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.
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
Department and Agencies
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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
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2026-15549, Information Collection Requirement; Defense Federal Acquisition Regulation Supplement (DFARS) Part 225, Foreign Acquisition and Related Clauses
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