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Contract Management

Why the Pentagon keeps failing its audit, and what your contract file has to do with it

A-Frame Solutions September 2026 7 min read

The short answer. The Department of Defense has failed eight straight financial audits. It is the only one of the 24 major federal agencies that has never passed one, and the law says it must pass by December 31, 2028. GAO told Congress in May 2026 that a core problem is that DoD cannot produce a complete, reconcilable list of its transactions. A lot of that list starts in contract files. Contracting offices cannot fix the audit alone, but they decide whether a dollar can be traced from the requirement to the payment.

Audit stories usually read like a finance problem. Comptrollers, ledgers, opinions. Then you look at what the auditors actually ask for, and it is a list of transactions and the paper behind each one. For a large share of DoD's money, that paper is a requisition, a contract, a modification and an invoice. Contracting offices create most of it.

The numbers

Here is where things stand, from Breaking Defense's report on the fiscal 2025 results and GAO's May 13, 2026 testimony (GAO-26-109115).

The fiscal 2024 National Defense Authorization Act sets the deadline for a clean opinion at December 31, 2028. Acting Comptroller Jules Hurst said DoD will not reach that goal without a significant acceleration, Breaking Defense reported. The fiscal 2026 results are due before the end of this year.

What "universe of transactions" means

This phrase shows up in almost every DoD audit report, and it is simpler than it sounds.

Take a number on the balance sheet, such as accounts payable. The auditor asks for every individual transaction that adds up to that number. That list is the universe. It has to be complete, and it has to reconcile to the accounting records. The auditor then picks samples from it and asks for the documents that prove each one happened as recorded.

If you cannot produce the list, there is nothing to sample. If the list does not reconcile, the auditor cannot trust it. If the samples do not trace to documents, the number fails. GAO's testimony says DoD has been "unable to produce a complete, accurate, and reconcilable universe" of transactions. The DoD Inspector General found the same gap in Fund Balance with Treasury, DoD's cash account with the Treasury: no complete population of transactions. GAO also names accounts payable as a weakness that raises fraud risk.

A dollar's path, and where it breaks

Follow one dollar of a services contract.

  1. Requisition. A program office writes a purchase request, and a resource manager certifies that funds are available.
  2. Award. The contracting officer awards the contract. The obligation is recorded, and each funded line item carries a line of accounting.
  3. Funding periods. Options are exercised and incremental funding is added by modification. Each one adds money under a new line of accounting or fiscal year.
  4. Invoice. The contractor submits an invoice in PIEE (Procurement Integrated Enterprise Environment, the DoD invoicing and acceptance portal). The COR accepts the work.
  5. Payment. The paying office pays the invoice and charges it against a line of accounting.

Each step often lives in a different system. What holds the chain together is usually a number typed by hand: the purchase request number on the award, the line item and accounting reference on the invoice. When one of those numbers is missing or wrong, the dollar still gets spent. It just cannot be traced. Multiply that by millions of transactions and you get a universe that does not reconcile.

GAO's testimony describes the systems side of the problem too. The DoD Inspector General counted about 2,000 system interfaces in a complex environment that includes outdated systems. Every interface is a handoff where a link can drop.

DoD's new plan, and GAO's worries about it

DoD set up a Joint Task Force Audit in March 2026 and changed its approach. Instead of fixing controls first, it plans to prove balances directly, with manual testing of large samples and AI tools. The goal is a clean opinion on the DoD Working Capital Fund in fiscal 2027 and department-wide in fiscal 2028.

GAO is not convinced. Its testimony warns that the approach means DoD would deprioritize fixing key internal control problems for two or more years. It warns that DoD and its auditors may not be able to scale their resources for that much testing. And it warns that pressure to reach a clean opinion can create incentives that raise fraud risk. In plain terms, a big enough sample can pass one audit. It does not make next year's transactions any easier to trace.

What contracting offices can do now

None of this needs a new system or a new policy. It needs the links between records written down where someone can find them.

1. Carry the purchase request number onto the award

Every award and every funding modification should cite the requisition that funded it. If the purchase request number lives only in an email thread, the first link in the chain is already gone.

2. Record funding against each line item and modification

Know which line of accounting and fiscal year funds each line item, and which modification added it. This is the answer to "what money is on this contract, and where did it come from?"

3. Tie every invoice to its line item and funding on receipt

When an invoice arrives, match it to the contract line and the funding period it draws from before acceptance. Doing it at the time takes a minute. Doing it at audit time takes a data call.

4. Keep the links as data, not as file names

A folder called "Invoices" and a spreadsheet of numbers are not links. A record that points to its contract, and a contract that lists its requisition, funding periods and invoices, is something a person or a tool can follow.

5. Be able to answer the auditor's question in minutes

Test your own file with one question: "What has been invoiced against this funding period?" If the answer takes a day, an auditor's sample will too.

6. Reconcile at closeout

Closeout is the last chance to check that obligations, invoices and payments agree. Unliquidated balances and unmatched payments that survive closeout become someone else's audit finding.

Where AI fits

DoD is betting partly on AI to test more samples, faster. AI is good at reading documents, matching numbers and flagging gaps. It cannot rebuild a link that nobody recorded. If an invoice never pointed to its contract line, no model can prove which funding it drew from.

That is why we built linked records into ArcSuite AI. A requisition is the parent of its contract, and the contract is the parent of its funding periods and invoices. ArcInsight, our AI assistant, answers questions by following those links, and every record it names links back to the source. Our Item Relationships walkthrough shows it in under two minutes.

Bottom line

Frequently asked questions

Has the Pentagon ever passed an audit?

No. The Department of Defense has failed all eight of its full financial statement audits, the most recent for fiscal year 2025. It is the only one of the 24 major federal agencies that has never received a clean opinion. Some parts of DoD do pass. The Marine Corps received clean opinions for fiscal years 2023, 2024 and 2025.

When does DoD have to pass its audit?

The fiscal year 2024 National Defense Authorization Act requires a clean audit opinion on DoD's financial statements by December 31, 2028. DoD's current plan aims for a clean opinion on the DoD Working Capital Fund in fiscal year 2027 and on the department-wide statements in fiscal year 2028.

What is a universe of transactions?

It is the complete list of individual transactions behind a number on the financial statements. It has to reconcile to the accounting records. Auditors sample from it and trace each sample back to source documents. GAO testified in May 2026 that DoD has been unable to produce a complete, accurate, and reconcilable universe of transactions.

How many material weaknesses does DoD have?

Auditors reported 26 department-wide material weaknesses for fiscal year 2025, down from 28 the year before. GAO says 17 of them are pervasive, meaning they limit what the auditors can test at all.

What can a contracting office do to help the audit?

Keep the links between records as data. Carry the purchase request number onto the award, record funding against each line item and modification, tie every invoice to its contract line and funding on receipt, and reconcile obligations and payments at closeout. Each of these makes a transaction traceable from the requirement to the payment.

Can AI fix the DoD audit?

Not by itself. DoD's revised approach uses AI tools to help test large samples. AI can read and match records quickly. It cannot recreate a link between a requisition, a contract and an invoice that nobody recorded.

See a contract, its funding and its invoices, linked.

Watch the Item Relationships walkthrough, or ask a former Contracting Officer how it fits your contract files.

Watch the walkthrough → Talk to a former CO