial solutions wherever possible, avoiding unnecessary customization or development of unique products that already exist in the commercial marketplace. By doing so, the government can:
- Accelerate delivery of mission-critical capabilities
- Improve interoperability and standardization
- Reduce total lifecycle costs
- Benefit from the innovation and continuous improvement of the commercial sector
The order supports the broader goals of acquisition reform and digital modernization across the federal enterprise.
Definition of COTS
COTS stands for Commercial Off-the-Shelf. These are products or services that:
- Are sold in substantial quantities in the commercial marketplace
- Require no or minimal modification to meet agency needs
- Are available for immediate purchase and deployment
Examples include software platforms, IT hardware, cybersecurity tools, logistics services, and cloud infrastructure that are widely used in the private sector and adaptable to government use.
Key Provisions of the Order
The Executive Order outlines several requirements and expectations for federal agencies:
- Agencies must conduct market research to determine whether commercial products are available before initiating a custom development project
- Acquisition planning must include a justification if an agency chooses not to use a commercial solution
- Agencies are encouraged to use existing contract vehicles such as the GSA Multiple Award Schedule (MAS), Governmentwide Acquisition Contracts (GWACs), and Best-in-Class (BIC) contracts
- The order instructs procurement officers, CIOs, and program managers to coordinate closely to identify scalable and commercial-first options
- The Office of Management and Budget (OMB) is tasked with overseeing implementation and reporting progress
Impact on Federal Procurement
This Executive Order has a significant impact on how agencies approach procurement strategy, technology planning, and vendor engagement. It promotes the use of streamlined acquisition processes and shifts the focus from customization to rapid deployment. The benefits include:
- Faster acquisition lead times
- Access to cutting-edge commercial innovations
- Reduced contract risk and complexity
- Greater efficiency in IT and operations procurement
Agencies are now expected to justify deviations from commercial-first strategies, making commercial alignment the default expectation.
Role of GSA and Commercial Vendors
GSA plays a critical role in supporting the implementation of this Executive Order. Through its acquisition platforms, GSA provides access to a wide array of COTS offerings under pre-competed contract vehicles. These include:
- GSA MAS for a broad range of commercial products and services
- GSA Advantage for catalog-based purchases
- GSA eBuy for competitive RFQs
- GWACs such as Alliant 2, 8(a) STARS III, and VETS 2 for technology solutions
Commercial vendors that want to support this initiative should ensure their offerings are well-positioned on these platforms and aligned with federal COTS expectations. This includes maintaining standardized pricing, ready-to-implement solutions, and clear descriptions of capabilities.
Implementation Challenges
While the Executive Order sets a clear direction, agencies may face challenges in implementation, such as:
- Adapting legacy acquisition processes to prioritize commercial procurement
- Training acquisition staff to identify viable commercial alternatives
- Ensuring security, compliance, and performance standards are met with COTS solutions
- Managing integration of COTS tools into existing government systems
GSA, OMB, and agency leadership must work together to address these barriers and foster a government culture that embraces commercial-first acquisition.
Contractor Considerations
Contractors seeking to align with the Executive Order should:
- Offer configurable rather than customized solutions
- Emphasize scalability, interoperability, and industry standards
- Highlight past commercial use cases in federal proposals
- Maintain updated listings on GSA platforms
- Monitor opportunities that explicitly seek COTS-based proposals
Contractors who can demonstrate the ability to meet agency needs through commercial models will be in a stronger position to win contracts and grow their federal business.
Conclusion
The Executive Order on Commercial Solutions represents a major policy shift toward more agile, efficient, and cost-effective government procurement. By prioritizing COTS products and services, the federal government aims to modernize acquisition, reduce risk, and take advantage of private-sector innovation. Agencies and contractors alike must adapt to this new standard, making commercial-first thinking a cornerstone of successful acquisition strategy.
