State Wants Feedback on Export Violation Form
Published Date: 7/1/2026
Notice
Summary
The Department of State wants your thoughts on a form that companies and people must fill out if they break rules about exporting defense stuff. This helps keep track of violations under the Arms Export Control Act. You’ve got until July 31, 2026, to share your feedback—no money changes now, just making sure the process works well and isn’t too hard.
Analyzed Economic Effects
4 provisions identified: 1 benefits, 1 costs, 2 mixed.
Voluntary disclosure can affect penalties
If you make a voluntary disclosure, DDTC may treat it as a mitigating factor when deciding administrative penalties; however, failure to disclose is an adverse factor and the matter might be referred to the Department of Justice for possible criminal prosecution. The Department of Justice is not required to give weight to the voluntary nature of the disclosure.
Who must (voluntarily) disclose ITAR breaches
If you are an individual or company engaged in exporting, temporarily importing, or brokering defense articles or defense services and you committed an ITAR violation, you are the intended respondent for the voluntary disclosure form (Form DS-7787). The Department estimates 14,500 respondents and 600 responses for this collection; responding is voluntary.
Paperwork time burden per disclosure
Each voluntary disclosure (Form DS-7787) is estimated to take an average of 10 hours to complete, with a total estimated burden of 6,000 hours across all responses. The collection frequency is "On Occasion" and the Department is seeking comments on the time and cost estimates.
Disclosure moves to electronic form DS-7787
DDTC has developed a discrete electronic form (Form DS-7787) to collect voluntary disclosures, replacing historical hard-copy submissions. The Department says electronic submission will allow both DDTC and respondents to more easily track submissions.
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