The FY2027 Continuing Resolution Is Law. What Sections 102(a) and 102(b) Do to Your Estimates.

What changed

On 2 September 2026 the President signed H.R. 6500, the Continuing Appropriations and Extensions Act, 2027. It became Public Law 119-103. The Act provides continuing appropriations to federal agencies through 11 December 2026 and extends authorities for a range of programs including surface transportation and veterans programs. No full-year FY2027 appropriations act had been enacted as of the signing date.

For anyone building or defending a defense estimate, the operative text is sections 102 through 104, and it is worth reading rather than summarizing from memory. Section 102(a) provides that no appropriation, funds, or authority made available under section 101 for the Department of Defense shall be used for three things.

First, under 102(a)(1), the new production of items not funded for production in fiscal year 2026 or prior years. Second, under 102(a)(2), the increase in production rates above those sustained with fiscal year 2026 funds. Third, under 102(a)(3), the initiation, resumption, or continuation of any project, activity, operation, or organization for which appropriations, funds, or other authority were not available during fiscal year 2026. The Act defines that third category explicitly, down to the P-1 line item within a budget activity and the R-1 line item including program element and subprogram element.

Section 102(b) separately bars using those funds to initiate multi-year procurements utilizing advance procurement funding for economic order quantity procurement, unless specifically appropriated later. Section 103 makes section 101 appropriations available to the extent and in the manner the pertinent appropriations act would provide. Section 104 restates the no-new-starts rule for the government generally, except as otherwise provided in section 102.

Why it matters for estimating and pricing

A continuing resolution is not just a funding level. It is a set of prohibitions that can invalidate specific assumptions inside an estimate, and the three above map directly onto things estimators routinely assume.

A production ramp assumed to begin in the first quarter of FY2027 runs into 102(a)(2) if it raises the rate above what FY2026 funds sustained. Learning curve and rate effects modeled off that ramp move with it. A program whose first production article was to be funded in FY2027 runs into 102(a)(1). An economic order quantity buy planned to be initiated with FY2027 advance procurement runs into 102(b), which matters because EOQ savings are often carried in the estimate as a discrete quantity discount. And any new start, at the P-1 or R-1 line item level, runs into 102(a)(3) for the duration.

The practical consequence is schedule, and schedule is cost. Work that slips out of the CR period does not usually reappear compressed; it stretches, and stretched schedules carry level-of-effort and escalation. If an estimate assumes an award, a rate increase, or an EOQ commitment before 11 December 2026, that assumption now needs either a documented basis for why it survives the CR or an explicit alternative case. The same applies to a basis of estimate already delivered: this is the kind of change that warrants a note to the customer rather than a silent carry-forward.

The 11 December date is the one to plan against, not the one to count on. A CR that expires mid-December in an election year can be extended, replaced by full-year appropriations, or followed by another stopgap, and each of those produces a different FY2027 execution profile. Building the estimate so the funding assumption is visible and swappable is worth more than picking the right outcome.

Primary sources

H.R. 6500, Continuing Appropriations and Extensions Act, 2027, Public Law 119-103, signed 2 September 2026. Enrolled bill text: https://www.congress.gov/119/bills/hr6500/BILLS-119hr6500enr.htm

Bill actions and public law designation: https://www.congress.gov/bill/119th-congress/house-bill/6500/all-actions

White House statement on signing, 2 September 2026: https://www.whitehouse.gov/briefings-statements/2026/09/congressional-bill-h-r-6500-signed-into-law/