Fifty-three days. That's how long government contractors have before the Revolutionary FAR Overhaul (RFO) — the most sweeping rewrite of federal acquisition regulations in more than four decades — reshapes the cost and pricing compliance landscape under Executive Order 14275. The key changes take effect June 30, 2026, and they are not minor adjustments. They fundamentally alter who must comply with the most expensive, time-consuming requirements in federal contracting.
What changes on June 30
| Requirement | Current Threshold | New Threshold (June 30) | Change |
|---|---|---|---|
| Certified cost/pricing data (TINA) | $2 million | $10 million | +400% |
| Full CAS coverage (cumulative awards) | $50 million | $100 million | +100% |
| Full CAS coverage (per-contract trigger) | $2.5 million | $35 million | +1,300% |
| Modified CAS coverage trigger | $2 million | $2 million | No change |
These changes are being implemented via agency class deviations while formal rulemaking continues under the Administrative Procedure Act. That means they have the force of contract law even before a final rule is published.
Who gets freed from TINA
The Truth in Negotiations Act (TINA) requires contractors to certify the accuracy, completeness, and currency of cost or pricing data for contracts above the threshold. The compliance burden is enormous: generating cost or pricing data packages, internal audits, and DCAA reviews that can cost small-to-mid-size firms hundreds of thousands of dollars per proposal. At $2M, virtually any meaningful cost-type contract triggered the requirement. At $10M, a large share of the contractor base is effectively out of scope.
If your firm is currently on a cost-type contract between $2M and $10M awarded after June 30, the TINA certification requirement applies to that specific contract at time of award — retroactive relief is not automatic. But any new awards or modifications above $2M and below $10M after June 30 will not require certified cost/pricing data submission.
Who gets freed from full CAS coverage
Cost Accounting Standards (CAS) full coverage — which requires disclosure statements, advance agreements, and cost impact proposals — previously triggered when a contractor received $50M or more in CAS-covered awards in the prior year, or when a single contract hit $2.5M or more. The new per-contract trigger of $35M is a stunning change that effectively removes full CAS from nearly the entire mid-market. For context, the average CAS-full compliance program costs a firm $150,000–$500,000 per year in overhead. The firms most affected by the relief are those in the $30M–$100M annual government revenue range.
What hasn't changed
Modified CAS coverage — which applies to most non-commercial contracts over $2M and requires contractors to follow four specific CAS standards — is unchanged. And commercial item exemptions remain in place. The overhaul does not touch small business set-aside thresholds or simplified acquisition procedures.
Implementation risk: the OMB gap
Washington Technology reported in April 2026 that formal rulemaking implementing the overhaul is stalling at OMB's Office of Information and Regulatory Affairs (OIRA). Until a final rule is published in the Federal Register, these changes technically exist only as agency deviations — which can be challenged by contractors or agencies seeking to preserve legacy requirements. Contractors should document the basis for any new compliance positions taken on or after June 30, and watch the Federal Register for the interim final rule expected before summer recess.
Action items before June 30
- Map every active contract that currently requires TINA certification — identify which ones fall between $2M and $10M and assess whether any modifications are pending
- Firms currently under full CAS coverage who will fall below $100M cumulative this year should consult with their DCAA auditor about disclosure statement withdrawal procedures
- Proposal teams should update pricing templates to reflect the new thresholds effective for any solicitation with an expected award after June 30
- Review any teaming arrangements that triggered CAS on a per-contract basis — the $35M new trigger likely removes the requirement for most team leads below that contract value