A non-traditional defense contractor is an entity that is not currently performing and has not performed, for at least the one-year period preceding the solicitation of sources by DoD for the procurement or transaction, any contract or subcontract for the DoD that is subject to full coverage under the cost accounting standards prescribed pursuant to section 1502 of title 41 and the regulations implementing such section (see 10 U.S.C. 2302(9)). 

Most entities will find they qualify as non-traditional defense contractors, because: 

  • They are a small business exempt from CAS requirements
  • They exclusively perform contracts under commercial procedures
  • They perform exclusively under FFP contracts with adequate price competition
  • They perform less than $50M in CAS covered efforts during the preceding cost accounting period