JA Anduril Industries 13 Mar 26_FINAL.pdf

Control Number: JA-26-DC3oE-0038 Anduril EC

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Justification and Approval for Other than Full and Open Competition – FAR Part 6

1. Requiring Activity: Headquarters Department of the Army (HQDA) – Chief Information Officer (CIO), U.S. Army and cognizant Commands

2. Contracting Activity: U.S. Army Contracting Command – Aberdeen Proving Ground (ACC-APG), Aberdeen Proving Ground, MD 21005-3013, Digital Contracting Capabilities Center of Excellence (DC3oE) Division.

3. Description of Action: Request approval to award a new $20,000,000,000.00 Firm-Fixed-Price (FFP) Single Award (SA) Indefinite Delivery, Indefinite Quantity (IDIQ) Enterprise Contract (EC) to Anduril Industries, Inc., CAGE: 85LD7, 1400 Anduril, Costa Mesa, CA 92626. The contract will have a 10 year ordering period, consisting of a five-year base and one five-year option period. The total anticipated ceiling for this contract is $20,000,000,000.00. Multiple types of appropriate year funding, to include but not limited to Operations and Maintenance (OM), Research, Development, Test and Evaluation (RDT&E), and Other Procurement (OP), will be used and determined at the order level.

The EC will be available for ordering by the Department of War (DoW) and all other authorized federal agencies. For the purposes of this EC, a “DoW component” includes, but is not limited to: the Office of the Secretary of Defense, the Military Departments, the Chairman of the Joint Chiefs of Staff, the Unified Combatant Commands, the Inspector General of the Department of Defense, the Defense Agencies, the DoW Field Activities, the U.S. Coast Guard, the Intelligence Community (IC), and Foreign Military Sales with a Letter of Authorization.

While this EC is a sole-source award, orders issued under the EC are expected to result from competitive acquisitions in which the EC holder is selected as a prime contractor or as part of a competitively selected solution. When selected as a prime, awards will be issued as orders under this EC. When selected as a subcontractor or supplier, the EC holder’s portion of the requirement will be ordered under the EC and provided to the prime contractor as Government Furnished Property, Material, or Information.

4. Description of Supplies/Services:

The U.S. Army requires a IDIQ contract vehicle because Anduril is the only responsible source capable of providing the full suite of integrated software, hardware, and ancillary services required to meet the Army’s operational needs, as demonstrated by the lack of qualified responses to the Sources Sought notice posted to SAM.GOV on 19 December 2025 (responses due 9 January 2026). No other vendor demonstrated the capability to offer, perform, or fulfill Anduril’s full commercial suite of offerings. The resulting contract vehicle will serve as the DoW and federal agencywide Enterprise Contract to manage all current and future requirements for Anduril’s commercial offerings. This

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b. Alternatives Considered:

Continued use of Other Transaction (OT) agreements: While OTs have been instrumental in prototyping and initial deployment of Anduril’s solutions, they are not suitable for ongoing production and sustainment of Anduril’s products. Transitioning follow-on production awards to FAR-based SA IDIQ contract is necessary to ensure compliance with acquisition regulations, enable efficient scaling, and provide the Army with the contractual flexibility required for long-term operational support, which would be supported by this EC.

Use of in-house resources: The proprietary nature and technical complexity of Anduril’s solutions preclude the use of in-house resources. The Government does not possess the necessary subject matter expertise, nor the manpower or technical capacity, to replicate or maintain these integrated software and hardware solutions at the required scale. Attempting to develop comparable capabilities internally would require recruiting and training highly specialized personnel, establishing new development and integration teams, and investing in infrastructure, tools, and ongoing sustainment. This would include re-establishing security and cloud accreditations (such as FedRAMP and DoD Impact Levels), conducting extensive testing and validation, and developing new data ontologies and integration frameworks. Industry data and prior Army experience indicate that such efforts could cost tens to hundreds of millions of dollars over several years, far exceeding the cost of leveraging existing, proven commercial solutions. Additionally, the risk of technical gaps, interoperability issues, and loss of continuity in ongoing operations would be significant. These efforts would divert critical resources from other Army priorities and could result in capability gaps that directly impact operational effectiveness and mission success.

Conducting individual competitive acquisitions: The Army considered competitive acquisition approaches for individual requirements. Comprehensive market research was conducted, including a Sources Sought notice posted to SAM.GOV on 19

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December 2025, with responses due by 9 January 2026. No qualified vendors were identified who could meet the Army’s full suite of Anduril requirements, including accreditation, integration, and validated operational performance. Pursuing individual full and open competitions for each requirement, which typically requires 12–24 months to execute, would not be a prudent use of time or resources, as it is unlikely to yield additional qualified offerors and would introduce unnecessary delays and administrative burden. The consolidated IDIQ approach for the full suite of Anduril’s offerings leverages pre-negotiated terms, reduces duplication of effort, minimizes protest risk, and allows technical and contracting staff to focus on mission support rather than lengthy acquisition cycles. Relying on individual competitive acquisitions would undermine efforts to consolidate requirements and achieve efficiencies through a single-award IDIQ contract.

Extension of current contracts, agreements, and sub-contracts: Extending existing contracts, agreements, or sub-contracts—including sub-contracts that function as passthroughs—would perpetuate inefficiencies, increase administrative burden, and risk inconsistent pricing and performance. Passthrough sub-contracts, in particular, add unnecessary layers, reduce transparency, and often result in higher costs without adding value. This approach would limit the Army’s ability to achieve economies of scale, standardize technical oversight, and ensure consistent delivery of mission-critical capabilities. It would also complicate contract management and hinder efforts to consolidate requirements under a single, streamlined IDIQ vehicle.

Leveraging existing contract vehicles (e.g., GSA MAS, NASA SEWP, DoW ESI):

These vehicles were considered but do not fully accommodate the sophisticated and integrated nature of the Army’s requirements for Anduril’s comprehensive offerings.

There are typically access fees associated with these vehicles, and their scope do not include the full range of Anduril’s integrated solutions. Additionally, pricing can vary significantly, which may result in higher costs and inconsistent terms. No other market participants other than Anduril possess the unique combination of capabilities, total solutions, and modularity required for this effort.

None of these alternatives are in the best interest of the Government. The only acceptable solution is approval of this justification and proceeding with a single-award, IDIQ.

c. Impact if Not Approved:

Disapproval of this justification will have significant adverse effects on the Army’s ability to fulfill its mission and maintain operational readiness. Without approval to consolidate all Anduril requirements under a single-award IDIQ, the Army will be compelled to pursue multiple, fragmented procurement actions for similar or identical capabilities.

This approach would result in:

Risk of loss of services and therefore loss of life of the Warfighter: Anduril’s products are critical to the Army’s mission and serve to protect the Warfighter. Inability to procure from Anduril would put the Warfighter at risk.

Unacceptable Delays: Fragmented acquisitions would require repeated solicitation, evaluation, and award processes for each requirement. If the Army must conduct separate procurements for each requirement, the cumulative delay could

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7. Efforts to Obtain Competition:

In accordance with FAR 5.201, this action was synopsized to ensure public notice of the Government’s intent. A Sources Sought notice was posted to SAM.GOV on 19 December 2025, with responses due by 9 January 2026. No responses were received from vendors demonstrating the capability to fulfill the Government’s requirements for Anduril’s commercial suite of offerings. As a result, effective competition is not available for this acquisition. Further details regarding market research and outreach efforts are provided in Section 8, “Market Research.”

a. Effective Competition: Because this is a sole source action, effective competition is not anticipated for the SA IDIQ. The Government made reasonable efforts to solicit interest from as many potential sources as practicable, as evidenced by the public posting of the Sources Sought notice. No qualified sources responded, confirming that only Anduril is capable of meeting the Army’s requirements for this procurement.

b. Subcontracting Competition: As part of any contract awarded as the result of this J&A, the prime contractor shall provide to the Government, in accordance with FAR 52.219-9, a Small Business Subcontracting Plan for review and approval. The contract will also include all required subcontracting competition clauses, such as FAR 52.219- 8, Utilization of Small Business Concerns, and FAR 52.244-5, Competition in Subcontracting, to ensure that the prime contractor seeks competitive opportunities for subcontractors to the maximum extent practicable.

8. Actions to Increase Competition: The EC is designed to streamline access to Anduril’s commercial solutions, but the Government will continue to take all practicable steps to ensure sufficient competition on future acquisitions to the maximum extent practicable, including ongoing market research and periodic reassessment of the competitive landscape. Mission partners issuing orders under this EC must conduct market research to ensure competition requirements are met or, if not, properly justify any exceptions, at the ordering activity level. HQDA OCIO will continue to actively monitor the commercial marketplace for potential alternatives, including other commercial solution providers and any future authorized distributors for commercial solutions.

This encompasses software platforms, most notably Anduril’s proprietary, open-architecture, AI-enabled Lattice suite, along with integrated hardware, data, compute infrastructure, and a range of ancillary technical support services. The intent of this EC is to streamline access to Anduril’s existing commercial solutions while ensuring the Government retains the ability to solicit competitive proposals for future programs and requirements.

It will also be incumbent upon mission partners that cut and issue orders under this EC to actively and continuously monitor, engage, and stay abreast of the commercial marketplace for alternatives and emerging technologies or comparable solutions/offerings that may provide cost savings, operational efficiencies, or address

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capability gaps. These mission partners are expected to leverage this market awareness to prevent arbitrary price increases by Anduril and to ensure the Army continues to receive best value.

Any decision to transition to a competitor’s platform will be carefully evaluated based on the Army’s capability requirements, DoW approval, and the potential benefits and costs, including the risks of operational disruption, retraining, and recertification. This EC does not substitute competition for future programs and is not intended to unduly restrict the Government’s ability to pursue competitive acquisitions in the future.

The Army will continuously evaluate emerging capabilities and reassess this consolidation every 18–24 months, as well as at the time of option exercise, to ensure ongoing improvements, optimal performance, and to encourage constant innovation and competition in the market (see Army Open Solicitation: https://sam.gov/opp/cb79d6adaa3a4ae5b175865b2e803365/view). In accordance with FAR 17.207, the Army will conduct a thorough evaluation of pricing and other relevant factors at the time of option exercise to ensure that prices are fair and reasonable and remain consistent with current marketplace comparable offerings.

Only Anduril can directly provide the full suite of their commercial solutions while meeting active provisional authorizations across all relevant impact levels.

9. Market Research:

A Sources Sought was posted to SAM.GOV on 19 December 2025. Responses were due on 9 January 2026. No responses were received from vendors demonstrating the capability to fulfill the Government’s needs.

The vendors that responded are as follows:

On 29 January 2026 the Government requested the above four (4) vendors to confirm whether they are able to supply or provide Anduril capabilities to include the following:

(1) comprehensive accreditations (NIST, Impact Levels, CMMC, etc.)

(2) corresponding commercial offerings inclusive of the GenAI capabilities

(3) integration with tactical data links

(4) tailored data ontology; and

(5) validated operational performance necessary for Army operations.

The request for information indicated that a non-response would be interpreted by the Government as confirmation that the company is unable to provide the required capabilities.

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Of the four (4) vendors above, only responded to the email.

confirmed they are unable to provide the entire bandwidth of Anduril products or the necessary accreditations, tactical data links, data ontology, etc., as detailed above.

Evaluation Results:

1. Unable to provide Anduril products/services:

o Comprehensive Accreditations: is unable to provide the active authorizations across all Impact Levels (IL2- IL6), limiting its ability to support unclassified, sensitive, and classified workloads simultaneously.

o GenAI Capabilities: is unable to provide Generative AI capabilities, which are critical for advanced data analysis and decision-making in battlefield applications.

o Integration with Tactical Data Links: is unable to provide tactical data link integration, which is essential for command and control (C2), intelligence fusion, targeting, and fires.

o Tailored Data Ontology: is unable to provide proprietary data ontology, which is essential for real-time data fusion, operational planning, logistics optimization, and intelligence analysis.

o Validated Operational Performance: is unable to provide validated operational performance as a single vendor solution for Army operations.

2. lacks the capabilities to support the effort, as no response to the Government’s 29 January 2026 request for additional information was received. A non-response was interpreted by the Government as confirmation that the company is unable to provide the required capabilities.

3. lacks the capabilities to support the effort, as no response to the Government’s 29 January 2026 request for additional information was received. A non-response was interpreted by the Government as confirmation that the company is unable to provide the required capabilities.

4. lacks the capabilities to support the effort, as no response to the Government’s 29 January 2026 request for additional information was received. The Government received an undeliverable status on the request for information email to

Market research on appear to indicate that this company is an online social platform for detection, publication and negotiation of public contracts.

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awards as detailed in Table 2. As part of these competitive actions, the Army conducted market research in compliance with FAR Part 10, identifying and evaluating vendors in the marketplace. These efforts included technical capability assessments to inform acquisition planning and ensure compliance with competition requirements. The consolidation of these requirements under a single contract vehicle is intended to streamline procurement, enhance oversight, and enable more effective management of pricing and performance for Anduril solutions. Across the competed contracts and subcontracts detailed in Table 2, Anduril was selected based on its distinctive combination of features that support national security operations and meet the Army’s mission requirements. The Army’s market research and competitive evaluations confirm that Anduril’s solutions are uniquely positioned to meet mission requirements while maintaining operational continuity and security, offering a combination of capabilities and technical specifications not found in any other total solution.

This action is further justified by the Army’s significant investment in and integration with Anduril’s proprietary, open-architecture, AI-enabled Lattice suite and related hardware and services, as established through multiple competitive awards and detailed in Table 2. As part of these competitive actions, the Army conducted market research in compliance with FAR Part 10, identifying and evaluating vendors in the marketplace. These efforts included commercial technical capability assessments from each offering. The Army’s market research and competitive evaluations demonstrate that Anduril’s solutions are uniquely positioned to meet mission requirements without compromising operational continuity, security, or readiness via a suite of capabilities and offerings. The establishment of a single-award IDIQ enterprise agreement for Anduril will streamline procurement, reduce administrative burden, and ensure timely access to critical capabilities, while maintaining flexibility to consider other commercial solutions as appropriate.

10. Interested Sources:

As described above, the following sources have written to express interest:

11. Other Facts:

a. Procurement history.

While HQDA OCIO and the Army have previously acquired individual Anduril components, including core software, data, compute infrastructure, and ancillary support services through full and open competition, this procurement represents a fundamentally new requirement. The consolidation of these previously disparate elements (as outlined in Table 2 below) into a unified, single point of use vehicle for

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integral technical support services.

12. Technical Certification:

I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

13. Requirements Certification:

I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

14. Fair and Reasonable Cost Determination:

I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable. Price analysis, such as comparison to previous prices paid, published pricing, and the IGE will be used to determine the price to be fair and reasonable in accordance with FAR 15.4. Certified cost and pricing data is not required as the products and related incidental services being acquired are commercial items and services IAW FAR 15.403-1(c)(3).

15. Contracting Officer Certification:

I certify that this justification is accurate and complete to the best of my knowledge and belief.