NDAA Raised the CAS and TINA Thresholds — These Changes Are Already in Effect and Every Defense Contractor Must Recalibrate

Published August 28, 2026 | TIKC NewsWire

Two of the most significant compliance reforms in the FY2026 National Defense Authorization Act are already in effect — and a significant number of defense contractors have not yet recalibrated their compliance posture to reflect them. A significant increase in the threshold for requiring certified cost or pricing data took effect for certain defense contracts on July 1, 2026. Section 1804 of the FY2026 NDAA increased the threshold from $2.5 million to $10 million. And separately, Section 1806(d) of the NDAA text increases the threshold for the mandatory application of CAS at the contract level from $2.5 million to $35 million, effectively eliminating the current CAS trigger contract mechanism.

Change 1: The TINA Threshold Is Now $10 Million

The Truthful Cost or Pricing Data Act — historically known as TINA — requires contractors to submit certified cost or pricing data when negotiating defense contracts above the applicable threshold. Section 1804(c) raises this threshold to $10 million for contracts entered into after June 30, 2026. Inaccurate certified cost or pricing data may reduce contract price, trigger penalties, and even expose companies to False Claims Act liability.

Change 2: The CAS Threshold Is Now $35 Million

Cost Accounting Standards are a set of 19 standards governing how contractors accumulate and allocate costs under government contracts. Section 1806(d) raises this threshold to $35 million, effectively eliminating the current CAS trigger contract mechanism. For the vast majority of small and mid-size defense contractors, this change means they will no longer face CAS coverage on new contracts.

What This Means for Your Compliance Program

Apply the new thresholds to contracts entered after July 1, 2026 only. Both the TINA and CAS threshold increases apply prospectively. Existing contracts remain subject to the prior thresholds.

If you have previously been CAS-covered, reassess your coverage status. Your future contracting decisions may be significantly simplified — and that simplification should factor into your business development strategy.

The FCA exposure for TINA violations shifts to higher-value contracts. TINA’s certification requirement now applies to defense contracts above $10 million. The FCA consequences apply to every negotiation above that threshold with the same force they applied at $2.5 million.

Commercial item and fixed-price contractors may see the largest benefit. If you have avoided defense contracting because of CAS and TINA compliance costs, the landscape has changed materially. Reassess your entry strategy.

The Bottom Line

The FY2026 NDAA’s CAS and TINA threshold increases are the most significant defense contractor accounting compliance reforms in years, and they are already in effect. If your firm has contracts entered after July 1, 2026, review them against the new thresholds now. Brick by brick — understand your obligations under the law as it is today, not as it was last year.

Frequently Asked Questions

What is TINA and what does the threshold change mean?

TINA requires contractors to submit certified cost or pricing data when negotiating defense contracts above the applicable threshold. The FY2026 NDAA raised that threshold from $2.5 million to $10 million for defense contracts entered after June 30, 2026.

What is the new CAS threshold and who is affected?

The FY2026 NDAA raised the CAS coverage threshold from $2.5 million to $35 million. Negotiated prime contracts and subcontracts below $35 million entered after the effective date no longer trigger CAS coverage for most contractors.

Do these changes apply to existing contracts?

No — both the TINA and CAS threshold changes apply prospectively to contracts entered after the specified effective dates (July 1, 2026 for TINA). Existing contracts remain subject to the prior thresholds.

References

Gordon Rees Scully Mansukhani. (2026, August). August 2026 Government Contracts Legal Update and Podcast. https://www.grsm.com/insight/august-2026-government-contracts-legal-update-and-podcast/

Government Contracts Law. (2026, January). Swept Away: FY2026 NDAA Updates to CAS and Certified Cost or Pricing Data Thresholds. https://www.governmentcontractslaw.com/2026/01/swept-away-fy26-ndaa-updates-to-cas-and-certified-cost-or-pricing-data-thresholds/