The Office of Management and Budget (OMB) is pushing agencies to be more transparent, accountable, and efficient in their IT contracting practices. In a memorandum released March 31, 2026, M-26-10, Reinforcing Transparency, Accountability, and Oversight of Federal Technology, OMB Director Russell Vought directs federal agency Chief Information Officers (CIOs) to increase transparency and accountability in IT contracting and to eliminate information silos in federal technology acquisitions. The memo has two distinct sections with different scopes — and contractors need to understand which one applies to them.

Monthly IT Contract Reporting

The first section, focused on empowering CIOs as strategic partners, applies only to covered Chief Financial Officers (CFO) Act agencies — in other words, civilian agencies — explicitly excluding the Department of War.

Requirements for federal agencies:

• Beginning in May 2026, CIOs at these agencies must report all personally approved IT contracts, as well as any delegee-approved contracts that enable public-facing digital services, to OMB monthly by the 10th of each month. This reporting requirement runs through October 2026, covering six monthly reporting cycles, though OMB reserves the right to extend it.

IT Vendor Utilization and Pricing Data Reporting

The second section is broader and applies to all agencies — including the Department of War. The only carve-out is for national security systems (NSS), which are explicitly excluded, though agencies are encouraged to apply these practices to NSS to the extent practicable.

Requirements for federal agencies:

• Effective immediately, all agencies must request that current IT vendors provide utilization rates and pricing data for hardware, software, and services.
• Going forward, new solicitations and contracts must include provisions requiring vendors to disclose utilization and pricing information, and it must be compiled in a machine-readable, open standard format and shared with OMB and the General Services Administration (GSA) upon request.

Unlike Section 1, Section 2 has no sunset date — these are standing requirements.

Contractor Implications

CIO Reporting Raises Accountability, but Could Slow Procurements

For civilian agency IT contractors, the new CIO reporting requirement adds a layer of senior accountability to the contract approval chain that was not previously subject to this level of centralized visibility. Every IT contract must be reviewed and approved by the agency CIO — or a delegee for digital services contracts — and those approvals will now flow to OMB on a monthly basis. Contractors at covered civilian agencies should anticipate the possibility of longer approval cycles and, potentially, greater scrutiny of contract proposals as CIOs exercise the oversight authority that this memo reinforces. Contractors selling exclusively to the Department of War or working only on NSS are not affected by this provision.

Pricing and Utilization Disclosure Will Increase Vendor Price Pressures and Administrative Burdens

This is where the memo has the broadest reach — and the most significant implications for contractors. Except for NSS-related contracts, existing vendors across all agencies, including the Department of War, will be asked to voluntarily provide utilization rates and pricing data for their IT hardware, software, and services. That includes resellers, third-party vendors, and manufacturers, suggesting that primes may bear responsibility for ensuring subcontractor data is captured as well. For new contracts and solicitations issued after March 31, 2026, disclosure will be a contractual requirement — not a request.

The voluntary language for existing contracts may provide some negotiating room for now, but contractors who resist disclosure could find themselves under greater scrutiny going forward. For new contracts, the stakes are higher: vendors who decline to include disclosure provisions may find themselves deemed non-responsive or in breach.

Government-wide visibility into prices paid will effectively eliminate the ability for vendors to charge different civilian agencies different rates without detection. Contractors may face pressure toward de facto preferred pricing across their federal customer base, and volume discount structures tied to individual agency relationships could become harder to sustain. Contractors whose federal business is concentrated in national security work are largely insulated from this repricing pressure — for now. Those with mixed portfolios spanning both NSS and non-NSS work will face exposure on non-NSS contracts, including those with the Department of War, while retaining pricing protection on their NSS work. Further, contractors supporting both NSS and non-NSS work within the same agency may face real administrative complexity in segregating reportable from non-reportable contract data, particularly on large enterprise agreements spanning multiple agency components.

Cross-Agency Data Sharing Could Both Pressure and Propel Competitiveness

Price competition will ramp up significantly as agencies begin sharing pricing and utilization data with OMB and GSA. New non-NSS contracts cannot include provisions that restrict such cross-agency sharing, meaning contractors should expect their pricing to be visible government-wide. GSA will support agencies by sharing best practices, sample contract language, and templates, further standardizing the non-NSS procurement landscape.

The competitive dynamics here cut both ways. Some contractors may find opportunity if agencies use benchmarking data to challenge underperforming incumbents at recompete time. Others — particularly those with above-market pricing on existing contracts — will face heightened scrutiny at renewal. Smaller vendors and resellers, who often rely on pricing flexibility to compete against larger primes, may feel the effects most acutely.

Protecting Proprietary Information Remains Unclear

One significant gap in the memo is that it does not address protections for contractor and supplier proprietary information. The memo contains no provisions or guidance on protecting that data as it flows across agencies, is compiled in open formats, and shared with OMB and GSA. The risk exposure increases further if data shared across agencies subsequently becomes subject to a Freedom of Information Act (FOIA) request by a competitor. While I am not a lawyer, a cursory reading of FOIA Exemption 4 — which protects confidential commercial information, particularly where pricing reflects proprietary cost structures — suggests that contractors may have grounds to challenge the memo's broad disclosure requirements. Presumably, OMB has considered this, and time will tell how OMB, GSA, and agencies address it going forward.

Closing Thoughts

M-26-10 continues the Trump Administration's efforts to transform federal contracting through greater economy and efficiency. It also advances GSA's growing role as the central arbiter of government-wide contracting, extending the Administration's push for federal procurement consolidation. The CIO reporting requirement is time-limited, sunsetting in October 2026 at the close of fiscal year 2026 — unless OMB extends it. The contractor disclosure provisions, however, carry no expiration date. Those pricing and utilization transparency requirements are written as permanent obligations that could significantly reshape the federal IT contracting landscape for the long term.