What changed with the 2026 TINA and CAS thresholds?
These changes come from the Fiscal Year 2026 National Defense Authorization Act (Sections 1804 and 1806), signed into law on December 18, 2025. They take effect for contracts entered into after June 30, 2026, with implementing regulations following.
What actually changed
- Certified cost or pricing data (TINA), Title 10 §3702: the threshold moves from $2.5M to $10M. Many sole source and limited competition contracts between $2.5M and $10M will no longer require certified cost or pricing data.
- CAS contract applicability, Title 41 §1806: the threshold moves from $2.5M to $35M. Many negotiated contracts in that range move out of CAS applicability.
- Full CAS coverage, Title 41 §1806: the threshold moves from $50M to $100M. Fewer business units trigger full CAS coverage and full disclosure statement burdens.
Why it matters
Lighter certification requirements are good news, but "no certified data required" is not the same as "no data required." Contracting officers still need information other than certified cost or pricing data to determine that a price is fair and reasonable. The work shifts from formal certification toward well organized, defensible pricing support.
The firms that benefit most are the ones that update their internal posture before the date, rather than discovering the new rules mid pursuit.
What to do before July 1
- Flag every award, modification, and subcontract that will cross July 1, 2026, and confirm which threshold set applies.
- Update proposal instructions, pricing checklists, and subcontract templates to reflect the new thresholds, so your team is not citing the old ones.
- Keep your pricing support strong even where certification is not required. Document market research, comparisons, and cost realism. The bar for "fair and reasonable" did not disappear.
Frequently asked
Does this apply to all agencies or just DoD? The thresholds were set in the defense authorization act and apply across the statutory framework for certified cost or pricing data and Cost Accounting Standards. Watch the implementing FAR and DFARS rules for agency specific mechanics.
Is this final, or still proposed? The statute is enacted law. Implementing regulations were directed to follow within 180 days of enactment, so the regulatory mechanics continue to roll out.
We are a small business. Does this help us? Often yes. Fewer mid sized awards will carry certified cost or pricing data and CAS burdens, which can shorten proposal effort. The trade off is that you still need clean, defensible pricing support ready to go.
General information for Federal contractors, not legal advice. Confirm specifics against the FAR, DFARS, and the FY2026 NDAA for your situation.