United States: OMB M-26-10 adds monthly IT contract transparency (July 10 cycle)
Federal agencies are tightening how they document and disclose technology spending, with an OMB memo that puts chief information officers (CIOs) at the center of both reporting and vendor data collection.
The memo—OMB Memorandum M-26-10, issued March 31, 2026, titled “Reinforcing Transparency, Accountability, and Oversight of Federal Technology”—sets up monthly reporting from covered CFO Act agencies and pushes those agencies to seek vendor utilization and pricing information for qualifying IT products and services in structured, machine-readable formats.
What changed: CIO-led visibility into covered IT contract approvals
In plain terms, OMB wants more consistent tracking of which federal technology contracts get CIO approval, and more visibility into how technology is used and what it costs.
For Section 1 reporting, OMB limits the requirement to covered CFO Act agencies (and excludes national security systems as defined in federal law). Under the memo, the CIO of each covered agency (with specific involvement by a CIO delegee in limited cases) is required to notify OMB of:
- Contracts or other agreements for IT or IT services that the CIO personally approves; and
- Certain IT product/service contracts approved by a CIO delegee when those contracts directly enable or facilitate interaction between the public and the Federal Government through digital services.
The timeline that matters now: reports due by the 10th (July 10 for June)
OMB directs the top-level CIO at each covered agency to report for the entire agency (including bureaus/components). Reports are:
- Sent via email to OMB’s Office of the Federal CIO, and
- Due no later than the 10th of each month, covering the immediately preceding month.
The memo’s reporting table shows the schedule as:
- Report #1: Due May 10, 2026 (April 1–April 30, 2026)
- Report #2: Due June 10, 2026 (May 1–May 31, 2026)
- Report #3: Due July 10, 2026 (June 1–June 30, 2026)
- Report #4: Due August 10, 2026 (July 1–July 31, 2026)
The memo says this requirement sunsets in October 2026 after covered CFO Act agencies submit a sixth and final report, unless OMB notifies agencies that it will continue past that time.
Who’s responsible inside agencies: top-level CIOs (with procurement coordination)
OMB is explicit that CIOs are responsible for the reporting stream, including ensuring bureau/component compliance. The memo also frames the work as a joint technology-and-procurement process—so CIOs coordinate with acquisition leadership (including the agency’s Chief Acquisition Officer or other responsible officials) for the vendor-information side.
What agencies must collect from vendors: utilization + “prices paid” for IT
Separately from the monthly reporting, Section 2 starts immediately and applies to all agencies (but not national security systems). OMB directs agency heads—acting through the CIO, Chief Acquisition Officer, or other relevant officials—to:
- Request current vendor information on the agency’s utilization rates and the prices paid for IT products (hardware and software) and services;
- Update solicitations and contracts issued after the memo’s date so IT vendors must disclose utilization and pricing information to the Government;
- Compile the information in a machine-readable, open standard format; and
- Share the information with OMB and GSA upon request, consistent with applicable law and contract provisions.
What to watch next: report submissions, contract language, and vendor data requests
For covered agencies, the immediate “next step” is the monthly reporting workflow that culminates in the July 10 due date for the June 1–June 30 window.
For contractors and IT vendors, the practical near-term sign is likely to be new or revised solicitation/contract language requiring utilization and pricing disclosures in the structured, open-format approach the memo calls for. The public-facing goal is clearer accountability about what federal agencies buy, how it’s used, and how that information can be shared across the Executive Branch.
Sources
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