CAS Board Final Rule – Increase of Monetary Thresholds and Other Matters Related to Cost Accounting Standards Program Requirements
15th October 2026
On September 1, 2026, the CAS Board issued a final rule related to monetary thresholds and other matters related to CAS applicability. Regarding monetary thresholds, the final rule:
- Raises the threshold for full CAS coverage and Disclosure Statement submission requirements from $50 million to $100 million
- Eliminates the CAS 9903.201-1(c)(ii) exemption if a segment’s CAS-covered awards are less than 30% of total segment sales for the period and less than $10 million
- Clarifies that a Disclosure Statement is required only for segments or business units that independently meet the applicable thresholds for full CAS coverage
- Provides a mechanism for determining eligibility for modified CAS coverage for contractors currently subject to full CAS coverage that would not otherwise be subject to full CAS coverage at the $100 million threshold. However, this requires that the contractor not have any unresolved CAS noncompliances.
- Does not change the definition of a CAS segment (i.e., address industry comments related to prior CAS Board inquiries regarding the relationship of a CAS segment and Unique Entity Identifier)
- Updates statutory exemptions at 9903.201-1(b) for modified CAS coverage (i.e., increase to $35 million; elimination of $7.5 million trigger contract threshold)
- Notes that the CAS Board has begun reviewing contract price adjustments requirements, which will be addressed in a separate case in accordance with the FY 2026 NDAA
- Modifies three statutory CAS exemptions at 9903.201-1(b) to make them applicable to portions of contracts and subcontracts (i.e., hybrid contracts)
The final rule also amends 9903.202-1 to clarify that the applicability of CAS to multiple-award Indefinite Delivery Contracts (IDCs) is determined at the task or delivery order level. For multiple award IDCs, CAS would only apply to individual task or delivery order whose values meet the CAS coverage threshold and do not qualify for CAS exemptions. For single-award IDCs, CAS applicability will be determined at the time of award using the ceiling value. The final rule also clarifies that a single-award IDC can be exempt from CAS if the entire IDC qualifies for one of the 9903.202-1(b) exemptions. The final rule states that the treatment for IDCs will reduce regulatory burden and promote consistency in the application of CAS. It is unclear how establishing separate requirements for multiple and single-award IDCs accomplishes these objectives.
The effective date of the final rule is October 1, 2026.
The DoW issued a class deviation dated July 30, 2026 to increase the full CAS applicability threshold and the Disclosure Statement threshold from $50 million to $100 million effective immediately for DoW contracts. DCAA subsequently issued an MRD dated September 29, 2026 addressing the increases to the CAS monetary thresholds. It supersedes audit guidance issued in an August 19 MRD and instructs auditors to evaluate the need for an initial Disclosure Statement given the increase to the full CAS and Disclosure Statement applicability thresholds. It also instructs auditors to verify that the business unit or segment is performing CAS covered contracts before initiating a CAS compliance audit.
Read the final final rule.
Read the memorandum.
Read the September 29 MRD.
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