The memorandum the September industrial base memo keeps referring back to directs contracting officer access to actual cost data at prime and supplier level for actions of $10 million or more, regardless of whether certification is required, and ordered delinquent CSDR reports submitted within 30 days. That deadline has passed.

DCMA and DCAA are directed to overhaul how forward pricing rate agreements are built. Estimating system and MMAS reviews are to be folded into commercial-aligned accounting system criteria within 90 days. Earned value management is confined to major development programs. And a DFARS profit policy rulemaking starts within 90 days.

The Deputy Secretary of War's 14 September 2026 memorandum, Fostering One Strong Industrial Base, directs the Department from Cost Accounting Standards to GAAP, sets a 60-day clock for proposals to the Cost Accounting Standards Board, and — effective on signature — bars any solicitation that would newly bring a business unit under full CAS coverage unless the Under Secretary for Acquisition and Sustainment approves the acquisition strategy in writing.

FAR Case 2026-006 would remove the IRS Form 941 payroll reconciliation, the detailed time-and-materials cost element data, and contract fee computations from the Allowable Cost and Payment clause, and narrow subcontract reporting to subcontracts above the certified cost or pricing data threshold.

DFARS Parts 244 and 231 were revised on 29 July and 4 August 2026 to implement FY2026 NDAA section 1826. Cost principles and purchasing system approval no longer apply to nontraditional defense contractors on Department of War contracts.