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 array of services, many of which would never qualify as “as-a-Service” by commercial standards, are now in play.

So, What Is AaaS Now?

According to the DPCAP memo, AaaS is defined as a “technology-supported capability” delivered via any mix of software, hardware, data, or labor, and priced on a fixed or metered usage basis. That’s the core idea. But the examples cited stretch the bounds of logic and language.

Newly aligned Product and Service Codes (PSCs) under this framework include:

  • DB10 – Compute-as-a-Service (Mainframes/Servers)

  • DE10 – End-User-as-a-Service

  • DK10 – Storage-as-a-Service

  • DC01 – Data Center Support Services

  • X1AA – Lease/Rental of Office Buildings

Yes—renting office space is now an “as-a-Service” capability.

This isn’t just mission creep; it’s definitional drift. The Pentagon has effectively turned “as-a-Service” into a philosophical question.

Why It Matters for Contractors

Despite the naming chaos, the AaaS Pilot is a serious policy initiative with significant implications for government contractors, especially those delivering recurring, outcome-based, or tech-enabled services.

Here’s why GOVCON should be paying attention:

1. Sole Source Pathways—No Full & Open Required

One of the most prominent features of the pilot is that it removes the requirement for full and open competition. Contracting officers can award directly, so long as the requirement qualifies under AaaS and the rationale is documented. This could fast-track awards for specialized, metered capabilities.

2. Pricing Flexibility—No Certified Cost or Pricing Data

Participants in the pilot are exempt from certified cost and pricing data (FAR 15.403). Contracting officers can use other accepted pricing methodologies under FAR 15.4 and DFARS 215.4. This opens the door for commercial pricing models that previously ran into regulatory friction.

3. COs Lead, Not PMs

This is a sleeper change with significant implications: contracting officers, not program offices, initiate the pilot designation. Capture and BD teams accustomed to engaging primarily with project managers (PMs) will need to recalibrate. Early CO engagement is now a strategic, not optional, priority.

4. Emphasis on Fixed-Price and Metered Models

The pilot strongly favors fixed-price or subscription-style pricing structures—anything that can be metered. Vendors offering scalable, tech-backed services will find this appealing. Others may need to revisit their delivery and pricing models.

5. The Definitions Are… Loose

There’s a real risk of overreach here. While the pilot invites creativity, vendors should avoid dressing up conventional labor-based services as “as-a-Service” without clear, metered capability delivery. Misalignment with the pilot's spirit could invite scrutiny and protest.

What GOVCON Should Do Now

Whether you’re in IT, digital transformation, cybersecurity, or other services, the AaaS Pilot should be on your radar. It offers a rare moment where innovation in contracting isn’t just permitted—it’s encouraged.

Consider the following steps:

  • Evaluate your offerings. Do you have a fixed-price, technology-supported capability that delivers measurable outcomes?

  • Build relationships with COs. They’re the ones who can initiate AaaS classification—and potentially bypass lengthy competitions.

  • Stay informed on DPCAP updates. The policy framework is evolving, and early movers may influence how it’s shaped.

  • Pilot before you propose big. A modest, well-scoped effort under the AaaS model could demonstrate value and lay the groundwork for future enterprise engagements.

AaaS Is Real—Even If It’s Weird

The AaaS Pilot Program is a bold, yet imperfect, attempt to shift how the DOD acquires tech-enabled capabilities. It trades clarity for flexibility, standardization for speed. For some, it will be a distraction. For others, it’s a real opportunity to show that outcome-based, subscription-style services can work in federal acquisition.

Just don’t call your janitorial contract “Cleaning-as-a-Service.” Even the Pentagon has its limits.

Location: Washington, DC, USA

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