As many of you may already know, there are a few threshold changes in the FY2026 National Defense Authorization Act (NDAA) that will affect your procurement documentation requirements and related SpendLogic setup. Thresholds decide which files a reviewer will ask to see, as explained in our Guide to CPSR.
The FY2026 NDAA was enacted as Public Law 119-60 on December 18, 2025. Because the NDAA is now law, the Certified Cost or Pricing Data (CCoPD) threshold change must be followed for covered DoD procurements based on the applicable effective date. The Cost Accounting Standards (CAS) changes are still pending additional regulatory action.
The most significant changes relate to Certified Cost or Pricing Data (CCoPD) and Cost Accounting Standards (CAS).
1. Certified Cost or Pricing Data (CCoPD) Increasing to $10M
For covered DoD procurements, the threshold for requiring CCoPD is increasing from $2.5 million to $10 million. DoD Class Deviation 2026-O0048 implements this statutory change.
Applies to: Covered DoD Prime contracts awarded after June 30, 2026.
As of now, sub-awards, including purchase orders (POs), subcontracts, modifications, and change orders made against prime contracts awarded on or before June 30, 2026, should continue to apply the current $2.5M threshold.
For DoD prime contracts awarded after June 30, 2026, the new $10M threshold will apply. We will continue to monitor for any additional guidance that may expand or further clarify how this threshold should be applied.
2. Cost Accounting Standards (CAS) - A Pending Update
The CAS threshold is expected to increase to $35 million. The full CAS coverage and Disclosure Statement thresholds are expected to increase from $50 million to $100 million.
Applies to: TBD – Requires additional regulatory action.
Unlike the CCoPD change, CAS changes will only take place once regulatory updates have been made by the CAS Board. The public comment deadline on this change closed April 20, 2026, and a final rule has yet to be issued.
Next Steps
SpendLogic Actions
SpendLogic is preparing system updates to support the CCoPD threshold change. These updates are scheduled to take effect for covered DoD procurements tied to prime contracts awarded after June 30, 2026.
Planned updates include:
- Updating threshold references in documentation folders and price analysis screens
- Updating date-based applicability triggers for orders, changes, and modifications
- Reviewing Prime Contract Date data and DoD / Non-DoD identifiers where needed
SpendLogic will reach out to clients with incomplete Prime Contract Date data or incomplete DoD / Non-DoD system identifiers before implementation.Clients not using the Documentation Folder module will be responsible for updating their own documentation workflows and related internal references.
Client Actions
Clients should take the following actions:
- Revise policies and procedures with new CCoPD threshold and the pending CAS threshold changes, as needed.
- Replace specific dollar values with references to “current applicable thresholds” where appropriate.
- Review flowdowns to confirm they align with the new thresholds and effective dates.
- Inform buying teams of the new thresholds, including when and how they apply.
- Facilitate and participate in upcoming SpendLogic Zoom sessions, as needed, so that these changes can be implemented smoothly.
Where SpendLogic Fits In
If you have any questions, please reach out to us at help@spendlogic.com.
If you are interested in seeing how SpendLogic can help remove uncertainties like this for your company, schedule a quick fifteen-minute demo. We would be happy to show you how it works.
Stay tuned for our next article in the “How to Be an Audit-Ready Buyer” series – Part 4: Sole Source Justifications That Hold Up Under Review.