What must contractors do to comply with the proposed DFARS FOCI beneficial ownership and disclosure rule? 2026

According to GSA guidelines, contractors must begin internal discovery and data collection now to meet proposed DFARS/FOCI disclosure requirements. This opening summary names GSA, SBA, FAR, DoD, DCSA and OMB because each has a role: GSA coordinates acquisition policy, SBA addresses small business impacts, FAR governs contracting practices, DoD issues DFARS rules, DCSA will receive and vet FOCI submissions, and OMB oversees cross-agency data use. The May 7, 2026 proposed DFARS rule published in the Federal Register requires contractors to provide beneficial ownership information (BOI) and FOCI-related documentation to DCSA for entity vetting and FOCI mitigation assessments. Contractors must identify ultimate beneficial owners holding greater than 10 percent ownership and disclose foreign affiliations, board control, and material relationships, and must provide supporting corporate documents, shareholder registries, and organizational charts. The proposed rule applies to offerors and contractors for DoD prime and major subcontract awards; government-wide acquisition contractors with DoD involvement should assume applicability. Contractors should map their corporate tree, capture ownership percentages, and create an auditable record of communications. Expect DCSA to require electronic submissions in a standardized format and to start scheduling entity vetting shortly after the final rule's effective date.