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.

FAR Case 2026-011 would remove contractor team arrangements from the FAR entirely and, implementing section 812(a)(6) of the FY2026 NDAA, excuse the Department of War from paying for a small business to undergo qualification testing where fewer than two manufacturers could compete. Civilian agencies keep that obligation.

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.

Class Deviation 2026-O0037, Revision 1, issued 24 July 2026, absorbs the standalone SDVOSB class deviation, points eligibility verification at SBA's certification search, and corrects the sole-source 8(a) threshold to $100 million.