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GuideCertified cost or pricing data,
and the 2026 threshold change
Formerly known as TINA, this is the requirement to disclose and certify cost or pricing data on higher value negotiated awards. The threshold moved substantially in 2026, and it reaches your subcontracts as well as your prime work.
The Truthful Cost or Pricing Data statute, long known as TINA, requires contractors to submit and certify cost or pricing data on certain negotiated awards above a threshold. For contracts entered into after 30 June 2026 that threshold rose from $2.5 million to $10 million. Certifying data that is not accurate, complete and current creates defective pricing exposure.
The thresholds before and after
Sections 1804 and 1806 of the FY2026 National Defense Authorization Act revised these figures. The change is forward looking and does not alter awards already made.
The thresholds before and after
Sections 1804 and 1806 of the FY2026 National Defense Authorization Act revised these figures. The change is forward looking and does not alter awards already made.
- Certified data threshold now $10 million
- CAS applicability raised to $35 million
- Change applies after 30 June 2026
| Contracts entered into on or before 30 June 2026 | Contracts entered into after 30 June 2026 | |
|---|---|---|
| Certified cost or pricing data threshold | $2.5 million | $10 million |
| Contract level CAS applicability | $2.5 million | $35 million |
| Full CAS coverage | $50 million | $100 million |
| Trigger contract mechanism | $7.5 million | Removed |
It reaches your subcontracts
Teams treat certified cost or pricing data as an accounting obligation attaching to their prime work. It also attaches to what they buy.
It reaches your subcontracts
Teams treat certified cost or pricing data as an accounting obligation attaching to their prime work. It also attaches to what they buy.
- Accurate, complete and current at agreement
- Applies award by award to subcontracts
- Current is the element that fails most often

Treated as accounting
The requirement is owned by finance, applied to prime proposals, and subcontract pricing is assumed to be somebody else's concern.

Shared with purchasing
Where a subcontract crosses the threshold, obtaining and analysing the data is a purchasing responsibility and the evidence belongs in the purchase file.

Data gathered early
Information is accurate when collected but superseded before price agreement, and nobody updates it, which is the most common defective pricing failure.

Updated to agreement
Data is refreshed up to the point of price agreement, because that is the moment the certification speaks to.

Assumed
An exemption is relied on without the basis being recorded, so the file cannot show why data was not obtained.

Documented
Where an exemption applies, the basis is recorded on the award so the absence of certified data is explained rather than unexplained.

Obtained but not examined
Cost data is collected because it was required and filed without evidence that anybody analysed it, which defeats the purpose.

Obtained and analysed
The data is examined, the analysis is recorded, and the file shows how it informed the negotiated price.
Three words that carry the exposure
| Word | What it means in practice |
|---|---|
| Accurate | The data reflects the facts as they are, not as they were estimated or hoped to be |
| Complete | Nothing relevant has been left out, including information that would weaken your position |
| Current | The data is up to date as at the point of price agreement, which is the most commonly failed element because information gathered early is often superseded before agreement |
Thresholds and exemptions in this area changed materially in 2026 and are subject to further rulemaking. Confirm the position for the specific award before relying on a figure.
Four things worth doing
Check the threshold per subcontract
The determination is made award by award, and the applicable figure now depends on when the contract was entered into.
Learn moreRefresh data up to agreement
Current means current at price agreement. Data gathered early and never updated is the most common failure.
Learn moreRecord the exemption basis
Where certified data was not required, the file should say why rather than simply containing nothing.
Learn moreShow the analysis
Data obtained and filed without evidence of analysis satisfies the form of the requirement and none of its purpose.
Learn moreCommon questions about certified cost or pricing data
What is TINA?
What is the current threshold?
Does this apply to subcontracts?
What does defective pricing mean?
Which element fails most often?
Are there exemptions?
Did the CAS thresholds change at the same time?
Other explainers and the pages they connect to

Cost Accounting Standards
What CAS requires and the thresholds that changed alongside this one.
Learn more
Finance leaders
Award against funded amounts, and what has actually been committed.
Learn moreCheck a subcontract against the threshold
Bring a higher value negotiated subcontract. We will look at what the file holds about data, analysis and timing.
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