Federal Contractor Semiconductor Supply Chain Disclosure

A February 2026 proposed FAR rule implementing NDAA Section 5949’s covered-semiconductor ban gives contractors a 72-hour window to report a prohibited part after contract award and requires a documented “reasonable inquiry” into supplier semiconductor sourcing before then — the prohibition itself takes effect December 23, 2027.

Why GovChain

• A 72-hour reporting window only works if a contractor already knows which semiconductor supplier fed which component — a chain-of-custody record traced to the part level answers that query in the time the rule allows, not after it
• A “reasonable inquiry” is a documented due-diligence process, not a one-time attestation — the same distinction protocol/SPEC.md draws about any signed record: a signature shows who asserted sourcing, not that the inquiry behind it was thorough
• The rule remained a proposal, not final text, as of this writing — GovChain builds the part-level traceability layer now, so a deadline three years out does not become a scramble in month thirty-five

How it works

Issue a unique identifier per unit, anchor its record on-chain for tamper-evidence, and let anyone verify it with a single scan. No enterprise contract — public-sector pricing.

FAQ

When does the covered-semiconductor prohibition take effect?

December 23, 2027, under NDAA Section 5949. The FAR Council released its proposed implementing rule on February 17, 2026; it had not been finalized as of this writing.

Which suppliers are covered?

Semiconductor parts, products, or services from SMIC, ChangXin Memory Technologies (CXMT), Yangtze Memory Technologies Corp (YMTC), or their subsidiaries and affiliates — plus, under a broader provision, any electronic part incorporating those semiconductors for use in “critical systems.”