On March 31, 2026, the Executive Office of the President, Office of Management and Budget (OMB), issued Memorandum M-26-10 titled, “Reinforcing Transparency, Accountability, and Oversight of Federal Technology,” (Memorandum) containing a new policy designed to reinforce oversight, transparency, and accountability across federal technology programs, increase accountability for agency chief information officers (CIOs), and enhance information sharing among government agencies. OMB issued the policy in furtherance of several executive orders (EOs) issued by President Trump, including: EO 13833, “Enhancing the Effectiveness of Agency Chief Information Officers,” EO 14240, “Eliminating Waste and Saving Taxpayer Dollars by Consolidating Procurement,” and EO 14243, “Stopping Waste, Fraud, and Abuse by Eliminating Information Silos.”
Under the new OMB guidance, agency CIOs identified under the Chief Financial Officers Act, 31 U.S.C. § 901(b), except for the Department of War CIO, are required to “monitor the performance of their agencies’ IT programs, evaluate the performance of those programs, and advise the agency head on whether to continue, modify, or terminate a program or project.” Specifically, beginning in May 2026, the CIOs must submit monthly reports to OMB detailing approved IT contracts and agreements, including contracts that “directly enable or facilitate interaction between the public and the Federal Government through digital services.” These reporting requirements are scheduled to run through October 2026.
The Memorandum also directs agencies to eliminate “information silos” for federal technology acquisitions by actively facilitating the collection and sharing of IT-related acquisition data consistent with OMB Circular No. A-137, “Strategic Management of Acquisition Data and Information.” Recognizing that contractors “may have information that the Government needs to make data-driven decisions around IT acquisitions,” OMB instructs agencies to request from current and future vendors information on pricing and utilization rates, and to compile this information in machine-readable formats for sharing across the federal government. To do so, OMB explicitly instructs agencies to include provisions in solicitations and contracts after March 31, 2026, the date of the Memorandum, that require IT vendors to disclose utilization and pricing information to the government without limiting the extent to which that information may be shared across agencies.
Contractors should expect to see provisions requiring this information in new solicitations and contracts. As explained in the Memorandum, the General Services Administration (GSA) will support agencies in rolling out these provisions by sharing “best practices, sample contract language, and templates, as appropriate,” but there may be inconsistent approaches and language across agencies in the implementation of these new disclosure requirements.
Contractors will also need to be mindful of what they disclose to the Government. The sensitive information disclosed may be shared with government enforcement stakeholders, which may lead to audits, inquiries, or investigations. Likewise, contractors may need to seek assurance from the government that this sensitive information will not be accessed by other third parties, such as government contractors, that may support agencies in the collection and review of this information.