DoD Expected to Finalize Personal Property Program Rules by November

The U.S. Department of Defense’s Personal Property Activity (PPA) is expected to issue final rules for the Defense Personal Property program by the end of November 2026. The public-comment period closed October 26, giving the agency an opportunity to consider industry feedback before publishing the final requirements. The rulemaking concerns the contractors and service providers responsible for military household-goods moves, a service where provider availability and reliable performance are important to continuity for military families and government customers.

Industry objections focus on several proposed provisions with potential operational and cost impacts: CMMC Level 2 cybersecurity requirements, limits on service-member-sponsored access to military installations, performance evaluation periods, and compensation for waiting time. These provisions remain proposals rather than final requirements. Their eventual wording and implementation details will determine whether contractors need to make new compliance investments, adapt access procedures, revise staffing and scheduling practices, or account for different payment terms in their bids and operating plans.

Movers for America has emphasized the potential burden on smaller providers. Executive Director Katie McMichael said, “Our industry is primarily made up of small businesses, and the cost of getting to level 2 CMMC compliance is very high.” That concern is directly relevant to the government’s supplier base: if compliance costs or other operating requirements prove difficult for smaller firms to absorb, participation and available provider capacity could be affected. For the government, reduced capacity could pose risks to competition and to the continuity of household-goods moving services, although the source material does not establish that such effects will occur.

Contractors and government customers should use the remaining rulemaking period to assess the proposals without treating them as settled obligations. Moving companies can identify likely cybersecurity, installation-access, evaluation, and waiting-time impacts; review where small-business resources may be constrained; and prepare to compare current procedures with the final text once issued. Government customers can consider how the final provisions may affect provider participation, capacity, and service continuity. The expected end-of-November publication makes prompt monitoring important, but the final rules—not the proposed provisions—will establish the requirements companies must follow.

• Rulemaking timeline: PPA is expected to publish final Defense Personal Property program rules by the end of November 2026; public comments closed October 26.
• Cybersecurity proposal: Proposed CMMC Level 2 requirements could add compliance costs. Movers for America says the cost of reaching Level 2 is very high for an industry primarily made up of small businesses.
• Installation access: Proposed limits on service-member-sponsored base access could affect contractor procedures for entering military installations.
• Performance evaluations: Proposed evaluation periods could influence how moving providers are assessed under the program; the final evaluation approach remains to be seen.
• Waiting-time compensation: Proposed provisions could change how waiting time is compensated, with potential implications for contractor operations and costs.
• Small-business exposure: Providers should assess whether compliance and operational changes could affect their ability to participate or maintain service capacity.
• Government customer considerations: Customers should evaluate possible effects on competition, provider availability, and continuity of household-goods moving services.
• Action for contractors: Map each proposed provision to current practices, identify potential cost and process changes, and review the final requirements promptly when PPA issues them.
• Status reminder: The provisions described are proposals, not final requirements; contractors should avoid treating them as binding until final rules are published.