DoD Extends Paperwork Chase for Tech Data Rights
Published Date: 1/14/2026
Notice
Summary
The Department of Defense wants to keep collecting info from businesses about rights to technical data and software for three more years. They’re asking for your thoughts by March 16, 2026, to make sure this process is useful and not too much work. If you work with DoD contracts involving tech data or software, this affects you and helps keep things clear and fair.
Analyzed Economic Effects
4 provisions identified: 0 benefits, 3 costs, 1 mixed.
DoD extends data-collection for 3 years
The Department of Defense proposes to extend its information collection about rights in technical data and computer software for an additional period that would expire three years after OMB approval. The existing OMB approval runs through January 31, 2026, and DoD will accept public comments on the proposal through March 16, 2026.
Marked identification of limited-rights data
If you supply technical data or computer software under DoD contracts, DFARS clauses require you to identify and mark any data or software that you provide with limited rights. Specific clauses cited include DFARS 252.227-7013, 252.227-7014, and 252.227-7017.
Recordkeeping and validation obligations
DFARS requires contractors and subcontractors to maintain records and be prepared to furnish written justification for any asserted restrictions on the Government's rights to use or release data. Clauses cited include DFARS 252.227-7019 and 252.227-7037, which require validation of restrictive markings.
Use agreements and prior-delivery identification
Contractors receiving restricted government data may need to sign use and non-disclosure agreements before receiving it (DFARS 227.7103-7 and 252.227-7025). Offerors also must identify any technical data or software previously delivered to the Government so DoD can avoid paying for rights it already owns (DFARS 252.227-7028).
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Key Dates
Department and Agencies
Related Federal Register Documents
2026-05935 — Information Collection Requirement; Defense Federal Acquisition Regulation Supplement; Rights in Technical Data and Computer Software
The Department of Defense is renewing its paperwork rules about who owns technical data and software rights in defense contracts. This affects over 46,000 businesses that work with the DoD, requiring them to provide info about their software and data rights. Comments on these rules are open until April 27, 2026, and the paperwork takes about 1.6 hours per response.
2026-03870 — Information Collection Requirement; Defense Federal Acquisition Regulation Supplement; Performance-Based Payments-Representation (OMB Control Number 0750-0001)
The Department of Defense wants to keep collecting info from businesses about performance-based payments to make sure everything runs smoothly. This info collection, affecting about 438 companies, is up for a three-year extension with no big changes or extra costs. Comments on this plan are open until April 27, 2026, so now’s the time to speak up!
2025-17359 — Defense Federal Acquisition Regulation Supplement: Assessing Contractor Implementation of Cybersecurity Requirements (DFARS Case 2019-D041)
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The Department of Agriculture is asking for public feedback on a form they use to manage debt settlements for rural electric loans. This helps make sure the info they collect is useful and not too much work for folks involved. Comments are open until February 13, 2026, so anyone affected by these loans should speak up!
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