DoD Tells Auditors: Spill the Beans on Past Troubles
Published Date: 1/5/2026
Notice
Summary
The Department of Defense is updating rules for companies that audit its finances. If you’re an accounting firm working with the DoD, you’ll need to share info about any past disciplinary actions before getting or renewing contracts. This change affects about a dozen firms, with a small paperwork impact, and comments are open until February 4, 2026.
Analyzed Economic Effects
4 provisions identified: 1 benefits, 3 costs, 0 mixed.
Preaward Disclosure for Audit Firms
If you are an accounting firm that provides financial statement auditing or audit remediation services to the Department of Defense, you must disclose details of any disciplinary proceedings involving the firm or its associated persons to DoD before any contract action, including award, renewals, and amendments. The rule implements NDAA section 1006 and applies when firms respond to solicitations or are awarded contracts for those services.
Requirement Extended Beyond Accounting Firms
DoD is extending the same preaward and postaward disclosure requirement to firms other than accounting firms that provide financial statement auditing or audit remediation services in support of DoD audits. That means non-accounting firms that perform those covered services must also disclose disciplinary proceedings before contract actions.
Disclosures Protected as Confidential
Disclosures of disciplinary proceeding details must be treated as confidential to the extent required by the court or agency where the proceeding occurred and consistent with protections or privileges established by Federal law, per the NDAA amendment. This affects how DoD will handle the information firms submit.
Estimated Paperwork Burden for Firms
DoD estimates this information collection will affect 12 respondents, with 35 responses per respondent (420 annual responses), an average burden of 0.062 hour per response, and 26 annual burden hours in total. The collection is described as a small paperwork impact.
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Key Dates
Department and Agencies
Related Federal Register Documents
2026-09067, Defense Federal Acquisition Regulation Supplement: Mitigating Risks Related to Foreign Ownership, Control, or Influence (DFARS Case 2021-D011)
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2026-09038, Defense Federal Acquisition Regulation Supplement: Disclosure of Greenhouse Gas Emissions (DFARS Case 2024-D021)
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.
2026-16682, Information Collection Requirement; Defense Federal Acquisition Regulation Supplement (DFARS), DoD Mentor-Protégé Program
The Department of Defense wants to keep collecting info for its Mentor-Protégé Program, which helps businesses team up and grow. This extension affects about 96 businesses and won’t cost extra but asks for feedback by October 16, 2026. The goal is to make sure the info collected is useful and easy to provide for the next three years.
2026-15545, Information Collection Requirement; Defense Federal Acquisition Regulation Supplement, Contract Pricing
The Defense Acquisition Regulations System has submitted to OMB for clearance the following proposal for collection of information under the provisions of the Paperwork Reduction Act.
2026-15544, Information Collection Requirement; Defense Federal Acquisition Regulation Supplement (DFARS) Part 204, Administrative Matters, and Related Clause at 252.204; OMB Control Number 0704-0225
The Defense Acquisition Regulations System has submitted to OMB for clearance the following proposal for collection of information under the provisions of the Paperwork Reduction Act.
2026-15549, Information Collection Requirement; Defense Federal Acquisition Regulation Supplement (DFARS) Part 225, Foreign Acquisition and Related Clauses
The Defense Acquisition Regulations System has submitted to OMB for clearance the following proposal for collection of information under the provisions of the Paperwork Reduction Act.
Previous / Next Documents
Previous: 2025-24248, Information Collection Requirements; Defense Federal Acquisition Regulation Supplement (DFARS); Cyber Incident Reporting and Cloud Computing
If you’re a business working with the Department of Defense, you’ll need to keep reporting cyber incidents and how you use cloud computing to stay safe. These updates make sure everyone protects important defense info and follows clear rules, with about 2,000 companies expected to report roughly 16,000 times a year. Comments on these rules are open until February 4, 2026, so get ready to stay secure and compliant!
Next: 2025-24250, Information Collection Requirement; Defense Federal Acquisition Regulation Supplement; Bonds and Insurance
The Department of Defense is renewing a paperwork rule that affects businesses working on defense contracts. They need to keep collecting info about bonds, insurance, and accident reports to make sure contractors are covered and costs are fair. Comments on this update are open until February 4, 2026, and it won’t cost businesses extra time beyond what they already spend.