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 (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: July 29, 2016
MEGABYTE Act of 2016 (Pub. L. 114-210): software license inventories
In force since July 29, 2016.
“establish a comprehensive inventory, including 80 percent of software license spending and enterprise licenses in the executive agency, by identifying and collecting information about software license agreements using automated discovery and inventory tools”
What we do: The teardown starts from the license inventory the Act already requires and adds usage, price benchmarks and retire-or-consolidate decisions.
Source: MEGABYTE Act of 2016 (Pub. L. 114-210) (govinfo.gov) (opens in a new tab) · Checked November 10, 2026
U.S. federal (GSA)Key date: April 29, 2025
GSA OneGov agreements
Live agreements, each with its own terms, eligibility and expiration date (GSA's current list includes Microsoft, OpenAI, Anthropic, Google, SAP, ServiceNow, Salesforce, Oracle and Adobe); most are for federal agencies only, and a few, among them OpenAI's and Anthropic's model agreements, are also open to state, local and tribal governments.
“GSA's OneGov Strategy is a comprehensive plan to transform how government buys almost everything.”
What we do: In each license and application teardown, we compare what your agency pays with the GSA OneGov terms open to it, using GSA's published agreement summaries and the terms your team provides.
Source: GSA OneGov agreements (itvmo.gsa.gov) (opens in a new tab) · Checked November 12, 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
U.S. federal (executive agencies)Key date: January 23, 2026
OMB M-26-05: Adopting a Risk-based Approach to Software and Hardware Security (rescinds M-22-18 and M-23-16)
In force since January 23, 2026.
“Agencies shall continue to maintain a complete inventory of software and hardware”
What we do: The software and hardware inventory your agency keeps is where the license and application teardown starts.
Source: OMB M-26-05 (whitehouse.gov, PDF) (opens in a new tab) · Checked November 10, 2026