SIIA Joins Associations in Commenting on DFARS Rule for Foreign Obligations Disclosure

The Software & Information Industry Association (SIIA), along with several leading industry associations, submitted comments to the Department of Defense (DoD) regarding the proposed rule under DFARS Case 2018–D064, which mandates disclosure of contractors’ foreign obligations as outlined in Section 1655 of the National Defense Authorization Act for Fiscal Year 2019. While recognizing the importance of transparency, the associations raised concerns that the proposed rule unnecessarily broadens disclosure requirements, particularly for commercial and Commercially Available Off-the-Shelf (COTS) products, beyond the scope of the legislation. This overreach, they argue, risks creating compliance burdens, hindering innovation, and reducing participation in the defense industrial base. The letter includes detailed recommendations to align the rule with legislative intent, streamline compliance, and support the DoD’s mission while maintaining operational efficiency and market accessibility.