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When must you submit certified cost or pricing data?

Source last checked: 1 September 2026 · FAR Part 15, FAC 2026-01, effective 13 March 2026

When the data are required

Certified cost or pricing data are required before the following actions, when the action is expected to exceed the threshold at FAR 15.403-4(a)(1) and no exception applies: the award of any negotiated contract, except undefinitized actions such as letter contracts; the award of a subcontract at any tier, if the contractor and each higher-tier subcontractor were themselves required to furnish the data; and the modification of any sealed bid or negotiated contract, whether or not certified cost or pricing data were initially required.

The order of the test matters. A contracting officer does not start from the dollar value. FAR 15.403-4(a)(1) says the officer shall obtain certified cost or pricing data only after concluding that none of the exceptions in FAR 15.403-1(b) applies; and FAR 15.402 puts the whole subpart in a hierarchy, under which the officer obtains certified data when FAR 15.403-4 requires them and otherwise obtains only as much other data as is needed to establish a fair and reasonable price, and “not more data than is necessary”.

The threshold for obtaining certified cost or pricing data is $950,000 for prime contracts awarded before July 1, 2018, and $2.5 million for prime contracts awarded on or after July 1, 2018. When a clause refers to this threshold, and if the threshold is adjusted for inflation pursuant to 1.109(a), then pursuant to 1.109(d) the changed threshold applies throughout the remaining term of the contract, unless there is a subsequent threshold adjustment.

FAR 15.403-4(a)(1)

Two consequences follow from that second sentence and are easy to miss. First, the figure in the regulation is a floor that moves: it is adjusted for inflation under FAR 1.109, so the number printed in a contract clause can differ from the number in force when the clause is read. Second, once a threshold adjustment has been applied to a contract, FAR 1.109(d) freezes the changed threshold for the remaining term of that contract, until the next adjustment. For an existing contract the question is therefore not “what is the threshold today” but “what threshold does this contract carry”: FAR 15.403-4(a)(1) requires the data before any covered action expected to exceed the current threshold or, for existing contracts, the threshold specified in the contract.

Source for this section: FAR Part 15 — Contracting by Negotiation, sections 15.402 and 15.403-4, acquisition.gov/far/part-15.

Who is bound by subpart 15.4, and who is not

Subpart 15.4 binds the pricing of negotiated prime contracts, the subcontracts under them, and contract modifications — and it expressly reaches modifications to contracts that were awarded by sealed bidding. That last point is the one that catches suppliers out: a contract can be awarded under FAR Part 14 with no cost or pricing data anywhere in sight, and a later modification to it can still be a certified cost or pricing data action.

What subpart 15.4 does not reach is just as important, because naming only the rule gives the wrong answer half the time:

• Acquisitions at or below the simplified acquisition threshold. FAR 15.403-1(a) states that certified cost or pricing data shall not be obtained for these at all. This is a prohibition, not a discretion.
• Any action covered by an exception in FAR 15.403-1(b). The contracting officer is barred from requiring certified data, though data other than certified cost or pricing data may still be required.
• Data supplied in support of forward pricing rate agreements and other advance agreements. FAR 15.407-3(c) states that contracting officers shall not require certification at the time of agreement for those. The data are swept into a later certificate when a contract action that needs one is priced using the agreement, but they are not certified when the rate agreement itself is struck.
• Allowability of the costs that are submitted. Whether a cost may be charged at all is a FAR Part 31 question, not a FAR Part 15 one.

The threshold also has a second, upward exception in the opposite direction. Under FAR 15.403-4(a)(2) the head of the contracting activity, without power of delegation, may authorise the contracting officer to obtain certified cost or pricing data below the threshold, provided the action exceeds the simplified acquisition threshold, and must justify that in writing with a finding that the data are necessary to determine whether the price is fair and reasonable.

Source for this section: FAR Part 15, sections 15.401, 15.403-1, 15.403-4 and 15.407-3, acquisition.gov/far/part-15.

The exceptions that bar the requirement

FAR 15.403-1(b) lists the cases in which the contracting officer shall not require certified cost or pricing data to support any action — contract, subcontract or modification:

1. Prices agreed upon are based on adequate price competition.
2. Prices agreed upon are based on prices set by law or regulation.
3. A commercial product or commercial service is being acquired.
4. A waiver has been granted.
5. A contract or subcontract for commercial products or commercial services is being modified.

Most of them have a written standard attached in FAR 15.403-1(c), and the standards are where most arguments are won or lost. Prices set by law or regulation are established by periodic rulings, reviews or similar actions of a governmental body, or by the laws themselves. A commercial determination that fails — the officer decides the product or service claimed to be commercial is not commercial, and no other exception or waiver applies — puts the action straight back under FAR 15.403-4(a)(1).

Waivers are narrower than they sound. Under FAR 15.403-1(c)(4) only the head of the contracting activity may grant one, without power of delegation, in exceptional cases, in writing, with the supporting rationale recorded. And a waiver does not clear the supply chain: the contractor to whom the waiver relates is treated as having been required to provide the data, so a lower-tier subcontract expected to exceed the threshold still needs certified data unless an exception applies to that subcontract or the waiver specifically includes it.

Source for this section: FAR Part 15, section 15.403-1, acquisition.gov/far/part-15.

What counts as adequate price competition

Under FAR 15.403-1(c)(1)(i) a price is based on adequate price competition when all of the following hold: two or more responsible offerors, competing independently, submit priced offers that satisfy the Government's expressed requirement; award will be made to the offeror whose proposal represents the best value, with price a substantial factor in source selection; and there is no finding that the price of the otherwise successful offeror is unreasonable. A finding of unreasonableness must be supported by a statement of the facts and approved above the contracting officer.

A single offer can also qualify — but not everywhere. FAR 15.403-1(c)(1)(ii) opens that route to agencies other than DoD, NASA and the Coast Guard. There, one offer can still count as adequate price competition where there was a reasonable expectation, based on market research or other assessment, that two or more responsible offerors would compete; the offeror appears to have bid expecting competition; and the determination is approved above the contracting officer. The same subsection offers a second route for those agencies: price analysis clearly demonstrating the proposed price is reasonable against current or recent prices for the same or similar items under contracts that resulted from adequate price competition, adjusted for changes in market, economic, quantity and contractual conditions.

If you are bidding to DoD, NASA or the Coast Guard, do not plan around the single-offer route. It is not available to you, and a sole response to a competitive solicitation can leave you inside FAR 15.403-4 after all.

Where competition does establish the price, FAR 15.403-3(b) says that generally no additional data are necessary; if the officer concludes additional data are needed in unusual circumstances, the officer must to the maximum extent practicable obtain them from sources other than the offeror.

Source for this section: FAR Part 15, sections 15.403-1 and 15.403-3, acquisition.gov/far/part-15.

What you actually submit, and what you sign

FAR 15.403-4(b) names what is submitted. The certified cost or pricing data themselves, together with any data other than certified cost or pricing data the contracting officer needs to determine that the price is fair and reasonable; and a Certificate of Current Cost or Pricing Data in the format specified at FAR 15.406-2, certifying that the data were accurate, complete and current as of the date of agreement on price, or an earlier agreed date as close as practicable to it.

This is to certify that, to the best of my knowledge and belief, the cost or pricing data (as defined in section 2.101 of the Federal Acquisition Regulation (FAR) and required under FAR subsection 15.403-4) submitted, either actually or by specific identification in writing, to the Contracting Officer or to the Contracting Officer's representative in support of ________ are accurate, complete, and current as of ________.

FAR 15.406-2(a), Certificate of Current Cost or Pricing Data

Read the certificate for what it is not. FAR 15.406-2(b) states that it does not constitute a representation as to the accuracy of the contractor's judgment on the estimate of future costs or projections; it applies to the data on which that judgment or estimate was based. The distinction between fact and judgment is the whole of the obligation. The same paragraph closes the obvious escape route: if the contractor had information reasonably available at the time of agreement showing the negotiated price was not based on accurate, complete and current data, its responsibility is not limited by any lack of personal knowledge on the part of its negotiators. FAR 15.406-2(c) adds that data within the contractor's or a subcontractor's organisation on matters significant to contractor management and to the Government will be treated as reasonably available.

You should know before you bid whether the certificate is coming. Under FAR 15.408(l) the contracting officer inserts the provision at FAR 52.215-20 in the solicitation whenever it is reasonably certain that certified cost or pricing data or data other than certified cost or pricing data will be required — and that provision is also where the instructions for requesting an exception live. If an exception is later found to apply after you have submitted, FAR 15.403-4(c) and FAR 15.406-2(e) both say the data must not be treated as certified and must not be certified.

Source for this section: FAR Part 15, sections 15.403-4, 15.406-2 and 15.408, acquisition.gov/far/part-15.

A worked example: the modification that is bigger than it looks

For modifications the test is not the net change in price. It is the size of the pricing adjustment, and increases and decreases are added, not offset. The regulation gives its own arithmetic:

Price adjustment amounts must consider both increases and decreases (e.g., a $500,000 modification resulting from a reduction of $1,500,000 and an increase of $1,000,000 is a $2,500,000 pricing adjustment exceeding the $2,000,000 threshold).

FAR 15.403-4(a)(1)(iii)

Work it through on a live job. You hold a negotiated contract to deliver a monitoring platform. A change order removes a reporting module priced at $1,500,000 and adds a data-ingest component priced at $1,000,000. The invoice change is a reduction of $500,000, and the instinct is to treat the modification as a half-million-dollar action well under any threshold. Under FAR 15.403-4(a)(1)(iii) the pricing adjustment is $2,500,000, and the modification is a certified cost or pricing data action unless an exception applies — which means a Certificate signed over both the deletion and the addition, not just over the part that went up.

Note also that the example printed in the codified text measures its $2,500,000 adjustment against a $2,000,000 threshold, while the threshold sentence in the same subsection reads $2.5 million. The two figures sit in the same subsection. That is a reason to work from the threshold your contract actually carries and from the current adjusted figure, rather than from the illustration.

Three further points from the same subsection. Unrelated, separately priced changes that would not themselves require certified data do not get pulled in merely because they were bundled into one modification for administrative convenience. Negotiated final pricing actions — termination settlements, total final price agreements for fixed-price incentive and redeterminable contracts — are modifications for this purpose, and require certified data where the total final price agreement exceeds the threshold, or where a partial termination settlement plus the estimate to complete the continued portion exceeds it. And for a prime contract entered into before July 1, 2018, FAR 15.403-4(a)(3) lets the contractor ask for the contract to be modified, without consideration, to carry the $2.5 million subcontract threshold for subcontracts entered on or after that date.

Source for this section: FAR Part 15, section 15.403-4, acquisition.gov/far/part-15.

Subcontracts: when the duty flows down

If you are required to submit certified cost or pricing data, you also become a gatekeeper. FAR 15.404-3(c) requires any contractor or subcontractor under that duty to obtain and analyse certified cost or pricing data before awarding any subcontract, purchase order or modification expected to exceed the certified cost or pricing data threshold, unless an exception in FAR 15.403-1(b) applies to that action.

Some of those subcontractor data then go to the Government. FAR 15.404-3(c)(1) requires submission of subcontractor data for, among others, subcontracts that are both more than the pertinent certified cost or pricing data threshold and more than 10 percent of the prime contractor's proposed price, unless the contracting officer believes such submission is unnecessary. Under FAR 15.404-3(c)(2) the officer may also ask for subcontractor data below those thresholds, and for data other than certified cost or pricing data, where that is needed to price the prime contract properly.

Source for this section: FAR Part 15, section 15.404-3, acquisition.gov/far/part-15.

What happens if the data turn out to be wrong

Before agreement on price, correction. FAR 15.407-1(a) requires the contracting officer who learns that submitted certified cost or pricing data are inaccurate, incomplete or noncurrent to raise it with the prospective contractor immediately — whether the defect pushes the price up or down — and to reflect the adjustment or the corrected data in the price negotiation memorandum.

After award, money. Under FAR 15.407-1(b)(1), if the data are found to be inaccurate, incomplete or noncurrent as of the date on the Certificate, the Government is entitled to a price adjustment, including profit or fee, of any significant amount by which the price was increased because of the defective data. That entitlement is carried by the clauses at FAR 52.215-10 and FAR 52.215-11, prescribed by FAR 15.408(b) and (c), and it covers defects in data submitted by the contractor, a prospective subcontractor or an actual subcontractor. FAR 15.407-1(b)(2) requires the officer, in sizing the adjustment, to consider when the data became reasonably available to the contractor and how far the Government relied on the defective data.

The practical reading: the Certificate is the hook, and the date on it is the measuring point. That is the single strongest argument for agreeing cutoff dates in advance, which FAR 15.406-2(c) encourages, and for updating data to the latest available closing date before price agreement.

Source for this section: FAR Part 15, sections 15.406-2, 15.407-1 and 15.408, acquisition.gov/far/part-15.

Certified data compared with data other than certified cost or pricing data

The two regimes are often spoken of as more and less paperwork. They are different obligations with different consequences, and the table is the fastest way to see where they part company.

One asymmetry is worth stating plainly, because it changes how you answer a data request. An exception from certified data is not an exemption from data. FAR 15.403-1(b) lets the officer require data other than certified cost or pricing data in every one of the exception cases, and FAR 15.403-3(c) limits commercial sales-data requests to the same or similar items over a relevant period, and to the form in which the offeror regularly keeps them as part of its commercial operations.

Source for this section: FAR Part 15, sections 15.402, 15.403-1, 15.403-3, 15.403-4, 15.406-2, 15.407-1 and 15.408, acquisition.gov/far/part-15.

What this guide does not cover

• The dollar value of the simplified acquisition threshold. FAR 15.403-1(a) and FAR 15.403-4(a)(2) both turn on it, but neither states it; the figure lives outside FAR Part 15 and is not quoted here.
• Sealed bidding itself. FAR Part 14 is a different part. Subpart 15.4 reaches modifications to sealed-bid contracts, not their award.
• Agency supplements and deviations. DFARS and other agency supplements, and class deviations issued under the current FAR rewrite, can change the answer for a specific buying office.
• Cost allowability and cost accounting standards. Whether a submitted cost may be charged is a FAR Part 31 question.
• The statutes behind the rule. FAR Part 15 cites 10 U.S.C. chapter 271 and 41 U.S.C. chapter 35; this page quotes the FAR text, not the statutes.
• How the officer analyses what you submit. Proposal analysis techniques at FAR 15.404-1, field pricing support at FAR 15.404-2 and should-cost reviews at FAR 15.407-4 are outside the scope of this page.

Frequently asked questions

What is the dollar threshold for certified cost or pricing data?

FAR 15.403-4(a)(1) states $950,000 for prime contracts awarded before July 1, 2018 and $2.5 million for prime contracts awarded on or after July 1, 2018, and adds that the threshold is adjusted for inflation under FAR 1.109. Once an adjustment applies to a contract, FAR 1.109(d) holds that changed threshold for the remaining term of the contract until the next adjustment, so an existing contract can carry a different figure from a new one.

Do I need certified cost or pricing data if my price is competitive?

No, if the price is based on adequate price competition as FAR 15.403-1(c)(1) defines it. That needs two or more responsible offerors competing independently with priced offers, award on best value with price a substantial factor, and no finding that the winning price is unreasonable. Agencies other than DoD, NASA and the Coast Guard can also reach that conclusion on a single offer under FAR 15.403-1(c)(1)(ii); for DoD, NASA and the Coast Guard that route is not available.

Who signs the Certificate of Current Cost or Pricing Data?

The contractor executes it, and FAR 15.406-2(a) requires the contracting officer to include the executed certificate in the contract file. It certifies the data as accurate, complete and current as of the date of agreement on price, or an earlier agreed date as close as practicable to it, and FAR 15.406-2(b) makes clear it covers the data behind an estimate rather than the judgment in the estimate itself.

Does the commercial item exception cover modifications?

Modifying a contract or subcontract for commercial products or commercial services is itself one of the exceptions in FAR 15.403-1(b). But minor modifications of a commercial product are treated differently by funding agency under FAR 15.403-1(c)(3)(iii): outside DoD, NASA and the Coast Guard they are exempt, while for those three they are exempt only while the total price of all such modifications under the contract action stays within the greater of the FAR 15.403-4 threshold or 5 percent of the total contract price at award.

Do subcontractors have to submit certified cost or pricing data?

Yes, where the prime and each higher-tier subcontractor were themselves required to furnish the data and the subcontract is expected to exceed the threshold, under FAR 15.403-4(a)(1)(ii). FAR 15.404-3(c) also makes the contractor obtain and analyse the subcontractor data before award, and a waiver granted to a prime does not clear a lower-tier subcontract unless the waiver specifically includes it.

What happens if my certified cost or pricing data were wrong?

Before price agreement, FAR 15.407-1(a) has the contracting officer raise it with you at once and reflect the correction in the price negotiation memorandum. After award, FAR 15.407-1(b)(1) entitles the Government to a price adjustment including profit or fee for any significant amount by which the price was increased by the defective data, enforced through the clauses at FAR 52.215-10 and FAR 52.215-11.

Related guides

• When can a US agency use simplified acquisition instead of full competition?
• FAR Part 31 (Cost Principles): what it covers and who it binds
• Which costs are unallowable under FAR Part 31?
• What can you ask for in a federal debriefing, and when?

Source: FAR Part 15 — Contracting by Negotiation, FAC 2026-01, effective 13 March 2026, as published at acquisition.gov/far/part-15. Every section cited on this page is taken from that text; the corpus copy used here was fetched on 1 September 2026. This guide describes FAR Part 15 as codified today. On 18 September 2026 the FAR Council published a proposed rule rewriting Parts 8, 12, 13, 15, 38, 44 and 51 under Executive Order 14275 (91 FR 59406, FAR Case 2026-003). It is a proposal, not the text in force. Agencies may also be operating under class deviations that differ from the codified text quoted here.

Written by Robert Grabarević, founder of Scalebiz. He built the radar as a tool for himself, so that he would not have to re-read the same funding rules for every application. Every guide on this site cites the regulation by section or page, so each claim can be checked against the source. About Scalebiz · Robert on LinkedIn.