Each card gives the rule, its status, the words that matter and our part in the work. Your agency makes the determinations; we provide the evidence and the documentation.
U.S. federal (executive agencies)Key date: March 31, 2026
OMB M-26-10: Reinforcing Transparency, Accountability, and Oversight of Federal Technology
In force (issued March 31, 2026). Section 2 is a standing requirement for all agencies except for national security systems: agencies request utilization rates and prices paid from current IT vendors and include disclosure provisions in solicitations and contracts issued after March 31, 2026.
“Include appropriate provisions in solicitations and contracts issued after the date of this memorandum to require IT vendors to disclose utilization and pricing information to the Government, without limiting the extent to which that information may be shared across agencies”
What we do: We turn the utilization and price data your vendors disclose into a savings register and a retire-or-consolidate plan for your agency's technology review.
Source: OMB M-26-10 (whitehouse.gov, PDF) (opens in a new tab) · Checked November 10, 2026
U.S. federal budgetKey date: November 6, 2026
OMB Circular A-11 (2026), Section 55: Information Technology Investments
Current edition: OMB Circular A-11 (2026), Transmittal Memorandum No. 100 of November 6, 2026, which supersedes all previous versions.
“Agencies should regularly review their Major IT Investments to ensure that they continue to add the expected value to the agency's stated business goals or mission outcomes.”
What we do: We write investment business cases that carry the planned and actual costs, the anticipated and achieved benefits and the cost, schedule and performance risks that Section 55 asks agencies to document for Major IT Investments.
Accounting treatment is determined by your auditors; we provide evidence and documentation.
Source: OMB Circular A-11 (2026), Section 55 (whitehouse.gov, PDF) (opens in a new tab) · Checked November 10, 2026
U.S. federalKey date: April 8, 2025
OMB Circular A-94 (1992), reinstated by OMB M-25-23
In force: M-25-23 (April 8, 2025) revoked the 2023 Circular and reinstated the October 29, 1992 Circular with appendices A and B.
“The net present value of such investments should be evaluated with the 7 percent real discount rate discussed in Section 8.b. unless the analysis is able to allocate the investment's costs between provision of Federal cost savings and external social benefits.”
What we do: Our business cases compute net present value at the discount rates the Circular prescribes and show federal savings and public benefits separately.
Source: OMB Circular A-94 (whitehouse.gov, PDF) (opens in a new tab) · Checked November 10, 2026
U.S. federal budgetKey date: November 6, 2026
OMB Circular A-11 (2026), Appendix B: budgetary treatment of lease-purchases and leases
Current edition: OMB Circular A-11 (2026), Transmittal Memorandum No. 100 of November 6, 2026, which supersedes all previous versions; the Appendix B scoring rules carry over unchanged.
“budget authority will be scored in the year in which the authority is first made available in the amount of the net present value of the Government's total estimated legal obligations over the life of the contract”
What we do: We compare buying, leasing and as-a-service options in the terms OMB uses for budget scoring, and your budget office settles how each option scores, with its OMB representatives where Appendix B asks for review.
Source: OMB Circular A-11 (2026), Appendix B (whitehouse.gov, PDF) (opens in a new tab) · Checked November 10, 2026
U.S. federal (CFO Act agencies)Key date: December 12, 2017
Modernizing Government Technology Act, IT working capital funds (Pub. L. 115-91, sec. 1077; note to 40 U.S.C. 11301)
In force (statutory note).
“may reprogram and transfer any amounts saved as a direct result of the cost savings activities approved under clause (i)”
What we do: We build the savings register and the business case an IT working capital fund request rests on, and the reprogramming decision stays with your agency and its appropriators.
Source: Modernizing Government Technology Act, IT working capital funds (govinfo.gov) (opens in a new tab) · Checked November 10, 2026
U.S. federal (executive agencies)Key date: March 10, 2026
OMB Circular A-123 (revised 2026): Management's Responsibility for Internal Control
In force on issuance (March 10, 2026); supersedes all previous versions of the Circular, and Appendices A, B, C and D remain in effect.
“When possible, agencies should consider automated systems and technologies to streamline the process of conducting risk assessments, testing controls, and monitoring control performance.”
What we do: We build the governed data model and dashboards your control owners use for automated control testing and monitoring, on the financial system you already run.
Source: OMB Circular A-123 (revised 2026) (whitehouse.gov, PDF) (opens in a new tab) · Checked November 10, 2026
U.S. federal accountingKey date: October 7, 2026
FASAB SFFAS 10, Accounting for Internal Use Software (replacement in deliberation)
SFFAS 10 in effect; the Board plans to rescind and reissue it in a new intangible-asset Statement, and a draft exposure draft was on the agenda of its October 20-21, 2026 meeting (staff memorandum of October 7, 2026; not authoritative).
“The Board plans to rescind Statement of Federal Financial Accounting Standards (SFFAS) 10, Accounting for Internal Use Software, and reissue the internal use software (IUS) guidance”
What we do: We document the capitalization options for software and AI with the evidence behind each, and your finance team and auditors decide the treatment.
Accounting treatment is determined by your auditors; we provide evidence and documentation.
Source: FASAB SFFAS 10, Accounting for Internal Use Software (files.fasab.gov, PDF) (opens in a new tab) · Checked November 10, 2026
U.S. federal (executive agencies; national security systems excluded)Key date: June 24, 2026
OMB M-26-15: Execution of the Migration to Post-Quantum Cryptography
In force since June 24, 2026 (implements Executive Order 14412); agency migration plans were due October 22, 2026; prioritized systems move to post-quantum key establishment by December 31, 2030 and to post-quantum signatures by December 31, 2031, with full migration by 2035.
“Systems incapable of supporting PQC or hybrid cryptography must be identified and given priority for replacement or decommissioning.”
What we do: We put the post-quantum migration into the capital plan as a costed, scheduled line, and we price the replace-or-retire decision for each system that cannot make the move, so the run costs freed by retirement help fund the AI roadmap.
Source: OMB M-26-15 (whitehouse.gov, PDF) (opens in a new tab) · Checked November 10, 2026
Texas (state agencies; major information resources projects)Key date: September 1, 2005
Texas Project Delivery Framework: business case (Gov. Code §2054.303) and post-implementation review (§2054.306)
In force since September 1, 2005; applies to major information resources projects: projects in a state agency's biennial operating plan with development costs above $5 million that take a year or more to reach operations, involve more than one agency or substantially alter work methods or service delivery, projects the Legislature designates, and projects designated for additional monitoring with development costs above $5 million (Gov. Code §2054.003(10)).
“After implementation of a major information resources project, a state agency shall prepare a post-implementation review.”
What we do: For Texas major information resources projects, the Business Case Sprint drafts the business case and workbook on DIR's templates for your agency to approve and file, and the Run milestone measures the outcomes your post-implementation review compares with the business case.
Source: Texas Project Delivery Framework (statutes.capitol.texas.gov) (opens in a new tab) · Checked November 10, 2026
U.S. (community water systems serving more than 3,300 people)Key date: October 23, 2018
America's Water Infrastructure Act §2013: risk and resilience assessments and emergency response plans
In force. This cycle's risk and resilience assessment certifications were due March 31, 2025, December 31, 2025 and June 30, 2026, by system size; emergency response plans follow six months after each assessment certification, the last on EPA's schedule by December 31, 2026; reviews repeat at least once every five years.
“electronic, computer, or other automated systems (including the security of such systems)”
What we do: Utility twin, operational-data and capital-planning work is scoped so its findings can feed the risk and resilience assessment and the emergency response plan a community water system reviews and certifies to EPA at least once every five years.
Source: America's Water Infrastructure Act §2013 (epa.gov) (opens in a new tab) · Checked November 10, 2026
U.S. (state and local government accounting)Key date: June 15, 2022
GASB Statement No. 96: Subscription-Based Information Technology Arrangements
Effective for fiscal years beginning after June 15, 2022.
“A SBITA is defined as a contract that conveys control of the right to use another party's (a SBITA vendor's) information technology (IT) software, alone or in combination with tangible capital assets (the underlying IT assets), as specified in the contract for a period of time in an exchange or exchange-like transaction.”
What we do: For state and local governments, the business case models how subscription payments and implementation costs may be treated under GASB Statement No. 96, and your auditors determine the classification.
Accounting treatment is determined by your auditors; we provide evidence and documentation.
Source: GASB Statement No. 96 (gasb.org) (opens in a new tab) · Checked November 10, 2026