2026-09038RuleSignificantWallet

DoD Eases Greenhouse Gas Reporting for Contractors – Paperwork Relief

Published Date: 5/7/2026

Rule

Summary

Starting May 7, 2026, the Department of Defense won’t make most new defense contractors share their greenhouse gas emissions unless it’s really needed for the contract. This change helps nontraditional contractors avoid extra paperwork, but DoD can still ask for info if it’s directly tied to the job. It’s a smart move to keep things fair and focused without slowing down important defense work.

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Analyzed Economic Effects

3 provisions identified: 2 benefits, 1 costs, 0 mixed.

No required GHG inventories for certain bidders

Starting May 7, 2026, DoD contracting officers must not require nontraditional defense contractors to disclose a greenhouse gas inventory or any other greenhouse gas report as a condition of winning a contract. This prohibition applies unless an exception or waiver is granted under the rule.

DoD cannot use GHG reps in awards for nontraditional firms

As of May 7, 2026, DoD contracting officers must not consider greenhouse gas emission information from annual representations and certifications when awarding contracts to nontraditional defense contractors. The rule specifically bars using information that might be provided under FAR 52.204-7; FAR 52.204-8 paragraph (c)(1)(xix); FAR 52.212-3 paragraph (t); and FAR 52.223-22.

Limited exceptions and contract-by-contract waivers allowed

Even though disclosures are generally barred, DoD can require greenhouse gas information in two limited ways: an exception if a contracting official at least one level above the contracting officer determines it is necessary to verify a voluntary disclosure, and a contract-by-contract waiver by the head of the contracting activity if the information is directly related to contract performance. Any waived requirement must be clearly described in the contract.

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Key Dates

Published Date
Rule Effective
5/7/2026
5/7/2026

Department and Agencies

Department
Independent Agency
Agency
Defense Department
Defense Acquisition Regulations System
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