On September 1, 2026, the Cost Accounting Standards Board published a final rule that takes effect October 1, 2026. The rule makes the most significant changes to CAS applicability in decades. Federal contractors should assess the impact before October 1.
What Changed
Basic CAS applicability threshold: Raised from $2.5 million to $35 million. Negotiated contracts and subcontracts at or below $35 million are now exempt from CAS entirely. The $7.5 million trigger-contract concept is eliminated.
Full CAS coverage and Disclosure Statement threshold: Doubled from $50 million to $100 million. Contractors previously subject to full CAS coverage based on the $50 million threshold may be eligible to transition to modified coverage beginning October 1.
Agency waiver authority: Raised from $15 million to $100 million. Agency heads may now waive CAS on individual contracts up to $100 million without prior Board approval.
Indefinite delivery contracts: For multiple-award IDCs, CAS applicability is determined at the individual task or delivery order level using the order ceiling value. For single-award IDCs, CAS applicability is determined at the IDC level using the IDC ceiling value.
What Did Not Change
CAS thresholds and TINA thresholds are now decoupled. The threshold for certified cost or pricing data remains at $2.5 million for non-defense contracts (and $10 million for covered DoD contracts under the FY 2026 NDAA). A contract exempt from CAS may still require certified cost or pricing data.
Small businesses remain exempt from CAS regardless of contract value.
Transition
Contractors currently subject to full CAS coverage under the prior $50 million threshold may transition affected contracts to modified coverage at the start of their next full cost accounting period beginning on or after October 1, 2026, provided the business unit has no unresolved CAS noncompliances and does not meet the criteria for full coverage under the new $100 million threshold.
Source
Cost Accounting Standards Board, Increase of Monetary Thresholds and Other Matters Related to Cost Accounting Standards Program Requirements, 91 Fed. Reg. 56056 (Sept. 1, 2026), effective Oct. 1, 2026.