Federal Contractor Greenhouse Gas Disclosure (DFARS/FAR)

Current understanding

Federal procurement rules requiring contractors—starting with defense contractors under the DFARS—to disclose greenhouse gas emissions as a condition of doing business with the government. The DoD is implementing this via DFARS Case 2024-D021 pursuant to a provision of the FY2024 National Defense Authorization Act, translating a statutory mandate into procurement clauses. Practical effect includes new reporting burdens for defense contractors and a federal data stream on supply-chain emissions parallel to (but distinct from) securities-law climate disclosures.

Evidence log

• 2026-05-07 — Defense Federal Acquisition Regulation Supplement: Disclosure of Greenhouse Gas Emissions (DFARS Case 2024-D021): cross-connection with sec-climate-related-disclosures: Both establish mandatory GHG emissions disclosure regimes on different populations (federal contractors via DFARS/FAR vs. SEC registrants); together they define the federal government’s split approach to emissions transparency across procurement and securities law. (novelty: 2)

Open questions

Related