CASB Final Rule: Monetary Thresholds, Indefinite Delivery Contracts, and — At Long Last — Treatment for Hybrid Contracts

On September 1, 2026, the Cost Accounting Standards Board (CASB) issued a final rule, effective October 1, 2026, revising when and how Cost Accounting Standards apply to federal contracts. The rule raises CAS coverage thresholds, changes the treatment of indefinite delivery contracts, expands agency waiver authority, and permits CAS exemptions for portions of hybrid contracts. While the changes may reduce compliance burdens for many contractors, questions remain regarding their application to contracts awarded over the past nine months. The final rule has significant implications for contractors’ CAS compliance obligations and contracting strategies going forward.

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CAS, CASB, government contracts, Hybrid Contracts

About Phillip Seckman

Phillip Seckman represents clients concerning government and commercial contract matters. His practice spans a broad range of subjects related to federal procurement law, state and local procurement law, and complex federal regulatory issues. He concentrates his practice in the areas of commercial item acquisitions, GSA schedule contracting, cybersecurity, compliance, internal investigations, and bid protests (both federal and state). A significant component of his practice involves government contract cost allowability, proper cost accounting, and contract cost and pricing issues.

About Evan Sherwood

Evan Sherwood is a partner in the Dentons Government Contracts-US practice, counseling federal contractors on Contract Disputes Act (CDA) claims, the cost accounting standards (CAS), cost allowability, requests for equitable adjustment (REAs), commercial products/services contracting, contract terminations for convenience / default, and related audits, litigations, and investigations.