The Cost Accounting Standards Board published a final rule on 1 September raising every major CAS dollar threshold. It takes effect 1 October. The headline number: basic CAS applicability moves from $2.5 million to $35 million, and the separate $7.5 million trigger contract concept goes away entirely.
What changed
Full CAS coverage and Disclosure Statement thresholds double, from $50 million to $100 million. Agency-head waiver authority, the power to waive CAS without Board approval, rises from $15 million to $100 million, implementing a provision of the FY2017 NDAA that has sat unwritten into the CFR for nine years. The statutory change driving the applicability increase came in Section 1806 of the FY2026 NDAA, enacted last December, and the proposed rule ran on 20 March.
The exemption at 9903.202-1(c)(ii), covering segments whose CAS-covered awards fall under 30 percent of segment sales and under $10 million, is deleted along with the rest of 9903.202-1(c).
The Board’s own numbers on the full-coverage threshold are worth reading. Analyzing FPDS data for fiscal 2020 through 2024, it found 773 entities subject to full coverage and Disclosure Statements, with aggregate contract value of $1.22 trillion. At $100 million, that drops to 564 entities while retaining $1.21 trillion. Roughly a 30 percent cut in entities for a sub-1 percent loss of dollars. Across all thresholds, the Board estimates the statutory change reduces covered business segments by about 60 percent while keeping over 90 percent of the money in scope. Those are Board estimates using Unique Entity Identifier as a proxy for segment, and commenters flagged that a UEI and a CAS segment aren’t the same thing.
The IDC ruling cuts the other way
For multiple-award indefinite-delivery contracts, applicability is now determined at the task or delivery order level. For single-award IDCs, it’s determined at the contract level using ceiling value. Industry commenters objected to the second half and lost. The Board’s justification is a number: obligations on task orders under single-award IDCs hit $262 billion in fiscal 2024, over a third of all contract obligations, and the Board wrote that single-award vehicles increase the potential for vendor lock-in.
So a contractor holding a $100 million sole-source ID/IQ ceiling is CAS-covered from day one, whether or not the orders ever show up.
Who this actually helps
Nine sets of comments came in, five from industry associations, and all of them supported the direction. Commenters did win a transition mechanism: a contractor currently under full coverage can move to modified coverage on new awards only if it has no unresolved CAS noncompliances.
The practical read is that a compliance regime built to chase $3 million task orders no longer buys anything, and the entry price for federal work with cost-based pricing just moved up an order of magnitude. Whether that produces the competition the Board expects is unproven. The Board concedes that comments "did not provide information to quantify the impact," so "reduces barriers to entry" remains an assertion.
Federal building programs are where this lands first. Long-running work like the Smithsonian Institution Building revitalization runs through exactly the cost-accounting machinery these thresholds govern. The rule is signed by Kevin R. Rhodes, administrator of the Office of Federal Procurement Policy and CAS Board chair; the full text is in the Federal Register.