Checklist
DoD Is About to Inventory Your Technical Data. Audit Yours First.
Part 1
What was owed
Can you produce, per program, the complete list of technical data deliverables the contract actually required — CDRLs, cited standards, tailoring and all?
The government's inventory starts from the contract's requirements. If your own picture of what was owed lives in tribal memory and old emails, every later question inherits that fog.
For each cited standard, do you know the exact part and revision invoked — and does your delivered data match it?
"40051-compliant" means the part and revision the contract names, under its tailoring. Deliverables validated against the wrong revision read as gaps in an audit, whatever their quality.
Were data requirements flowed down to your suppliers — contractually, not conversationally?
The highest-profile sustainment fight in recent reporting turned exactly here: supplier data never put under obligation is data the government discovers missing years later, with your name on the prime contract.
Where deliverables were negotiated away, waived, or deferred, is there a paper trail?
A documented descope is a fact; an undocumented one is a finding. The difference is an afternoon of records now versus a dispute later.
Part 2
What was delivered
Can you show what was actually transmitted, when, and in what form — for programs that may be decades old?
The inventory will compare required against possessed. Being able to prove delivery is the difference between the government's gap and yours.
Is your master copy of each deliverable findable, or distributed across shared drives, archives, and departed employees' folders?
If assembling your own deliverables would take a scavenger hunt, you cannot answer questions about them on government timelines.
Do delivered manuals and data match the configuration actually fielded — mods, variants, and updates included?
Data that describes a configuration nobody flies anymore is 'unusable' in exactly the sense the new platform is built to expose.
Are your rights markings on each deliverable correct and consistent?
Data rights assertions are about to get systematic scrutiny. Over-marked deliverables invite challenge; inconsistent markings invite the worst interpretation.
Part 3
Whether it's usable
Is the data in formats that are usable today — or in dead tool formats and untagged scans?
The statute cares about unusable data explicitly. A deliverable that technically exists but practically can't be opened, validated, or republished sits in the same column as a missing one.
Could you regenerate the publications from source if asked — or do only the PDFs survive?
Source data (the structured content behind the manual) is what makes updates, conversions, and reuse possible. If only renditions survive, every future obligation is a reconstruction project.
Can your data be delivered in the structured, addressable forms modern contracts increasingly cite?
The direction of travel is data as data — model-based TDPs, structured publications, APIs. Libraries that can only export paper-shaped files will meet that expectation the expensive way.
If the government asked for a data map of one program tomorrow — what exists, where, in what state — how long would honest answers take?
This is the whole audit in one question. The answer is measured in days for organized estates and quarters for everyone else, and Section 805 just made the difference reportable.
The Context
Why Now
The policy background is in our right-to-repair briefing: the compelled-disclosure provisions were stripped from FY26, but the inventory survived, the Army is surveying its contracts, and the FY27 drafts push further. Every trajectory points the same way — systematic government visibility into what was owed, delivered, and usable. The twelve questions above are how a contractor gets there first, and they pair with our TM contract review checklist on the front end of programs and the convert-or-ingest playbook on the remediation end.
FAQ
Questions We Hear
What exactly does the FY26 NDAA require?
Section 805 directs the department to create an electronic platform that tracks what technical data was required to operate major weapon systems, whether the government possesses that data, and whether missing or unusable data is making systems harder or more expensive to operate — with progress reported to Congress every 90 days. It explicitly does not change intellectual property law; where gaps exist, the department is to pursue contractual requirements, access agreements, and negotiated licenses.
We're compliant — why audit ourselves?
Because 'compliant' is currently your assessment, made program by program over decades, and the new platform will make it the government's assessment, made systematically. Most contractors we know have never assembled a single cross-program view of their own technical data deliverables. The self-audit isn't an admission of doubt — it's making sure the first comprehensive picture of your data posture is one you produced, on your timeline.
What usually turns up in these audits?
Rarely scandal; usually entropy. Deliverables that were transmitted but can't be proven; supplier data never put under contractual obligation; source files lost while PDFs survive; rights markings applied inconsistently across decades; and data that exists in formats nothing current can open. Each item is fixable cheaply when found by you, and expensively when found about you.
What does fixing the 'usable' column look like?
The same estate playbook as any legacy library, with contractual stakes: inventory and consolidate the masters, ingest the settled material into a platform where it's findable, addressable, and provable, and convert the living document families to structured form on their own revision cycles. The deliverable isn't just compliance posture — an organized technical data estate is cheaper to sustain, faster to bid with, and ready for the model-based direction contracts are heading.
Get In Touch
Twelve Questions, Answered First
We run technical-data self-audits — contract requirements to delivered reality to usability — and build the organized estate that turns the government's inventory into a non-event.