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The Revolutionary FAR Overhaul: Get Ready for Big Changes to Government Contracting
Hold onto your hats, government contractors – the Federal Acquisition Regulation (FAR) is undergoing a massive transformation. On May 6, 2025, the Federal Acquisition Regulatory Council (FAR Council) released draft revisionsfor a sweeping, phased update known as the Revolutionary FAR Overhaul (RFO). This isn’t just a minor tweak; it’s a fundamental shift aimed at modernizing how the government buys goods and services.
The RFO was born out of President Trump’s Executive Order 14275, which directed a transformational update to the FAR to reduce government inefficiency, increase competition, and protect taxpayer dollars. The initiative is being led by the Office of Federal Procurement Policy (OFPP) in collaboration with key FAR Council members: the Department of Defense (DOD), the National Aeronautics and Space Administration (NASA), and the General Services Administration (GSA). According to OMB Senior Advisor Dr. Kevin Rhodes, the goal aligns with the Administration’s commitment to transparency in deregulation, seeking to reduce bureaucracy, accelerate procurement, reduce costs, and increase competition.
The initial draft revisions focus on FAR Parts 1, 34, and 52. What’s changing in these crucial sections?
- Part 1: Introduces a mandatory four-year sunset clause for all non-statutory FAR provisions. This means any rule not specifically required by law will automatically expire after four years unless the FAR Council actively renews it. The drafts also remove much of the background and context language that traditionally guided users of the FAR.
- Part 34 (Major System Acquisition): This part is being streamlined significantly. Earned Value Management System (EVMS) requirements and Integrated Baseline Review (IBR) language are being curtailed into concise directives, eliminating detailed policy and procedural guidance.
- Part 52 (Solicitation Provisions and Contract Clauses): Updates cross-references and clause triggers to align with the revised Parts 1 and 34. Like Part 1, this section is also seeing a paring back of explanatory context.
The Four-Year Sunset Clause in Part 1 is particularly consequential. While it’s presumably intended to keep the FAR lean and current, this provision could introduce rule instability. Program offices and contractors might find themselves navigating constantly shifting requirements as provisions expire or are renewed.
Replacing some of the removed non-statutory FAR text is a new framework called Strategic Acquisition Guidance (SAG). These are envisioned as plain-language, scenario-specific guides designed to simplify compliance for contractors while giving contracting officers more discretion. The first SAG will focus on Software as a Service (SaaS) acquisitions, reflecting the government’s priority on agile development and faster authorization processes for cloud services.
Perhaps the most controversial aspect of the RFO is its “rolling implementation.” Federal agencies are being directed to begin immediate adoption of the draft text through FAR deviations – even before the formal notice-and-comment rulemaking process is complete. This is a major break from traditional practice and has already begun, with GSA issuing deviations for FAR Parts 1 and 34. This “adopt first, finalize later” approach raises serious questions about government contractor input, regulatory stability, and transparency, with some likening the process to a “runaway train” that risks undermining public participation and making the rulemaking process a mere rubber stamp. Influencing the finalized text could be difficult once operational norms have already shifted.
Despite the concerns about the process, the RFO initiative promises significant benefits:
- Elimination of non-statutory and duplicative regulations, including certain Diversity, Equity, and Inclusion (DEI) clauses, many of which have already been rescinded via class deviations.
- Replacement of burdensome procedural content with SAG, starting with fast-moving areas like cloud software.
- Ultimately, the goal is faster, more competitive procurement.
The draft revisions are currently open for public comment until September 30, 2025, at 12:00 PM EST. This window represents your best chance to provide input and help ensure the final overhaul balances efficiency, transparency, and oversight. You can follow updates on the RFO website, review the drafts, and submit your comments.
The Revolutionary FAR Overhaul is here, bringing substantial changes that government contractors need to understand and prepare for. Stay informed and consider participating in the comment process to have your voice heard.
Tags: FAR, Government Contracts, Revolutionary FAR Overhaul, RFO, Federal Acquisition Regulation, FAR Council, Procurement, Contracting Officers, FAR Deviations, FAR Part 1, FAR Part 34, FAR Part 52, Strategic Acquisition Guidance, SAG, Four-Year Sunset Clause, Public Comment