Full CAS Coverage Now Starts at $100 Million for Defense-Only Business Units

What changed

On 30 July 2026 the Principal Director, Defense Pricing, Contracting, and Acquisition Policy (DPCAP) issued Class Deviation 2026-O0006, Revision 1, revising DFARS Part 230, Cost Accounting Standards Administration, and PGI 230. It revises and supersedes Class Deviation 2026-O0006, issued 18 December 2025, and implements section 1806 of the National Defense Authorization Act for Fiscal Year 2026 (Pub. L. 119-60). The deviation memo describes section 1806 as changing the applicability of cost accounting standards, increasing the threshold for disclosure of cost accounting practices, and increasing the CAS waiver threshold.

Two provisions carry the dollar changes. New DFARS 230.201-70, Applicability, provides that for contractor business units having only defense contracts and subcontracts, full CAS coverage applies where the unit receives a single CAS-covered contract award of $100 million or more, or received CAS-covered contracts during its preceding cost accounting period with a net value of $100 million or more. Below $100 million on both measures, modified coverage applies. DFARS 230.101(d)(1) directs that, in lieu of the dollar values at 48 CFR 9903.202-1 through 9903.202-7 for disclosure requirements, $50 million be replaced with $100 million wherever it appears, citing section 1806(a)(2).

A discrepancy worth tracking

The FAR Part 30 text published on the Revolutionary FAR Overhaul deviation guide still prescribes the clause at 52.230-3, Disclosure and Consistency of Cost Accounting Practices, for negotiated contracts over $2.5 million but less than $50 million where the offeror certifies eligibility for modified coverage. The DFARS deviation is defense-specific and directs the substitution. On a Department of War acquisition, the DFARS deviation is the governing direction. Anyone relying on the FAR overhaul page alone will read the older figure.

Update, 7 September 2026

The Cost Accounting Standards Board has now made the threshold change government-wide. A final rule published 1 September 2026 (91 FR 56056, RIN 0348-AB85) replaces $50 million with $100 million throughout 48 CFR 9903.201-2, 9903.201-3, 9903.201-4 and 9903.202-1, raises the basic CAS applicability threshold from $2.5 million to $35 million while eliminating the trigger contract concept, and raises agency head waiver authority from $15 million to $100 million. All of it takes effect 1 October 2026. The DFARS deviation described above is therefore no longer the only authority carrying the $100 million figure.

The FAR-level mismatch has moved rather than closed. Rechecked on 7 September 2026, the Revolutionary FAR Overhaul Part 30 text still reads $2.5 million and $50 million. From 1 October that clause prescription will be out of step with Chapter 99 itself, not merely with a defense-specific deviation — and the $2.5 million floor it cites will sit below the new $35 million applicability threshold. Treat the FAR overhaul Part 30 page as stale on these figures until it is conformed.

Why it matters for estimating

Full versus modified coverage decides which standards a business unit must follow and, with that, which practices have to be disclosed and held consistent between estimating, accumulating, and reporting. Modified coverage applies only a subset of the standards (see 48 CFR 9903.201-2). Moving the line to $100 million shifts a band of business units out of full coverage and out of the disclosure statement requirement entirely.

For anyone building or reviewing an estimate, the practical consequence is that the indirect allocation standards that anchor a forward pricing rate structure no longer bind units below the new line. Comparability arguments across business units, and any reliance on a disclosure statement as the record of a unit's practices, need to be rechecked against the unit's coverage status under the revised threshold rather than the status it held before 30 July.

Primary sources

Class Deviation 2026-O0006, Revision 1 (30 July 2026): https://www.acq.osd.mil/dpap/dars/classdev/DFARS_RFO/Part-230/2026-O0006_Rev1_TAB_A_Deviation_Memo_DFARS_230.pdf

CAS Board final rule, Increase of Monetary Thresholds and Other Matters Related to Cost Accounting Standards Program Requirements, 91 FR 56056 (1 September 2026): https://www.federalregister.gov/d/2026-17901

Revolutionary FAR Overhaul, FAR Part 30: https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-30

DPCAP index of DFARS Revolutionary FAR Overhaul class deviations: https://www.acq.osd.mil/dpap/dars/dfars_far_overhaul_class_deviations.html