The deadline is keyed to your fiscal year end — not the federal government's. If your fiscal year ends December 31, your due date is June 30 of the next year. If you operate on a non-calendar fiscal year, count six months forward from your year-end date. The rule is the same; only the dates change.
| Fiscal Year End | ICP Due Date | Notes |
|---|---|---|
| December 31 | June 30 | Calendar fiscal year — the most common for small & mid-size GovCon firms |
| January 31 | July 31 | Retail-aligned fiscal year |
| February 28 / 29 | August 28 / 29 | Leap-year contractors should confirm with their ACO |
| March 31 | September 30 | Common for foreign-affiliated contractors |
| April 30 | October 31 | Rare but valid custom fiscal year |
| May 31 | November 30 | Used by some education-sector contractors |
| June 30 | December 31 | Common for non-profits and academic affiliates |
| July 31 | January 31 | Custom fiscal year |
| August 31 | February 28 / 29 | Custom fiscal year |
| September 30 | March 31 | Federal fiscal year — common for contractors aligned with the U.S. Government FY |
| October 31 | April 30 | Custom fiscal year |
| November 30 | May 31 | Custom fiscal year |
A contractor closes its books on December 31, 2026. The ICP for fiscal year 2026 must be submitted to DCAA and the cognizant ACO by June 30, 2027. If the contractor closes on September 30, 2026 instead, the deadline is March 31, 2027. The submission must be adequate at the time of receipt — a missing schedule or unsigned FAR 52.242-4 certificate restarts the clock.
Contractor closes the books on the fiscal year
Proposal delivered to DCAA & the cognizant ACO
ACO issues final rate agreement letter
Until DCAA settles your rates, every flexibly priced contract for that fiscal year remains open and unbillable for closeout. Submitting an inadequate proposal returns it for correction and effectively resets your spot in the queue.
The request must be submitted to the cognizant ACO before the six-month deadline expires. Late requests effectively become missed-deadline events and are not treated as valid extension requests.
Provide a substantive justification — e.g., delayed prior-year audit results, corporate reorganization, accounting system migration, or material data dependencies that are outside the contractor's control.
Recommend a specific revised submission date and a brief plan describing what will be ready by that date. Extensions are typically measured in weeks or a few months — not years.
Approval must come from the contracting officer in writing, not from DCAA. Save the email or letter granting the extension; without documented approval, the original deadline still controls.
Per DCAA CAM guidance, contracting officers consider extension requests case by case. Routine workload pressure or ordinary year-end accounting work is not a sufficient reason. Build a buffer into your prep calendar so your internal target is well before day 180 — that way the deadline is a backstop, not the date you're racing to hit.
Under FAR 52.216-7(d)(6), the ACO may establish final indirect cost rates unilaterally when the contractor fails to act — almost always in the government's favor, not the contractor's.
The contracting officer may unilaterally reduce provisional billing rates on flexibly priced contracts when an adequate ICP is not received on time — directly cutting cash flow until the situation is corrected.
If the submission fails the DCAA adequacy checklist, DCAA issues an inadequacy letter listing the deficiencies. The contractor must correct and resubmit — pushing audit fieldwork and final rate settlement further out.
Late filings draw closer audit scrutiny. Expressly unallowable costs found in indirect pools can trigger penalties equal to the disallowed amount — doubled for repeat findings — on top of the disallowance itself.
Recurring late submissions create a documented compliance record that follows the contractor across procurements, contract renewals, and past-performance evaluations. The reputational cost outlasts any single fiscal year.
Every flexibly priced contract from that fiscal year stays open until rates are settled. Contractors with multiple late years stack up unclosed contracts, locked-up retainage, and unbillable completion invoices.
Lock the general ledger for the fiscal year. Reconcile payroll to IRS Form 941. Tie out subcontract billings. Adjusting entries should be final by the end of month 1.
Review every indirect pool against FAR 31.205. Remove expressly unallowable costs (entertainment, lobbying, alcohol, interest) before they reach Schedule B or C.
Build pools and bases per FAR 31.203 and your CAS 410 base election. Reconcile to the trial balance.
Generate all 15 ICP schedules. Schedule H (direct costs by contract), Schedule I (cumulative), and Schedule L (payroll reconciliation) usually drive the most rework.
Walk the full DCAA 47-question adequacy checklist against the package. Fix every "no" before DCAA sees it.
Officer signs the FAR 52.242-4 Certificate of Final Indirect Costs (Schedule N). Deliver the package to DCAA and the cognizant ACO with a transmittal letter.
Aim for day 150–165. The buffer absorbs late audit results, last-minute reclassifications, and signature delays without putting the deadline itself at risk.
If anything threatens the deadline — data delays, audit holdovers, system migrations — raise it to the cognizant ACO well before day 180. Extensions are far easier to secure proactively than retroactively.
The ICP due date isn't really one date — it's the end point of a six-month process. Contractors who treat the deadline as a planning horizon rather than a single calendar event submit on time, pass adequacy review on the first try, and close out fiscal years cleanly. Those who treat it as a single deliverable due in month six tend to learn the consequences in section 05 the hard way.
The ICP Dashboard tracks your fiscal year end, builds Schedules A–O from your trial balance, runs the full 47-question adequacy checklist, and surfaces the exact submission date on every project. Browser-based. Works with any ERP.
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