DCAA’s October 6, 2026, memorandum addresses exemptions for nontraditional defense contractors from certain cost, pricing, and business system requirements. DCAA may still provide audit and advisory support, and contractors may still need to provide cost data. Questions remain about implementation and how individual exempt contracts will be reviewed.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Estimating System Compliance
Department of War’s (DoW) October 1, 2026, memorandum provides guidance on cost data requests, reporting, and profit expectations. Questions remain about how the direction will affect pricing negotiations, accounting requirements, and profit sharing. Government contractors should assess these expectations alongside existing contract terms and applicable regulations.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Estimating System Compliance, Commercial Determination
DoW is pursuing significant acquisition reforms that could reshape CAS applicability, pricing, audits, and contractor business system oversight. The planned changes emphasize greater use of GAAP, reduced administrative requirements, and streamlined acquisition practices, with implementation actions scheduled over the next 30 to 120 days and additional regulatory changes potentially required.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Estimating System Compliance, Manufacturing Operations Consulting
The CAS Board has finalized significant changes to CAS thresholds and coverage requirements effective October 1, 2026. The rule raises the basic and full coverage thresholds while introducing new considerations for IDIQ contracts, existing awards, and Disclosure Statement requirements.
Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Estimating System Compliance
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On August 18, 2026, DoW issued a memorandum calling for broader access to contractor and subcontractor cost data, greater pricing transparency, and increased scrutiny of profit. The direction could significantly affect pricing practices, negotiations, system access, and compliance expectations across the defense industrial base.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Estimating System Compliance
DoD’s July 30, 2026, class deviation raises the Full CAS and Disclosure Statement thresholds to $100 million, changing how CAS coverage may apply to certain defense contracts. Government contractors should reassess CAS applicability, pending proposals, Disclosure Statement requirements, and ongoing audit activity to determine how the new thresholds affect current obligations.
Topics: Accounting System Compliance, DFARS Business Systems, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Estimating System Compliance
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Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Estimating System Compliance, Commercial Determination
The Department of Defense (DoD) issued an advance notice of proposed rulemaking (ANPR) on July 2, 2026, Defense Federal Acquisition Regulation Supplement: Modifications to Printed Circuit Board Acquisition Restrictions (DFARS Case 2022-D-011) on prohibiting the acquisition of printed circuit boards (PCBs) from certain countries. DoD is requesting input from experts and industry to assist in the development and revision of DFARS. Comments are due August 31, 2026.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Estimating System Compliance, Commercial Determination, Manufacturing Operations Consulting
The United States Supreme Court has ruled that the International Emergency Economic Powers Act does not authorize presidential tariffs, effectively invalidating prior IEEPA-based duties. This decision creates uncertainty around potential refunds and shifts attention to new tariff measures now in effect. Importers and trade compliance teams must reassess duty exposure, documentation practices, and forward-looking trade strategies in a rapidly changing regulatory environment.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Material Management & Accounting System (MMAS), Estimating System Compliance, Manufacturing Operations Consulting
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Government contractors will see another significant change to the acquisition threshold under the FY 2026 National Defense Authorization Act. The Truthful Cost or Pricing Data threshold is increasing to $10 million, creating new considerations for proposals, negotiations, and contract modifications. Multiple threshold updates within a short period have introduced added complexity around timing, clause language, and award dates. Understanding how these changes interact with existing contracts is essential for maintaining consistency and avoiding unnecessary compliance risk.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Estimating System Compliance