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Desk reference · not legal adviceEvery threshold/Bonds, reporting, responsibility, CAS and other transactions/Checked 2 Nov 2026
CAS applicability — negotiated contract exemption
$35,000,000was $2,500,000 until 1 Oct 2026
- Citation
- 48 CFR 9903.201-1(b)(2)
- Last moved
- 1 October 2026, from $2,500,000
- Checked
- 2 November 2026, against the codified FAR and, where it leads the FAR, the statute
- Note
- The exemption now covers negotiated contracts and subcontracts “not in excess of $35 million”. Before 1 October 2026 the paragraph tracked the certified-data threshold, and a separate exemption at 9903.201-1(b)(7) covered contracts under $7.5 million unless the business unit was already performing a CAS-covered contract of $7.5 million or more; that trigger test is deleted. An order from one segment to another counts as a subcontract. For indefinite delivery contracts, 9903.201-1(c) tests the exemptions at each order against the order ceiling on a multiple-award IDC, and once at award against the contract ceiling on a single-award IDC. This is exemption, not coverage — for full against modified coverage see T-038.
A negotiated contract for other than commercial products or services, with a business unit that is not a small business. At or below what amount is it exempt from CAS on dollar value alone?
$35,000,000 (48 CFR 9903.201-1(b)(2)), as of 2 November 2026. It was $2,500,000 until it moved on 1 October 2026.
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Before you rely on it: this is the codified amount in effect on 2 November 2026. Agencies on a Revolutionary FAR Overhaul class deviation use the same value under a different paragraph number, and your agency supplement can set a lower one. Check it against the current text before it goes in the file.
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Play today’s ThresholdBonds, reporting, responsibility, CAS and other transactions
6 more- First-tier subcontract reporting$40,000
- Prototype OT — head of contracting activity approval$100,000,000
- Prototype OT — senior procurement executive and congressional notice$500,000,000
- Miller Act performance and payment bonds$150,000
- CAS full coverage threshold$100,000,000
- Subcontracts with excluded parties — compelling reason threshold$45,000