whatbindsCheck your order

Clauses · DFARS · Ethics and integrity

DFARS 252.203-7000 Requirements Relating to Compensation of Former DoD Officials

Does the regulation require it to flow down?

No

The clause has no subcontracts paragraph and DFARS 203.171-4 says nothing about subcontracts — there is no regulatory requirement to insert it in a subcontract. Primes flow it down anyway because 41 U.S.C. 2105(c) and DFARS 203.171-3(c) attach cancellation, rescission, suspension and debarment consequences to 'a DoD contractor' generally, and the prime wants the same duty and the same paper trail sitting on every company that touches its program.

A clause can reach your subcontract without a mandate. Once it is in your document, it is a contract term all the same. The missing mandate is a fact about the regulation. It is not a ruling on your order.

Checked against acquisition.gov on 2026-08-05 · edition SEP 2011 · base v0.9.3 Read the text ↗

What it makes you produce

One item for your checklist.

  1. Something somebody else has to issue you

    The same day if the issuer is one of your own suppliers, months if it is an assessor or an underwriter.

    • A written post-employment ethics opinion from the DoD ethics counselor, covering the activities the person is expected to undertake for you

      Owed before you pay a covered DoD official anything, within two years of the day they left DoD service

      DFARS 252.203-7000(b)

When it is used

Every DoD solicitation and contract, including ones using FAR part 12 procedures for commercial products and commercial services (DFARS 203.171-4(a)). No dollar threshold on the contract itself and no commercial or COTS carve-out — the clause goes in every time. The $10 million figure inside the clause describes the acquisition the former official worked on, not the value of your subcontract. The obligation only bites if you compensate a 'covered DoD official' within 2 years of the day they left DoD service, and only for officials who left on or after 2008-01-28. Implements section 847 of the FY 2008 NDAA (Pub. L. 110-181).

Read closely

(b) accepts a second state as well as the opinion itself: an opinion that was sought and not returned after 30 days. Either way the file exists before the first payment, and the counselor sets the date. (a) is the definition of a covered official, and it turns on a $10 million acquisition the person worked on rather than on the size of this order.

The 4 templates that name it, with the line
233RTX Flowdown of U.S. Government Contract Clauses Under U.S. Government ContractsRTXline 1382255GD Mission Systems SCM-TMP-005 — General Provisions, Firm Fixed Price PO under U.S. Government Contract (Non-Commercial)General Dynamicsline 1214243GD Mission Systems SCM-TMP-048 — T&M Purchase Orders for Non-Commercial Items in Support of a U.S. Government ContractGeneral Dynamicsline 2136178AAR Component Services NY — U.S. Government Contract FAR and DFARS Clauses Incorporated by ReferenceAAR Corpline 241

Source: acquisition.gov, DFARS 252.203-7000, DFARS 203.171-4 and DFARS 212.301(f) (verified 2026-08-05); DoD Class Deviation 2026-O0031, Revolutionary FAR Overhaul Part 3 / DFARS Part 203, 2025-12-18, Attachment A1, 203.171 and 252.203-7000

This is research, not legal advice. It states what the regulation says about this clause and cites the paragraph behind it. It does not rule on your order, and it does not rule on whether a prime's markings are correct.