Eligibility is narrow. The government must not already know about the conduct, so a disclosure cannot overlap with a pending qui tam complaint. The pilot covers civil liability only. Criminal conduct goes to DOJ's National Fraud Enforcement Division under a separate policy. The announcement does not say whether a permanent self-disclosure option will follow the pilot.
The window is short and the requirements are demanding. A disclosing company must investigate the conduct, quantify its financial impact (often through sampling and extrapolation), assemble exhibits that fully reflect the conduct, write a narrative that cross-references them, implement and document remediation, and secure a certification, all before the deadline. Law firm alerts from late October and early November are urging boards to act now. General counsel should start the internal review immediately, since the timeline leaves little room for a slow start. Counsel should also check for any qui tam activity, because a pending complaint would bar eligibility.