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Defense Federal Acquisition Regulation Supplement: Update of Challenge Period for Validation of Asserted Restrictions on Technical Data and Computer Software (DFARS Case 2022-D016)

Detected July 30, 2026 · in Government Contracting (SAM/FAR)

DoD final rule shortens the challenge period for validating asserted restrictions on technical data and computer software under DFARS from 90 to 60 days, effective March 18, 2025.

Aforeworn detected this change in the Government Contracting (SAM/FAR) space on July 30, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated Medium urgency. Defense contractors and subcontractors that assert restrictions on technical data or computer software delivered under DoD contracts. should confirm how it applies to their specific situation before acting. There is a time constraint attached: Effective March 18, 2025. Applies to solicitations issued on or after that date.. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors Government Contracting (SAM/FAR) continuously and turns every detected change into a plain-English briefing like this one, so you always know first. Forewarned is forearmed.

What changed

The period for DoD to challenge a contractor's asserted restrictions on technical data or computer software is reduced from 90 days to 60 days after receipt of the data or software.

Who it affects

Defense contractors and subcontractors that assert restrictions on technical data or computer software delivered under DoD contracts.

What you must do

Review and update internal processes to ensure timely response to any DoD challenge within the new 60-day window.

Deadline

Effective March 18, 2025. Applies to solicitations issued on or after that date.

Source: https://www.federalregister.gov/documents/2025/01/17/2025-00722/defense-federal-acquisition-regulation-supplement-update-of-challenge-period-for-validation-of

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