The Lacuna Project

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Chapter 3

The Audit

Abstract

The Department of Defense Inspector General has issued a disclaimer of opinion on the department-wide financial statements in every fiscal year from 2018 through 2025, eight years in a row. The result for fiscal year 2026 had not been published as of 9 November 2026. GAO reports that DoD is the only one of the 24 agencies covered by the Chief Financial Officers Act that has never obtained a clean opinion. A disclaimer means the auditors could not gather enough evidence to give any opinion. The Inspector General's reports do not state that money is missing, and in 2018 the Comptroller told Congress that an unsupported accounting adjustment is a different matter from being unable to account for money. Some components now receive clean opinions, and the department reports progress. Congress required audit readiness by 2017, a full audit of fiscal year 2018, and a clean opinion by 31 December 2028.

3.1 Eight disclaimers of opinion

Finding DEF-3.1Primary record

The DoD Inspector General issued a disclaimer of opinion on the department-wide financial statements in each of fiscal years 2018 through 2025, eight years in a row. GAO reports that DoD is the only one of the 24 Chief Financial Officers Act agencies that has never obtained a clean opinion.

The DoD Inspector General issued its first disclaimer on 15 November 2018, for the first full audit of the department's statements. The Inspector General's 2025 report records the eighth, issued on 18 December 2025. GAO's high-risk report states that DoD has not yet received an audit opinion on its department-wide statements "because it has been unable to accurately account for and report on its spending or physical assets." GAO has listed DoD financial management as high risk since 1995.

Evidence: Exhibit 275, Exhibit 276, Exhibit 277, Exhibit 278, Exhibit 279, Exhibit 280, Exhibit 281, Exhibit 282, Exhibit 283, Exhibit 287, Exhibit 292, Exhibit 286

Mechanism: The study not run

§3.1.1

An auditor gives one of four opinions. An unmodified (clean) opinion says the statements are fairly presented. A qualified opinion says they are fairly presented except for stated matters. An adverse opinion says they are materially misstated. A disclaimer says the auditors could not obtain sufficient, appropriate audit evidence to support any opinion. The Inspector General's 2022 press release uses that definition for the FY2022 disclaimer.

§3.1.2

A disclaimer reports that the auditors could not obtain sufficient, appropriate audit evidence to support an opinion. It states that the evidence needed for an opinion was not available. It does not state an amount of lost or stolen funds, and each figure below is described in those terms.

Department-wide audit record, fiscal years 2018 to 2025, as counted in each Inspector General report
Fiscal yearDisclaimer date as statedAgency-wide material weaknessesEntity opinions in the reportReport date
201815 Nov 2018205 clean, 1 qualified, 13 disclaimers, 2 audits incomplete (21 entities)8 Jan 2019
2019not recorded here257 clean, 1 qualified, 15 disclaimers (23)28 Jan 2020
2020not recorded here269 clean, 1 qualified, 14 disclaimers (24)23 Feb 2021
202115 Nov 2021288 clean, 1 qualified, 17 disclaimers (26)18 May 2022
202215 Nov 2022289 clean, 1 qualified, 16 disclaimers (26)16 May 2023
202315 Nov 20232810 clean, 1 qualified, 18 disclaimers (29)8 Aug 2024
2024not recorded here2811 clean, 1 qualified, 12 disclaimers (24)28 Feb 2025
202518 Dec 20252611 clean, 1 qualified, 9 disclaimers (21 with opinions; 22 stand-alone audits)11 May 2026
§3.1.3

The counts differ by source and year. For fiscal year 2018 the Inspector General counted 21 entities. GAO's 2026 testimony counts 24 stand-alone audits for the same year: 16 disclaimers, 6 clean opinions and 2 qualified. For fiscal year 2022 the Inspector General's November 2022 press release gave a preliminary count of 6 clean opinions, 1 qualified and 16 disclaimers with 2 audits ongoing; its May 2023 report gave the final count of 9, 1 and 16.

§3.1.4

For fiscal year 2025 the Inspector General reports 22 stand-alone audits, of which 21 produced opinions. GAO's testimony counts 28 reporting entities and 11 disclaimers, against the Inspector General's 9. The Congressional Research Service counts 26 entity-level audits.

§3.1.5

The Congressional Research Service dates the underlying audit requirement to the Chief Financial Officers Act of 1990. In May 2026 GAO testified that DoD is the only one of the 24 agencies covered by that Act that has never obtained a clean opinion on its department-wide statements.

3.2 The deadlines Congress set

Finding DEF-3.2Primary record

The FY2010 National Defense Authorization Act required the Department of Defense to validate its financial statements as ready for audit by 30 September 2017, and the FY2014 Act required a full audit of the department's fiscal year 2018 statements, with results due to Congress by 31 March 2019.

Section 1003 of the FY2010 Act directed a plan "ensuring the financial statements of the Department of Defense are validated as ready for audit by not later than September 30, 2017." Section 1003 of the FY2014 Act stated that "upon the conclusion of fiscal year 2018, the Secretary of Defense shall ensure that a full audit is performed on the financial statements of the Department of Defense for such fiscal year."

Evidence: Exhibit 293, Exhibit 294

Mechanism: The study not run

§3.2.1

The first full audit therefore arrived on the statutory schedule, one year after the readiness date. Its result was the disclaimer of 15 November 2018. At the time the Inspector General reported that the DoD Chief Financial Officer called it one of the largest financial statement audits in history, and that DoD did not expect a clean opinion.

3.3 Counting material weaknesses

Finding DEF-3.3Primary record

The DoD Inspector General counted 20 agency-wide material weaknesses in fiscal year 2018, 25 in 2019, 26 in 2020, 28 in each of 2021 through 2024, and 26 in 2025. The Inspector General states that comparing these counts from year to year is not a reliable way to measure progress.

A material weakness is a deficiency in internal control that gives a reasonable possibility that a material misstatement will go undetected. The counts in the table above are the Inspector General's, taken from each year's report. The 2025 report records 26 agency-wide weaknesses and 297 major financial systems.

Evidence: Exhibit 275, Exhibit 276, Exhibit 277, Exhibit 278, Exhibit 279, Exhibit 281, Exhibit 282, Exhibit 283

Mechanism: The study not run

§3.3.1

The Inspector General's FY2024 report states that "comparing the number of material weaknesses from year to year is not a reliable way to measure progress towards a clean financial statement opinion." The table records what the auditors reported in each year.

§3.3.2

The component-level figures also differ between reports. The FY2024 report states 151 material weaknesses and 2,848 notices of findings across components. The FY2025 report states 121 entity-level weaknesses, described as 21 fewer than the prior year, and 2,485 notices of findings, described as 427 fewer. Taken against the FY2024 totals, the stated reductions do not reconcile: 151 less 21 is 130, and 2,848 less 427 is 2,421. Neither report explains the difference.

3.4 Components with clean opinions

Finding DEF-3.4Primary record

In fiscal year 2025 the DoD Inspector General reported opinions on 21 reporting entities: 11 clean, 1 qualified and 9 disclaimers, up from 5 clean opinions among 21 entities in fiscal year 2018. The Congressional Research Service reports that the entities with disclaimers account for 43 percent of DoD assets.

The Inspector General's counts of clean opinions among entities rose from 5 of 21 in fiscal year 2018 to 11 of 21 in 2025. GAO's snapshot of FY2023 counted 10 clean opinions and 18 disclaimers among 29 components. GAO found that nearly all of the assets held by components with clean opinions in FY2024 belong to the Military Retirement Fund.

Evidence: Exhibit 283, Exhibit 292, Exhibit 288, Exhibit 289, Exhibit 275

Mechanism: The study not run

§3.4.1

The count of clean opinions is one measure of progress that the audit reports record. It rose from 5 in fiscal year 2018 to 11 in fiscal years 2024 and 2025 in the Inspector General's reports, and the Marine Corps has held a clean opinion since fiscal year 2023. The denominators vary: 21 to 29 entities in the Inspector General's reports, 24 to 29 in GAO's counts and 26 in the Congressional Research Service's count.

§3.4.2

The clean opinions cover a smaller share of assets than their number suggests. GAO's September 2025 report states that the eleven components with clean opinions in FY2024 held 42.8 percent of DoD's reported assets, and that nearly all of that share relates to the Military Retirement Fund. The Congressional Research Service reports that the components with disclaimers account for 43 percent of assets and at least 64 percent of budgetary resources. The disclaimers cover the Army, Navy and Air Force.

3.5 The Army adjustments of 2016

Finding DEF-3.5Primary record

In 2016 the DoD Inspector General found that the Army and DFAS Indianapolis did not adequately support $2.8 trillion in third-quarter and $6.5 trillion in year-end journal voucher adjustments to fiscal year 2015 Army General Fund data. The report states that the amounts are not cumulative and should not be added together.

The Inspector General's 2016 report, DODIG-2016-113, examined adjustments made to fiscal year 2015 Army General Fund data. DFAS's own count was that 138,887 of 142,355 year-end adjustments, worth $4.44 trillion, lacked support. The Inspector General found that 170 of 194 adjustments sampled as supported, worth $2.1 trillion, were also unsupported.

Evidence: Exhibit 284

Mechanism: The study not run

§3.5.1

The report states in a footnote that the two headline amounts "are not cumulative and should not be added together." The Inspector General found that 137,618 of the unsupported adjustments, worth $4 trillion, were generated by systems and not by a person. In one example a net unsupported adjustment of $99.8 billion was applied to an intragovernmental receivable balance of $0.2 billion.

§3.5.2

The DFAS Indianapolis Director disagreed with the dollar values. The Director's response stated that the figures were a misrepresentation, because 22 adjustments totaling $1.4 trillion were counted in both the third-quarter and the year-end amounts. The Inspector General disagreed with the response and added the footnote that the amounts are not cumulative.

Exhibit 284 · Inspector general report

Army General Fund Adjustments Not Adequately Documented or Supported (DODIG-2016-113)

Amounts are not cumulative and should not be added together.

Found that the Army and DFAS Indianapolis did not adequately support $2.8 trillion in third-quarter and $6.5 trillion in year-end journal voucher adjustments to FY2015 Army General Fund data. DFAS's own count: 138,887 of 142,355 year-end adjustments unsupported ($4.44 trillion), and the IG found 170 of 194 sampled 'supported' adjustments ($2.1 trillion) were in fact unsupported. 137,618 unsupported adjustments, $4 trillion, were system-generated. Footnote 2: amounts are not cumulative. The DFAS Director said the values were a misrepresentation because 22 adjustments totaling $1.4 trillion were counted in both periods; the IG disagreed (PDF p. 21-22). Example effect: net unsupported adjustment of $99.8 billion to a $0.2 billion intragovernmental receivable balance.

Source
DoD Office of Inspector General
Date
26 July 2016
Quoted from
PDF p. 3 (footnote 2) and p. 4
Grade
Primary record
Document
https://media.defense.gov/2016/Jul/26/2001714261/-1/-1/1/DODIG-2016-113.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit

3.6 What an unsupported adjustment is

Finding DEF-3.6Primary record

An unsupported accounting adjustment is a change to the accounting records that lacks the documentation showing why it was made. In 2018 the Under Secretary of Defense (Comptroller) told the House Armed Services Committee that this is not the same thing as not being able to account for money that Congress has given the department to spend.

The Inspector General's 2026 report defines unsupported accounting adjustments as "Changes made to accounting records without the proper documentation to show why the change was needed or correct." The same report states that adjustments totaled more than $859 billion in the last two quarters of FY2025, and lists unsupported adjustments as a continuing material weakness.

Evidence: Exhibit 283, Exhibit 284, Exhibit 285

§3.6.1

An adjustment is an entry that changes a ledger balance, usually to make the general ledger agree with another record such as a property book. An adjustment is unsupported when the file does not show why the entry was made or whether it was correct. The size of an adjustment is the size of the change to the ledger. It does not measure spending or lost funds.

The official position

On 10 January 2018 Representative Walter Jones asked the Under Secretary of Defense (Comptroller), David Norquist, about the Inspector General's report of $2.8 trillion and $6.5 trillion in Army adjustments. Norquist replied that journal vouchers are written after money is spent, that entries are made from the property book into the general ledger, and that an entry without adequate support is unsupported. He told the committee: "It is not the same thing as not being able to account for money that Congress has given you to spend, but it is still a problem that needs to be fixed."

What the record shows

The Inspector General's finding is about documentation. The Army and DFAS could not show why 170 of 194 sampled entries were correct. The report does not state that any money was lost, and its footnote states that the two headline amounts are not cumulative. The Inspector General's FY2025 definition of an unsupported adjustment, quoted above, also turns on documentation.

§3.6.2

The FY2025 report shows that the weakness persists, with adjustments of more than $859 billion in the last two quarters of that year and unsupported adjustments still listed as a material weakness. The Inspector General's report does not give the unsupported share of the $859 billion.

Exhibit 285 · Hearing transcript

Department of Defense Update on the Financial Improvement and Audit Remediation Plan, H.A.S.C. No. 115-64

It is not the same thing as not being able to account for money that Congress has given you to spend, but it is still a problem that needs to be fixed.

Rep. Walter Jones asked about the IG's report that the Army made $2.8 and $6.5 trillion in adjustments. Under Secretary (Comptroller) David Norquist answered that journal vouchers occur after money is spent, that entries are written from the property book into the general ledger, and that an entry without adequate support is wholly 'unsupported'.

Source
House Committee on Armed Services
Date
10 January 2018
Quoted from
Norquist reply to Mr. Jones, govinfo HTML text (printed page not yet recorded)
Grade
Primary record
Document
https://www.govinfo.gov/content/pkg/CHRG-115hhrg28967/html/CHRG-115hhrg28967.htm
Accessed
2026-11-09
Cited by
Findings citing this exhibit

3.7 The 2028 requirement

Finding DEF-3.7Primary record

Congress made the full DoD audit annual in the FY2018 National Defense Authorization Act and required an unqualified opinion by 31 December 2028 in the FY2024 Act. The FY2024 Act also requires cancellation of 1.5 percent of unobligated amounts for any component that is not independently audited.

Section 1002 of the FY2018 Act, creating chapter 9A of title 10, required a full audit each fiscal year. Section 1005 of the FY2024 Act requires an unqualified opinion by 31 December 2028. Section 1004 states that a component that fails to be subject to an independent audit "shall have 1.5 percent of unobligated amounts available for the component be cancelled and returned to the general fund of the Treasury for deficit reduction."

Evidence: Exhibit 295, Exhibit 296, Exhibit 297

§3.7.1

Section 1004 excludes military personnel and Defense Health Program accounts. Section 920 of the same Act requires audit-remediation metrics by 30 April 2025 and an evaluation of using them in the performance evaluations of senior officers and senior executives. The FY2026 Act, in section 1002, requires a funding estimate for corrective action plans, a ranking of components by auditability, and annual reports from the bottom quartile. Section 1005 of that Act extends the component audit requirement to 2035.

§3.7.2

No cited source records that any component has lost 1.5 percent of its unobligated funds under section 1004. Breaking Defense reported on 19 December 2025 that the acting Comptroller, Jules Hurst, wrote to Congress that the department would not reach its 2028 goal without a significant acceleration of its efforts, and that a revised strategy would follow in fiscal year 2026.

§3.7.3

GAO's May 2026 testimony examined the revised approach. It states that the approach "would be deprioritizing remediating key internal control deficiencies for two or more years." GAO counted 17 scope-limiting weaknesses, of which one has been resolved.

Exhibit 298 · News report

Pentagon fails (another) audit, restates 2028 goal to finally pass

the Department of War will not reach its goal of achieving a clean financial statement audit without a significant acceleration of its efforts

Reports a letter from the acting comptroller Jules Hurst that the department 'will not reach its goal' of a clean audit by 2028 'without a significant acceleration of its efforts' and a revised strategy in FY2026.

Source
Breaking Defense (Valerie Insinna)
Date
19 December 2025
Quoted from
Valerie Insinna, 19 Dec 2025, quotation from Jules Hurst's letter
Grade
Reported
Document
https://breakingdefense.com/2025/12/pentagon-fails-another-audit-restates-2028-goal-to-finally-pass/
Accessed
2026-11-09
Cited by
Findings citing this exhibit

3.8 Counting what is on the shelf

Finding DEF-3.8Primary record

GAO could not locate 18 of 96 sampled Air Force equipment items at the Reliance Test & Technology facility at Eglin Air Force Base; in the report body's generalizable sample at that facility the count was 14 of 58. GAO could not locate 58 of 104 sampled items at a second contractor, Standard Aero.

GAO's February 2026 report on Air Force general equipment held by contractors reports three counts. At Reliance Test & Technology at Eglin, GAO could not locate 18 of the 96 sampled items. The report body gives 14 of 58 (about 24 percent) for the generalizable sample at that facility. At Standard Aero, the count was 58 of 104 sampled items.

Evidence: Exhibit 290

Mechanism: The study not run

§3.8.1

The 18 of 96 and 14 of 58 figures refer to different samples at the same facility, and the 58 of 104 figure refers to a different facility. GAO also verified all 187 pod records at a Raytheon facility and all sample items in the Defense Property Accountability System. The Air Force concurred with one recommendation and partially concurred with the other.

§3.8.2

Two smaller physical tests also found discrepancies. For fiscal year 2021 the Inspector General reported that auditors from Ernst & Young found the Navy's records showing eight guided missile fin assemblies at a contractor's site, and a physical count found two. In 2023 the Inspector General found that the F-35 program office lacked a valid population of Joint Strike Fighter inventory, and that 41 of 217 part numbers reviewed (19 percent) had at least one existence or completeness error.

Exhibit 278 · Inspector general report

Understanding the Results of the Audit of the FY 2021 DoD Financial Statements

Ernst & Young determined that although the Navy’s Inventory records showed eight guided missile fin assemblies at the contractor’s site, a physical count revealed only two at the site.

FY2021: disclaimer issued 15 November 2021; 28 material weaknesses and 4 significant deficiencies; of 26 reporting entities with stand-alone audits, 8 clean, 1 qualified, 17 disclaimers (PDF p. 38). Inventory section reports a physical count at a Navy contractor site found 2 of 8 recorded guided missile fin assemblies.

Source
DoD Office of Inspector General
Date
18 May 2022
Quoted from
PDF p. 28 (Inventory and Related Property)
Grade
Primary record
Document
https://media.defense.gov/2022/Jun/01/2003009509/-1/-1/1/UNDERSTANDING%20THE%20RESULTS%20OF%20THE%20FY%202021%20AUDIT_FINAL.PDF
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Further quotation: “On November 15, 2021, the DoD OIG issued a disclaimer of opinion on the FY 2021 Agency-Wide Financial” (The FY 2021 Agency-Wide Audit Results panel (page marked 12 in the text layer; the sentence continues 'Statements' in the next text column)).

Exhibit 291 · Inspector general report

Management Advisory: DoD's Ability to Financially Report Joint Strike Fighter Inventory (DODIG-2023-096)

Our test determined that 41 (19 percent) of the 217 part numbers we reviewed had at least one existence or completeness error.

The F-35 program office lacked a valid population of JSF inventory; DoD reported no JSF inventory values in FY2022 statements.

Source
DoD Office of Inspector General
Date
21 July 2023
Quoted from
PDF p. 3
Grade
Primary record
Document
https://www.oversight.gov/sites/default/files/oig-reports/DoD/DODIG-2023-096.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit

3.9 The department's account of progress

Finding DEF-3.9Primary record

The Defense Department reports progress in its own audit record: the Marine Corps has received a clean opinion since fiscal year 2023, the FY2025 audit report records 121 entity-level material weaknesses and 2,485 notices of findings, which it describes as 427 fewer, and GAO counts one of 17 scope-limiting weaknesses as resolved.

The department's progress appears in the audit reports themselves. The FY2023 report records the Marine Corps' first clean opinion. The FY2025 report records 121 entity-level material weaknesses and 427 fewer notices of findings, and GAO counts one of 17 scope-limiting weaknesses as resolved.

Evidence: Exhibit 281, Exhibit 283, Exhibit 287

§3.9.1

The Inspector General's FY2025 report counts 297 major financial systems and states a plan to retire 39 of them by the end of fiscal year 2027. GAO's FY2023 snapshot records DoD officials saying that the rate of remediation fell because the department first addressed the less complex issues.

§3.9.2

The audits have also located assets. GAO's snapshot records that the Navy added nearly $2.4 billion in assets in fiscal year 2020 that it had not known to exist. The Congressional Research Service records $4.3 billion in Navy equipment that DoD reports it had not been tracking.

§3.9.3

The Inspector General's FY2025 report plans substantive testing of physical assets in fiscal year 2026, and its count shows 929 notices of findings without a remediation date. GAO states that the revised approach would postpone work on internal controls. The Inspector General reported its FY2025 results in December 2025, and the FY2026 results had not been published as of 9 November 2026.

3.10 Questions the sources leave open

§3.10.1

Four questions are open in the record. The first is whether the FY2026 audit will produce another disclaimer. The second is whether any component has lost funds under section 1004. The third is how the Inspector General's component-level weakness and finding counts for FY2024 and FY2025 reconcile. The fourth is what share of the more than $859 billion in FY2025 adjustments was unsupported.

§3.10.2

The department-wide result is documented for each of the eight years. The Inspector General issued a disclaimer in each, GAO states that DoD has never obtained a clean opinion, and Congress has set 31 December 2028 as the date for an unqualified opinion. None of the cited sources reports an amount of money lost.

Key findings

  1. The DoD Inspector General has disclaimed an opinion on the department-wide statements in each of fiscal years 2018 through 2025, and DoD has never obtained a clean opinion (3.1).
  2. Congress set audit readiness for 2017 and a full audit of fiscal year 2018 (3.2).
  3. Agency-wide material weaknesses stood at 20 in FY2018, 28 in FY2021 through FY2024, and 26 in FY2025 (3.3).
  4. Clean opinions among components rose from 5 of 21 to 11 of 21, and the 11 components with clean opinions in FY2024 held 42.8 percent of reported assets, nearly all of it the Military Retirement Fund (3.4).
  5. The Inspector General's 2016 Army figures measure unsupported adjustments, and the report states they should not be added together (3.5).
  6. An unsupported adjustment lacks documentation. The Comptroller told Congress it is not the same as being unable to account for money (3.6).
  7. Congress now requires a clean opinion by 31 December 2028 and cancellation of 1.5 percent of unobligated funds for unaudited components (3.7).
  8. GAO could not locate 18 of 96 sampled items at one contractor site, and 58 of 104 at another (3.8).
  9. The department reports a Marine Corps clean opinion, fewer entity-level weaknesses and 427 fewer notices of findings (3.9).

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