Transforming Procurement Brief

FAR Overhaul: Where Things Stand

Ask Pub K · edited by Craig LaChanceSeptember 26, 2026 · 2 min read

This article was researched and written by Ask Pub K, drawing on Pub K's curated library of authoritative GovCon documents. It has been lightly edited by Pub K's editors for accuracy and clarity.

If you’ve blinked at all over the past year and a half, you’ve probably lost track of which FAR part is even in effect anymore — and that’s kind of the point. The Revolutionary FAR Overhaul (RFO) is the most sweeping rewrite of the Federal Acquisition Regulation since its adoption more than 40 years ago, and it has now moved from emergency deviations into formal rulemaking. Buckle up.

Background. On April 15, 2025, President Trump signed Executive Order 14275, “Restoring Common Sense to Federal Procurement,” directing the FAR Council to eliminate non-statutory requirements and streamline the FAR into a leaner, principles-based framework. [1] OMB Memorandum M-25-26 tasked the Office of Federal Procurement Policy and the FAR Council with executing the initiative in two phases.[²]

Phase One — model class deviations. Rather than proceed through ordinary notice-and-comment rulemaking first, the FAR Council issued model class deviations replacing each FAR part on an interim basis, publishing them progressively on acquisition.gov’s FAR Part Deviation Guide.[²] Individual agencies then had to adopt each part by posting their own agency-specific class deviation before the overhauled text became binding on their procurements — the legacy FAR otherwise continued to govern that agency. As of this writing, FAR Part 1 alone shows 38 agencies with posted deviations, including DoD, GSA, VA, HHS, and DOJ, each dated separately (Part 1’s model deviation issued May 2, 2025).[3] DoD implements the overhaul through its own DFARS-side deviations — for example, Class Deviation 2026-O0002 (Rev. 1, Aug. 5, 2026) for DFARS Part 201.[4] Part 52 (the solicitation-provisions and clauses part, model deviation issued October 28, 2025) shows no agency-specific deviations posted yet, meaning the operative clause set for any given procurement still depends on which prescribing parts that buyer has adopted.[5]

Phase Two — formal rulemaking. In June 2026, the FAR Council issued its first four proposed rules to formalize the deviations, covering 20 FAR parts.[6] A second batch followed in September 2026 — FAR Cases 2026-006 (Parts 16-17), 2026-010 (Parts 14, 28, 36) and 2026-011 — published in the Federal Register on September 18, 2026.[7] The Small Business Administration’s Office of Advocacy has flagged that these rules also propose reorganizing and renumbering Part 52 clauses, and is urging small businesses to comment by the October 19, 2026 deadline.[8] Separately, Executive Order 14402 (April 30, 2026), “Promoting Efficiency, Accountability, and Performance in Federal Contracting,” has already driven updates to the overhauled Parts 16 and 52.[9]

What to watch. Practitioners should not assume legacy FAR numbering is current — a clause or section may have moved, been reserved, or been reassigned under the overhaul, and the operative version still turns on the buying agency’s adoption status. Critics warn the accelerated, deviation-first approach removes established contractor protections before Congress or the public has weighed in through ordinary rulemaking.[10]

Footnotes