The Department of War submitted a legislative proposal to Congress in June 2026 seeking to substantially weaken post-service lobbying restrictions for mid-grade Pentagon officials, targeting Section 1045 of the Fiscal Year 2018 National Defense Authorization Act — bipartisan legislation championed by the late Senator John McCain to slow the military-industrial revolving door. The proposal was first reported on June 14, 2026, by The Daily Caller.
What Section 1045 Currently Requires
Enacted in 2018 with broad bipartisan support, Section 1045 of the FY2018 NDAA went significantly further than the pre-existing baseline lobbying statute, 18 U.S.C. § 207(c). The older federal law restricted only direct lobbying contacts — meaning phone calls, meetings, and written communications with government officials — while permitting departing officials to immediately begin advising defense contractors on strategy, drafting lobbying materials, and coaching corporate teams behind the scenes.
McCain's Section 1045 closed that gap. Under current law, O-7 and O-8 rank military officers — one-star and two-star generals and admirals — along with their civilian grade equivalents, face a one-year cooling-off period before engaging in any lobbying activities at the Department of Defense. That includes behind-the-scenes strategy work, drafting communications, and advising, not merely direct lobbying contacts. O-9 and O-10 officers — three-star and four-star generals and admirals — face a two-year cooling-off period under the same expanded definition.
The scope is department-wide: a departing two-star Navy admiral cannot lobby Army or Air Force program offices any more than Navy offices during the one-year window. Notably, Section 1045 did not restrict lobbying directed at Congress — only at the Defense Department itself — leaving that avenue open even under the current, stricter framework.
What the Pentagon Is Proposing
The Pentagon's FY2027 NDAA submission would make three structural changes to Section 1045. First, it would eliminate entirely the one-year cooling-off period for O-7 and O-8 officers and their civilian equivalents, meaning one-star and two-star generals and admirals could begin lobbying activities the day after separating from service. Second, it would remove the one-year restriction on behind-the-scenes lobbying activities for O-7 and O-8 officials — collapsing the broader Section 1045 standard back toward the narrower 18 U.S.C. § 207(c) baseline for that tier. Third, it would narrow any remaining restrictions to apply only when a former official appears before or communicates with the specific department office where they served within their final year of government employment, rather than the entire Defense Department.
The practical consequence is significant. Under the proposal, a retiring two-star general who spent the final years of a career overseeing Navy ship programs could immediately begin lobbying Air Force and Army acquisition offices upon departing service. Only communications directed at the specific Navy office where that officer served would remain subject to any cooling-off restriction. The two-year cooling-off period for O-9 and O-10 officers would be retained, though it too would be narrowed to the specific-office standard rather than department-wide coverage.
The Department of War's stated rationale is that the current restrictions create a significant risk of reducing government access to the knowledge and expertise of former Defense officials, including during periods involving national security matters. Critics read that framing as an admission that experienced personnel are departing earlier than desired precisely because the lobbying window limits their private-sector earning potential — and that the department's preferred remedy is to shrink the window rather than address that underlying incentive structure.
Industry Context
The proposal arrives as defense revenues have surged for major contractors. Boeing's 2025 revenue reached approximately $89.5 billion, a 34 percent increase from 2024, while its defense segment backlog stood at $85 billion as of year-end. RTX Corporation saw its sales increase roughly 10 percent over the same period, with executive compensation among named officers rising an average of 26 percent. Boeing holds a $2.7 billion contract to produce seekers for Patriot missiles, while Raytheon — an RTX subsidiary — received a $3.5 billion AMRAAM missile production contract in July 2025. Both companies stand to benefit from faster access to newly-departed senior Pentagon officials across active acquisition programs in all service branches.
Mid-grade officers — the O-7 and O-8 cohort the proposal would fully exempt — are precisely the officials who manage major acquisition programs at the program executive officer and deputy program manager levels, making their post-service advisory relationships particularly valuable to contractors pursuing new or follow-on contracts.
The proposal is distinct from routine NDAA housekeeping. Section 1045 was itself an addition to existing law, inserted specifically because Congress determined that 18 U.S.C. § 207(c) was insufficient to address the scope of the revolving-door problem. Rolling back the 2018 additions while retaining only the older statute's narrower framework represents a substantive policy reversal, not a technical cleanup.
What It Means for Contractors
- Faster access to mid-grade talent: If enacted, the proposal would allow contractors and consulting firms to bring on O-7 and O-8 retirees immediately following separation, without waiting through a one-year window. Firms that currently plan 12-month gaps in advisory timelines for this cohort should model the business case under the new rules now, before FY2027 NDAA conference.
- Behind-the-scenes advisory work reopens sooner: The elimination of the behind-the-scenes restriction for O-7 and O-8 officials means recently separated one-star and two-star officers could advise on proposal strategy, draft communications, and coach BD teams without waiting — closing the gap that currently separates overt lobbying from shadow consulting for that tier.
- Compliance mapping changes for cross-service hires: The shift to a specific-office standard rather than department-wide coverage means compliance officers will need to map each hire's last assignment precisely. A hire that was previously off-limits for Army BD due to department-wide restrictions may become eligible for that work, while targeted contacts with the former official's specific Navy office remain restricted. Update your post-government employment review templates now.
- Watch the conference markup: The proposal is a Pentagon submission, not yet law. The Senate Armed Services Committee, which has historically been protective of the McCain-era restrictions, will be the key venue. Contractors and trade associations should track SASC markup language closely through summer 2026, as the final NDAA conference language could preserve, modify, or strip the proposal entirely.
