August 27, 2026 through August 27, 2027. Covered sellers face a 100% monthly domestic sales requirement unless BIS grants an adjustment or exception.
Reconcile the population
Start with all potentially covered sales for the month, then tie classification, buyer, quantity, value and physical-location evidence to source records. Use the DPAS allocation-order compliance checklist to verify the order, rating, acknowledgment, and delivery controls before reconciliation.
Separate exceptions from ordinary sales
Transactions relying on BIS authorization should be clearly identifiable and linked to the authorization terms rather than mixed into the normal domestic-sales population.
Sign off on unresolved gaps
A useful month-end control shows open issues, owner, corrective action and reviewer sign-off. That creates a contemporaneous record of the company’s compliance process.
Build the evidence while the transaction is current
The Syntera DPAS Covered-Material Sales Compliance & Evidence System organizes material classification, buyer diligence, sales, physical-location evidence, BIS requests, supporting documents and month-end review in one Excel control system.
Official source
This guide is based on the BIS temporary final rule published August 6, 2026. Read 91 FR 50701–50706.
Educational information and operational control guidance only. Not legal advice or a determination that any particular material, buyer or transaction is covered.