New decisions, rules and guidance a contracting officer should know about, with the line that actually matters. This issue is as it was published on 5 October 2026; later issues carry what has moved since.
1 Oct 2026ThresholdsThe Cost Accounting Standards Board's final rule (91 FR 56056, published 1 September 2026) took effect on 1 October 2026 and is in the eCFR text now. The exemption at 48 CFR 9903.201-1(b)(2) no longer tracks the certified-data threshold but reads “Negotiated contracts and subcontracts not in excess of $35 million”; the old (b)(7) exemption — contracts under $7.5 million where the business unit was performing no CAS-covered contract of $7.5 million or more — is deleted, full coverage under 9903.201-2(a) and the Disclosure Statement trigger in 9903.202-1(b) were raised from $50 million to $100 million, and agency-head waiver authority for a business unit primarily engaged in commercial sales went from contracts under $15 million to contracts under $100 million. A new 9903.201-1(c) settles indefinite delivery contracts: on a multiple-award IDC the exemptions are determined at each task or delivery order against that order's ceiling value, and on a single-award IDC once, at award, against the contract's ceiling value.
Two of these land on a file this week. First, the clause decision: FAR 30.201-4(b)(1) still prescribes 52.230-3 for a contract “over $2.5 million but less than $50 million” and was last touched in August 2025, so the FAR's own prescription band no longer matches the coverage rules it points to — read 9903.201-2 for coverage and treat the FAR band as the text that lags. Second, the IDC rule is the one to settle before your next order: on a multiple-award vehicle CAS is tested order by order against the order ceiling, so an order under $35 million to a business unit doing large CAS-covered work elsewhere is exempt where the deleted $7.5 million trigger would once have pulled it in. A contractor carrying full coverage only because of the old figure can also ask to move to modified coverage at the start of its next cost accounting period beginning on or after 1 October, under 9903.201-2(b)(4), if it has no unresolved noncompliances — expect the request and know it is in the rule.
eCFR, 48 CFR 9903.201-1 (91 FR 56056) →
2 Oct 2026GAO timelinessGAO dismissed Mission Analytics, LLC's protest of a Defense Information Systems Agency procurement under RFP HC101925R007, for video walls, video processors and related IT products at the Defense Network Center Pacific on Ford Island, Hawaii. Mission Analytics had filed an agency-level protest challenging the solicitation's treatment of the non-manufacturer rule and the DFARS Buy American and Balance of Payments requirements on 29 May 2026, the day proposals were due; the agency received proposals that day, dismissed the agency-level protest on 23 June, debriefed on 1 July, and Mission Analytics filed at GAO on 6 July. GAO held that receipt of proposals was the initial adverse agency action for purposes of 4 C.F.R. § 21.2(a)(3), because proceeding to receive proposals put the protester on notice that the agency would not take the corrective action it had asked for, so the ten-day period closed on 8 June and the June dismissal did not restart it. Decided 30 September 2026; posted by GAO 2 October 2026.
This decides what your file has to record, and it cuts both ways. When a firm protests a solicitation term to you and you then receive proposals on schedule, the date of receipt is the date that decides timeliness at GAO — so log it alongside the agency-level protest, because it is the fact a later GAO filing will be measured against, not the date of your written response. The other half is the harder one: letting the closing date pass without taking corrective action is itself the answer, so if you are still weighing corrective action on a solicitation-term protest, decide it before proposals come in rather than after, and do not leave a protester with the impression that its clock is waiting on your formal decision.
GAO, B-424631 →
5 Oct 2026RulesGSA published a proposed rule today (GSAR Case 2026-G502, 91 FR 63243) amending GSAR part 541 and part 552, the procedures and guidance for acquiring utility services, to align the supplement with the FAR Council's proposed rewrite of FAR part 41. That part 41 proposal is RFO FAR Case 2026-002, published 23 June 2026, whose comment period closed on 23 July, so the supplement is being conformed to a FAR text that is itself not final. GSA states that its guidance does not reach agencies acting under the special authorities at FAR 41.103(a)(2) and (3) — DoD under 10 U.S.C. 3201(a) and 40 U.S.C. 474(d)(3), and DOE under its organization act and the Atomic Energy Act. Comments close 4 November 2026.
Nothing about the utility contract in front of you moves: FAR part 41 and the GSAM you have still govern, and both of these are proposals. What is worth a look before 4 November is the authority line in the file. Unless you are DoD or DOE under those statutes, or VA for connection charges only, a utility service contract running more than one year still needs a delegation of contracting authority from GSA under FAR 41.103(b), and the request still carries your senior procurement executive's certification under FAR 41.103(c) — and that is precisely the procedure being moved out of the FAR, where an ordering agency outside GSA would read it in chapter 5 of title 48 instead. If you keep part 41 templates that cite FAR subsections, they belong on the same recheck list as your part 8 templates.
GSAR Case 2026-G502, proposed rule, 5 October 2026 →
Every item links its primary source. Figures and paragraph numbers are as of the issue date; check the current text before one goes in a file. Found an error? Tell us.