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 | 3 min read | 09.15.26
Until recently, Belgian law did not have a general regulatory framework for internal investigations. Companies wishing to conduct an investigation had to navigate a fragmented set of rules that covered general principles and, to a limited extent, privacy and employee rights. The application of these rules to internal investigations was not clear, and it was therefore often difficult to put the rules into practice. This legal vacuum created significant risks, both for the integrity of the investigation itself and for the admissibility of any evidence gathered.
Client Alert | 7 min read | 09.14.26
AI in Life Sciences: Ten Legal Considerations and Risks of AI Use in Drug Discovery and Development
Client Alert | 6 min read | 09.14.26
Mental Health Parity Bulletin Restates Best Practices for Evaluating Compliance
Client Alert | 6 min read | 09.11.26
It’s LIVE: The Cyber Resilience Act Reporting Is Mandatory as of Today - 11 September 2026

