Everything-as-a-Service? DOD’s AaaS Pilot and What It Means for GOVCON

All Opinions expressed are my own. Once upon a time, back when the Federal Acquisition Regulation still felt mildly comprehensible, we had a relatively tidy definition of cloud computing. NIST Special Publication 800-145 provided us with a framework: Software-as-a-Service (SaaS), Platform-as-a-Service (PaaS), and Infrastructure-as-a-Service (IaaS). It wasn’t perfect, but at least it gave contracting officers, vendors, and program managers a shared language. Then Congress got creative. Thanks to Section 809 of the FY24 National Defense Authorization Act (NDAA), the Department of Defense now has a new procurement experiment: the Anything-as-a-Service (AaaS) Pilot Program . The name alone is a red flag. Anything? Really? And yes, they mean it. In early May 2025, the Office of the Director for Defense Pricing, Contracting, and Acquisition Policy (DPCAP) released guidance expanding the definition of AaaS far beyond its cloud roots. Under this new model, a wide arr...