New Rule Requires Federal Contractors to Report Executive Compensation & Subcontractor Information


Several federal agencies have promulgated a new rule which requires covered federal contractors to disclose information about the total compensation paid to their five most highly compensated executives and to the highest paid executives of their first-tier subcontractors. This rule amends the Federal Acquisition Regulation (FAR) to implement the section of the Federal Funding Accountability and Transparency Act (FFATA) that requires the Office of Management and Budget (OMB) to create a free, public website that provides information about all federal contract awards. The website can be found at

The Rule extends the compensation and subcontractor reporting requirements applied to American Reinvestment and Recovery Act (ARRA) funded contracts to all federal contracts entered into after July 8, 2010 which are over $25,000, except the following: (1) classified solicitations and contracts; (2) contracts with individuals; and (3) contractors and subcontractors whose gross income is less than $300,000.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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