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 2026-003 would redefine deficiency around material terms, eliminate pre-competitive-range exchanges, loosen the competitive range, and formally recognize award to the highest technically rated proposal at a fair and reasonable price. Subpart 15.4 contract pricing is largely left alone.

A 24 July 2026 Department of War class deviation implements FY2026 NDAA sections 812(c), 1826, and 811(a)(5), converts the TINA Lite pilot into a permanent program, and changes should-cost review requirements.