One of the most closely monitored provisions of the 2018 National Defense Authorization Act (NDAA), Section 846, directed the General Services Administration (GSA) to create a new e-commerce portal for the sale of commercial goods.  Section 846 established delayed implementation of the new e-commerce portal, which is set to occur in phases that each require distinct action items and submissions.

• Phase 1 requires the Office of Management and Budget (OMB), in consultation with the GSA, to create an implementation plan and schedule for carrying out the e-commerce portal program.
• Phase 2 requires OMB and GSA to prepare recommendations for any changes to – or exemptions from – laws necessary for effective implementation of the program within one year of submitting the implementation plan and schedule contemplated under Phase 1.
• Phase 3 requires OMB and GSA to create guidance for the e-commerce portal program within two years of submitting the implementation plan and schedule contemplated under Phase 1.

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Holland & Knight’s analysis of Section 846 is available here, and the original Thornberry acquisition reform bill that started this is available here.