Quick context for anyone who lives outside the cost-and-pricing weeds: TINA is the Truthful Cost or Pricing Data statute (the old Truth in Negotiations Act). It’s the rule that forces contractors to hand over certified, auditable cost data on negotiated deals above a set dollar line, so the government can confirm your price reflects your actual costs.
Starting with contracts entered into after June 30, that line moves. The TINA threshold jumps from $2.5 million to $10 million, courtesy of Section 1804 of the FY2026 NDAA. And it isn’t just a defense thing. This one applies to civilian awards too. Running alongside it, Section 1806 lifts the CAS triggers as well: full Cost Accounting Standards coverage climbs from $50M to $100M, and the contract-level CAS applicability trigger goes from $2.5M to $35M.
Translation: a huge band of mid-size work just dropped out of the certified-data and CAS regime overnight.
For small and mid-tier firms, this is real relief. The old $2.5M line pushed companies to build government-unique accounting systems and pricing infrastructure long before their scale justified it. Plenty of shops simply avoided bidding just above the threshold to sidestep the burden. Now that ceiling lifts, and the logic is straightforward: lighter documentation, faster awards, more commercial and nontraditional players willing to step in.
Here’s the nuance worth sitting with, though.
The mandate to produce certified cost data is gone. The need for a defensible price is not. On everything in that $2.5M to $10M band, contracting officers will now lean on price analysis, market research, and historical comparisons instead of audited submissions. That holds up fine in competitive procurements. It gets thin in sole-source or limited-competition situations, where there’s no real benchmark to test you against. And don’t assume “no certification required” means “relax your rigor.” If your proposal lands above $10M, scrutiny actually intensifies, and a weak accounting trail can surface as a defective pricing problem or a stalled award. One more thing teams keep missing: the old threshold still governs anything entered into on or before June 30, so award timing matters this week.
So, the debate:
If you bid in that $2.5M to $10M range, do you drop the detailed cost build now that TINA no longer forces it? Or do you keep your numbers audit-ready anyway, because the evaluator across the table still has to trust your price even when the rulebook stops requiring proof?
Relief, or a risk waiting to surface? Tell me where you land.