What Government Contractors Need to Know About TINA Lite Becoming Permanent

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Highlights

• Preview Guidance. On July 8, 2026, Defense Pricing, Contracting, and Acquisition Policy issued Version 1.0 (Preview) of the TINA Lite Policy & Implementation Guide, describing how contracting officers may tailor certified cost or pricing data requirements for eligible acquisitions.
• Permanent Authority. The FY 2026 National Defense Authorization Act made TINA Lite permanent and codified the program at 10 USC 3709, although implementing DFARS regulations remain pending.
• Program Eligibility. TINA Lite applies to eligible contract actions exceeding $50 million and requires reliable historical actual cost data.
• Tailored Data Requirements. TINA Lite does not waive Truthful Cost or Pricing Data requirements but allows the contracting officer to specify the specific required certified data.
• Contractor Implementation. Government contractors will need to review solicitation requirements carefully to determine the specific required data, submission format, disclosure timing, and subcontractor responsibilities.

On July 8, 2026, Defense Pricing, Contracting, and Acquisition Policy issued Version 1.0 (Preview) of TINA Lite Policy & Implementation Guide. The term “TINA Lite” has been used to refer to “the authority to tailor the type and extent of certified cost or pricing data required for eligible, approved acquisitions.” The guidance states that it “provides [contracting officers] with a targeted alternative to traditional Truthful Cost or Pricing Data (TINA) requirements, allowing price reasonableness determinations to be grounded primarily in actual historical cost data from prior acquisitions.”

Please note: The Defense Federal Acquisition Regulation Supplement (DFARS) regulations to implement TINA Lite as a permanent program have not been promulgated as of the date of this article.

Background

TINA Lite was introduced as a pilot program in the FY 2019 National Defense Authorization Act (NDAA) Section 890. The pilot was extended in the FY 2020 NDAA Section 825, FY 2023 NDAA Section 818, and FY 2024 NDAA Section 841. Then in FY 2026 NDAA Section 812(c) the program was made permanent. The program was placed into law effective July 20, 2026, at 10 USC 3709: Program to accelerate contracting and pricing processes.

Structure of the Guide

The guide has five sections:

1. General Information: Overview of TINA Lite for those new to the authority or seeking general and historical information.
2. Planning: Practical pre-award information, processes, decision tools, and best practices for COs planning and executing a TINA Lite acquisition.
3. Execution: Guidance on administering TINA Lite actions including proposal content, data adequacy, and documentation.
4. Analysis: Guidance on analysis of historical actual cost data and determining price reasonableness.
5. Additional Information, Resources, and Policy: Provides additional information and policy on TINA Lite and related pricing authorities.

Key Program Requirements

The program is limited to Department of War (DOW), Defense if you would like, and will be implemented through regulations to be placed into DFARS. To utilize the now permanent program:

• The prime contract must be estimated to be greater than $50M, subcontracts under the prime may be of a lower value;
• The prime, including its subcontracts, must be determined to be a fair and reasonable price;
• There must be reliable and meaningful history actuals for the same or similar product which has been delivered to DOW; and
• The contracting officer needs to get approval from their Head of the Contracting Activity (HCA).

The guide states that “TINA Lite is a targeted pricing tool — not a waiver of TINA requirements and not a shortcut. It is the authority to strategically tailor the type and extent of certified cost or pricing data required in a Request for Proposal, in lieu of data required by FAR part 2 with historical actual cost data from prior relevant acquisitions.”

Myth vs. Fact

TINA Lite does not eliminate the need for certified cost or pricing data. It requires the contracting officer to state the specific required certified cost or pricing data in the solicitation.

TINA Lite is not limited to just prime contractors. TINA Lite may be flowed down to first-tier or lower-tier subcontractors. The contracting officer “must specify the data requirements for covered

The way we see the intent of this program is for a contracting officer with a well-established sole source production program to state in the solicitation the certified cost and pricing data (i.e., historical actual costs) they will rely on to determine the price fair and reasonable. This subset of data will allow the contractor to focus on that subset of data and reduce the effort necessary to develop and present a complete bottom-up proposal for the contracting officer.

Is This a Good Thing or a Bad Thing

One of the five key elements of establishing defective pricing, the principle underlying the TINA statute, is that the Government relied on the certified cost or pricing data. If the Government is going to set forth the data, it plans to rely on before the contractor even starts the develop of its proposal – that is a good thing.

The guide provides that a best practice is to have the Defense Contract Audit Agency (DCAA) “pull cost information directly from a contractor’s enterprise resource planning (ERP) or other financial systems.” DCAA auditors going on fishing expeditions in the contractor’s systems for historical cost data without the complete understanding of the program management practices and processes in place – that could certainly be a very bad thing.

The guide states that it is a best practice to clarify how data sweeps after price agreement will be handled. It goes on to state “[i]f deferring the review of sweep data (and engaging a DCAA post-award review), clearly document that the sweep data was NOT reviewed, but was provided to DCAA.” Is this going to result in a practice to where DCAA will be performing some type of audit procedures on all sweep disclosures – again a very bad thing.

What Government Contractors Need to Know

The contracting officer should be engaging with the contractor (i.e., collaborating) to reach a mutual understanding on:

• What data is available;
• The format in which the data is to be submitted; and
• The scope and expected timeliness of the required data disclosures.

The contractor will need to carefully review the solicitation as some parts of the proposal will be subject to TINA Lite requirements and other parts will require the traditional requirement for submission of certified cost or pricing data. The guide states “TINA Lite does not preclude use of certified cost or pricing data for items not covered by TINA Lite, unique items, or non-recurring aspects of the acquisition.”

The prime and higher-tier contractor will need to ensure the “type, structure, and level of detail of historical actual cost data required from subcontractors” is clear to all parties.

Recommended Best Practice

As part of the collaborative process request that the contracting officer provide a draft copy of the request for proposal so the contractor can provide edits to the specific data type, period, and format required at the prime and subcontract level. This will help ensure there is little, if any, back and forth as to the data being provided.

The contractor will have to ensure that the Government is made aware of any significant changes to production processes and practices that could make the historical data not representative of the future and therefore not current, accurate, and complete. Significant changes in production processes and practices as well as scope of work by the Government will likely result in the acquisition not being found appropriate for TINA Lite.

Preparing for TINA Lite Requirements

Redstone GCI assists government contractors in evaluating TINA Lite solicitation requirements, identifying which proposal elements are subject to tailored or traditional certified cost or pricing data requirements, and determining whether historical actual costs are reliable and representative of the proposed work. Our team reviews required data types, periods, formats, and disclosure expectations, helps prime and higher-tier contractors establish clear subcontractor flowdown requirements, and works with accounting, estimating, contracts, and program personnel to align ERP data and proposal support. We also assist with cost volume development, estimating procedures, data sweep processes, and training so government contractors understand their responsibilities before proposal submission and price agreement.