Blog entry: Once upon a time, government had an exception for onerous procurement rules for software you could walk into a store and buy. If you wanted copies of Windows, fine, just buy copies of windows. They called it “COTS”: Commercial Off-The-Shelf software. And that became a big loophole.
It’s only COTS if you can use it the next day and configure it yourself, otherwise it’s just sparkling custom software. https://waldo.jaquith.org/blog/2025/01/customized-cots-when-government-demands-to-be-lied-to/