IR&D Reporting Requirements Reinstated
Client Alert | 1 min read | 01.30.12
In a final rule published today, the DFARS were amended to reinstate a requirement that was eliminated from the regulations in the early 1990s, providing that as a condition of allowability for Independent Research and Development (IR&D) costs, major contractors must submit to DoD at least annually technical descriptions of the IR&D projects that the contractor claims as allowable. In response to criticism of a draft regulation proposing a $50,000 coverage threshold, the final rule limits mandatory reporting to “major contractors” that allocate more than $11 million annually to “covered contracts” (a term that excludes fixed-price contracts without cost incentives), leaves largely to the contractor’s discretion how much detail needs to be reported in the on-line template through which the reports must be submitted, encourages voluntary reporting by contractors not subject to the mandatory requirement, and promises that the reports will be exempt from disclosure under the Freedom of Information Act.
Contacts
Insights
Client Alert | 10 min read | 12.24.25
Since the signing of Executive Order 14187 (“Protecting Children from Chemical & Surgical Mutilation”) in late January 2025, the Trump Administration has made its skeptical stance on gender-affirming care—especially regarding services provided to minors—clear.
Client Alert | 3 min read | 12.24.25
Keeping it Real: FTC Targets Fake Reviews in First Consumer Review Rule
Client Alert | 5 min read | 12.23.25
An ITAR-ly Critical Reminder of Cybersecurity Requirements: DOJ Settles with Swiss Automation, Inc.
Client Alert | 2 min read | 12.23.25
Record-Setting False Claims Act Settlement Highlights DOJ Commitment to Customs Enforcement

