The National Defense Authorization Act for Fiscal Year 2026 (2026 NDAA) isn’t just another annual budget bill. For government contractors, especially small and mid-sized firms, it represents a significant shift in acquisition policy that reduces longstanding compliance hurdles and opens up the defense marketplace in meaningful ways. Among the most consequential changes are increases to the certified cost or pricing data threshold and Cost Accounting Standards (CAS) coverage requirements. These reforms are already signed into law and take effect for relevant contracts after June 30, 2026, giving contractors time to integrate them into proposal strategies for summer and later awards.
This article breaks down what these thresholds mean, why they matter, and how small and mid-sized businesses can leverage the changes to improve competitive positioning.
Understanding the Basics: Certified Cost or Pricing Data and CAS
Before diving into what’s new, it’s essential to understand the underlying compliance regimes:
Certified Cost or Pricing Data (TINA/CCPD): Under the Truth in Negotiations Act (TINA), contractors historically had to submit certified cost or pricing data to the government on negotiated procurements above a statutory dollar threshold unless an exception applied. This certified data is a sworn statement that the costs and pricing information submitted to the government is accurate, complete, and current at the time of agreement.
Cost Accounting Standards (CAS): Managed by the CAS Board and codified at 48 CFR 9903, CAS governs how contractors allocate costs for government contracts. When CAS applies, contractors must follow detailed accounting standards designed to ensure consistency, transparency, and allocability of costs. Non-compliance can lead to audit risk and costly post-award adjustments.
Both TINA and CAS compliance have traditionally imposed significant administrative and financial burdens, particularly on smaller firms without extensive back-office support.
What’s Changing in the 2026 NDAA?
1. Certified Cost or Pricing Data Threshold Rises to $10 Million
One of the most important thresholds in federal contracting is the one that triggers certified cost or pricing data. Previously set at $2.5 million for most negotiated procurements, that threshold now increases to $10 million under the 2026 NDAA.
Certified cost or pricing data will no longer be required on negotiated contracts under $10 million.
This change applies to contracts awarded on or after June 30, 2026.
Why this matters: For decades, the burden and risk of submitting certified cost or pricing data deterred many small businesses from pursuing contracts just above the old threshold. Raising the limit to $10 million means that many proposals previously requiring detailed cost justifications can now move forward with lighter pricing documentation. This can result in:
Faster proposal preparation
Reduced compliance risk
Lower proposal development costs
More accessible opportunities in the $2 to $10 million range
For many small and midsize firms, this is the contract value range where growth occurs. Removing the CCPD requirement allows for greater participation and agility in the federal marketplace.
2. CAS Coverage Thresholds Increase
The NDAA also raises the thresholds related to Cost Accounting Standards:
The full CAS coverage threshold increases from $50 million to $100 million in annual contract awards.
The contract-level CAS trigger will also increase, although the exact adjustment is being formalized through regulation.
Why this matters: CAS compliance involves detailed accounting policies, reporting, and audits. The cost of compliance is significant, particularly for businesses that do not have government-specific accounting systems in place. Raising the threshold gives companies more room to grow before being required to implement CAS-compliant systems and practices.
Contractors that previously hesitated to expand due to CAS-triggering contract awards can now pursue larger opportunities without immediately taking on that burden.
What These Changes Mean for Small and Mid-Sized Contractors
These NDAA reforms are not just technical updates—they represent a policy shift that directly supports competition and lowers the barrier to entry.
Lower Compliance Costs
Compliance with CCPD and CAS can be time-consuming and expensive. These changes allow businesses to dedicate more resources to operations, capture efforts, and business development rather than administrative oversight.
Faster Contract Awards
With fewer requirements for certified pricing data and CAS reporting, proposal evaluation and award timelines are likely to shrink. This benefits both contractors and contracting officers by streamlining the procurement process.
Easier Market Entry
Companies with primarily commercial operations can now engage more easily in the federal market. The high cost of compliance has long served as a gatekeeper; these changes reduce that barrier and make initial government contracts more feasible.
More Competitive Playing Field
Large firms with built-in compliance infrastructure have traditionally enjoyed a competitive edge. The threshold increases help level the field by emphasizing price, performance, and value rather than regulatory sophistication.
What Contractors Should Do Now
The law is already in place, and the effective date is clear: June 30, 2026. That gives companies a window to prepare. Here’s how:
1. Update Internal Pricing Templates
If you have proposal templates that reference certified cost or pricing data for projects under $10 million, revise them now. Your teams should understand when those requirements will no longer apply.
2. Reevaluate Growth Strategies
If you previously avoided prime contracts or larger deals to stay below the old CAS threshold, it may be time to revisit that strategy. The higher limits make growth less risky from a compliance standpoint.
3. Adjust Capture Plans
Many firms screen opportunities based on anticipated compliance costs. Now, deals in the $5 to $10 million range that may have been marginal could be viable.
4. Review Accounting Capabilities
If you’ve been preparing to move toward CAS compliance, evaluate whether that investment is still needed based on your current and projected pipeline.
5. Train Internal Teams
Proposal writers, pricing analysts, and executives need to understand the new rules. Training sessions or internal memos explaining the policy shift will help reduce confusion as the effective date nears.
How FedBizAccess Helps You Navigate These Changes
Understanding policy shifts is one thing. Adapting to them and using them to your advantage is another. That’s where FedBizAccess comes in.
Expert Coaching
Our team works with you to interpret legislative changes and adjust your strategy accordingly. Whether you’re new to the government space or already established, we help you prepare smarter bids.
Tools for Cost-Effective Proposals
Our proposal tools and templates are built to match current compliance standards, and we keep them updated. You’ll always have what you need to develop winning proposals quickly—without excess paperwork.
Targeted Opportunity Visibility
FedBizAccess helps you zero in on the right opportunities for your business, especially in the $2–$10 million sweet spot. Our FedBiz365platform lets you search active and forecasted federal and SLED (state, local, and education) opportunities with advanced filters to match your NAICS codes, certifications, and agency targets. You’ll spend less time searching and more time bidding.
Final Thoughts
The 2026 NDAA delivers a meaningful reset for contractors. By raising the thresholds for certified cost or pricing data and CAS coverage, it reduces red tape and unlocks access to a broader range of opportunities.
But as with any shift in federal policy, the advantage goes to those who act. Businesses that proactively adjust their capture strategies, update their pricing practices, and streamline their proposals will be in the best position to win contracts under these new, contractor-friendly conditions.
If you want help aligning your strategy with these updates or identifying which awards now make sense to target, contact FedBizAccess today: 844-628-8914 (or book a call at your convenience). From coaching to contract opportunity alerts, our team is here to help you grow smarter in 2026 and beyond.
Mya was great with communications throughout the project. She has outstanding graphics and document creation ability.
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thanks Cassie for everything !!
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2 weeks ago
While working with FedBiz Access to update our cage code was an extremely easy worry-free process. Elizabeth was great to work with.
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2025/2026 UPDATE: Cassie and her team at FedBizAccess continue to provide us with professional and reliable support for SAM registration and other government contracting needs.
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Original Review: We hired FedBizAccess several years ago to help us manage our federal contractor profile through the SAM database. Throughout the years they have been quick to respond to our requests. The past few years more of our focus has been outside the federal contracting arena and we hadn’t required their help. This year, though, we hit a snag renewing our SAM profile since we had a slight change in our company name. We reached out to FBA for help, and Cassie Elbanay responded immediately. She has been critical in helping us navigate the process. She is very knowledgeable, personable, and an overall professional. We are confident work will be done correctly and successfully when Cassie and her team are on the case. It has been a pleasure working with her, and I look forward to continuing our firm’s partnership with her and her team at FBA.
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3 weeks ago
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4 weeks ago
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4 weeks ago
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4 weeks ago
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1 month ago
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2 months ago
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3 months ago
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3 months ago
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3 months ago
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Rifles Only
3 months ago
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4 months ago
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4 months ago
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4 months ago
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4 months ago
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4 months ago
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4 months ago
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4 months ago
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4 months ago
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4 months ago
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4 months ago
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4 months ago
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4 months ago
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4 months ago
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4 months ago
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4 months ago
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5 months ago
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5 months ago
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5 months ago
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5 months ago
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5 months ago
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5 months ago
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5 months ago
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Elias Caro
5 months ago
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P.J. Hughes
5 months ago
Cassie Elbanay is a wonderful professional to deal with. She is very proactive in her approach, has an incredible attitude, and communicates very well. I highly recommend her. A GREAT Value. I just recently tasked her with 2 issues and she handled them with incredible precision and in a very timely manner. Her communication skills are top shelf and very timely.
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Tara Ash
5 months ago
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5 months ago
I’ve had the pleasure of working with Cassie for the past two renewals. Cassie’s kindness, patience, and communication truly stand out. She makes the renewal process effortless and pleasant every time.
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Jay Reyes Feliciano
5 months ago
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JUAN MENENDEZ
5 months ago
FedBiz is a great partner on guiding us on how to start a bidding process. Cassie is great! Very knowledgeable and extremely responsive.
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Juan Peralta
6 months ago
FedBiz was able to get me on track with advertising to my Government Purchasers, thank you Cassie Elbanay.
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Aaron Dirks
6 months ago
I have contracted with FedBiz to help me get started with the SAM account. I had already filled out most of the information and they helped by checking it and making sure we had the correct services listed. Mya then worked with me to put together the Capability Statement and a video. She did a very nice job and was great to work with. I got prompt, friendly and accurate service.
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Andrea Humphreys
6 months ago
Ashley Futral is always very helpful and knowledgeable regarding our applications and always on top of deadlines.
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https://i0.wp.com/fedbizaccess.com/wp-content/uploads/2026/02/Changing2026NDAA.jpg?fit=1344%2C896&ssl=18961344fedbizadminhttps://fedbizaccess.com/wp-content/uploads/2023/04/fedbizaccess-website-logo.pngfedbizadmin2026-02-04 19:25:512026-02-04 19:25:53How the 2026 NDAA Transforms Pricing and Accounting Requirements for Government Contractors
