DoD, GSA, and NASA Adjust Acquisition Thresholds for Inflation

Schwabe, Williamson & Wyatt PC
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Schwabe, Williamson & Wyatt PC

On Wednesday, August 27, 2025, the Department of Defense (“DoD”), General Services Administration, and NASA issued a final rule increasing certain acquisition-related thresholds. Effective October 1, 2025, the increased thresholds reflect adjustments made to account for inflation.

Notably, the justification and approval threshold for 8(a) direct awards by civilian agencies has been increased from $25 million to $30 million. This means that civilian agencies can make directed awards to 8(a) companies of up to $30 million without having to go through the justification and approval process.

The final rule, however, does not increase the justification and approval threshold for 8(a) direct awards by civilian agencies by the DoD. That threshold remains at $100 million.

The other threshold changes are:

    • The micro-purchase threshold (MPT) at FAR 2.101 is increased from $10,000 to $15,000. For contingency operations or to facilitate defense against certain attacks, the thresholds are increasing from $20,000 to $25,000 and from $35,000 to $40,000, respectively.
    • The simplified acquisition threshold (SAT) is increased from $250,000 to $350,000. For contingency operations or to facilitate defense against certain attacks, the thresholds are increasing from $800,000 to $1 million and from $1.5 million to $2 million, respectively. For a humanitarian or peacekeeping operation, the threshold increases from $500,000 to $650,000.
    • The threshold for reporting first-tier subcontract information, including executive compensation, increases from $30,000 to $40,000 (FAR 4.1401).
    • The pre-award and post-award notices (FAR part 5) remain at $25,000.
    • The ceiling for simplified procedures for certain commercial products and commercial services (FAR 13.500(a)) is increased from $7.5 million to $9 million. For acquisitions described at FAR 13.500(c), the $15 million ceiling is not increasing.
    • The cost or pricing data threshold at FAR 15.403-4, for contracts awarded before July 1, 2018, increases from $750,000 to $950,000. For contracts issued on or after July 1, 2018, the threshold increases from $2 million to $2.5 million.
    • The prime contractor subcontracting plan (FAR 19.702) threshold is increasing from $750,000 to $900,000, and the associated threshold for construction is increasing from $1.5 million to $2 million.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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