Cost Accounting Standards (CAS)

The CAS Board, an independent board within OMB's Office of Federal Procurement Policy, writes the standards under exclusive authority at 41 U.S.C. ch. 15. FAR Part 30 handles the contracting side — coverage determinations, Disclosure Statement adequacy, compliance administration. The exemptions at 48 CFR 9903.201-1 do most of the sorting in practice: sealed bids, small businesses, commercial products and services, prices set by law or regulation, and firm-fixed-price awards on adequate price competition without certified cost or pricing data.

Covered contracts carry either modified coverage, meaning four standards (401, 402, 405, 406), or full coverage, meaning all standards plus a Disclosure Statement once a business unit crosses the full-coverage line. The numbers moved in 2026: section 1806 of the FY2026 NDAA lifted the applicability exemption from $2.5 million to $35 million, and the CAS Board's September 1, 2026 final rule raises full coverage and Disclosure Statement filing from $50 million to $100 million, both effective October 1, 2026. The same rule drops the $7.5 million trigger-contract concept.

The exposure sits in administration. A change to a disclosed practice, or a practice found noncompliant, opens a cost-impact process that can end in a price adjustment, and contractors near the lines routinely miss that coverage is measured at the business-unit level, not the company level.