How to Fill Out and Submit DD Form 2139: Filing, Deadlines, Exemptions

DD Form 2139, “Report of Contract Performance Outside the United States,” is the Department of Defense form that defense contractors use to report work performed, or planned to be performed, in a foreign country under a DoD contract.¹ It captures the dollar value, location, and description of the overseas effort so DoD can track how much of its contract spending flows to foreign suppliers. The requirement comes from 10 U.S.C. § 4603, which obligates contractors to notify DoD when a significant portion of a defense contract will be performed outside the United States and Canada.²

When You Have to File It

Two DFARS clauses trigger the report, one at the proposal stage and one after award.

With Your Offer

Under DFARS 252.225-7003, you submit DD Form 2139 with your proposal when both of these are true: the total offer exceeds $20 million, and you know that you or a first-tier subcontractor will perform work outside the United States and Canada worth more than $900,000 that could have been performed domestically.³ Both prongs have to be met. A $25 million offer with only $500,000 of foreign work does not trigger the form, and neither does a $10 million offer with $2 million of foreign work.

After Award

DFARS 252.225-7004 kicks in once the contract has been awarded. If you or a first-tier subcontractor will perform any portion of the contract outside the United States and Canada worth more than $900,000, and that portion could have been done domestically, a report is required.⁴ The $900,000 threshold reflects a 2025 inflation adjustment; the prior figure was $750,000.⁵ You do not need to resubmit information already provided with your offer unless it has changed, but foreign work that surfaces after award needs a fresh report.

Getting the Form

Blank copies are available from the DoD Forms Management Program at esd.whs.mil, or from your contracting officer.⁶ A computer-generated report is acceptable in place of the official form as long as it contains every data element DD Form 2139 requires.³

How to Fill It Out

The form is short. Work through it with the contract paperwork in front of you.

Item 1a — Prime Contract Number. Enter the prime contract number. If you are submitting with an offer, use the solicitation number instead.
Item 1b — Purchase Order Number. Fill in if one applies; otherwise leave it blank.
Item 2 — Program Identification. Identify the specific program, such as the aircraft model, engine type, or category of services. Avoid acronyms.
Items 5 and 6 — Subcontractor or Foreign Division. Provide the name, full address including country, and tier level (first-tier or second-tier) of the entity performing the work.
Item 7 — Value of Effort. Report the dollar value of the foreign work for this contract action only. Do not include amounts reported on earlier submissions.
Item 8 — Country of Origin. Enter the city and country where the supplies are actually produced or the services actually provided.
Item 9 — Description of Supplies or Services. Describe the overseas effort in plain language, again without acronyms.

Item 7 is where filers most often stumble. Each submission should reflect only the new or incremental foreign work for that action, never a running total.¹

Where to Send It, and When

After-award reports go to two places. Send the original to your contracting officer, and a copy to:

Principal Director, Defense Pricing, Contracting, and Acquisition Policy (Contract Policy)
OUSD(A&S) DPCAP/CP
Washington, DC 20301-3060⁴

The form also lists an email inbox for completed submissions: osd.pentagon.ousd-a-s.mbx.asda-dp-c-contractpolicy@mail.mil.¹ For reports filed with an offer under DFARS 252.225-7003, the form goes to the contracting officer as part of the proposal package.

File the after-award report as soon as you have the information. When the report concerns a first-tier subcontract, aim to submit it at least 30 days before awarding that subcontract. The regulation phrases this as “to the maximum extent practicable,” so it operates as a strong expectation rather than a hard deadline.⁴

Exemptions

Not every DoD contract with overseas performance triggers the form. DFARS 225.7202 exempts certain acquisitions from the reporting requirement, and DFARS 225.7204 tells contracting officers to include the reporting clauses only in solicitations and contracts above the applicable dollar threshold.² If your solicitation contains neither DFARS 252.225-7003 nor 252.225-7004, the form is not required for that contract. Ask your contracting officer if you are unsure.

Not a Military Pay Form

DD Form 2139 has nothing to do with military pay, income verification, or Leave and Earnings Statements, despite what a few online sources suggest. It is strictly a defense acquisition reporting tool. Service members who need to verify income for a mortgage, divorce, or similar purpose should use the Leave and Earnings Statement available through myPay at mypay.dfas.mil, which shows pay grade, entitlements, and deductions. If a lender or court needs more than the LES or a military ID, DFAS directs service members to their personnel or finance office.⁷

1
Executive Services Directorate. DD Form 2139 – Report of Contract Performance Outside the United States
2
Acquisition.GOV. Subpart 225.72 – Reporting Contract Performance Outside the United States
3
eCFR. 48 CFR 252.225-7003 – Submission with Offer
4
eCFR. 48 CFR 252.225-7004 – Submission after Award
5
Federal Register. Inflation Adjustment of Acquisition-Related Thresholds (DFARS)
6
DoD Forms Management Program. DD Form 2139
7
Defense Finance and Accounting Service. Military Employment Verification