The Revolutionary FAR Overhaul: A Guide to the Most Significant Transformation of US Federal Procurement in Four Decades
The US government has launched the official rulemaking phase of the 'Revolutionary FAR Overhaul,' a massive initiative to strip decades of accumulated bureaucracy from federal contracting.
By Factlen Editorial Team
- Federal Procurement Leadership
- Focuses on accelerating mission delivery, saving taxpayer money, and cutting bureaucratic red tape.
- Government Contractors & Legal Counsel
- Focuses on compliance relief, standardization, and the practical realities of implementation.
- Federal IT & Mission Agencies
- Focuses on prioritizing commercial tech solutions and modernizing the supply chain.
What's not represented
- · Small Business Advocates
- · Government Accountability Office (GAO) Auditors
Why this matters
The Federal Acquisition Regulation dictates how the US government spends hundreds of billions of dollars annually. Streamlining this massive rulebook lowers the barrier to entry for small businesses and tech startups, potentially accelerating the delivery of critical technologies and services to federal agencies.
Key points
- The FAR Council has published four proposed rules to permanently implement the Revolutionary FAR Overhaul, revising 20 parts of the procurement rulebook.
- The overhaul strips non-statutory 'how-to' guidance from the FAR, relocating it to a flexible, non-regulatory 'FAR Companion.'
- Rigid mandates, such as mandatory audits for termination settlements and written acquisition plans, are being replaced with principle-based discretion.
- A new regulatory sunset process will require a comprehensive public review of the FAR every four years to prevent future bureaucratic bloat.
- The changes aim to attract commercial startups and non-traditional defense contractors by standardizing cybersecurity rules and reducing compliance burdens.
On June 23, 2026, the Federal Acquisition Regulatory Council published four massive proposed rules, marking the official start of Phase 2 of the Revolutionary FAR Overhaul. Spanning over 1,100 pages and revising 20 parts of the FAR, the package represents the most significant transformation of the government's procurement rulebook since its inception over four decades ago.[3][4]
The FAR is the foundational manual that dictates how the US government—the world's largest buyer—purchases everything from office supplies to fighter jets. Over the decades, it has ballooned into a highly prescriptive, complex web of regulations that often deters innovative companies from bidding on federal work.
In April 2025, Executive Order 14275, titled Restoring Common Sense to Federal Procurement, directed agencies to strip away this non-statutory bloat. The mandate was clear: restructure the system for speed, mission delivery, and alignment with modern commercial practices.[2]
The overhaul is unfolding in two distinct phases. Throughout 2025, Phase 1 relied on model class deviations—temporary stopgap measures that allowed agencies to bypass certain outdated FAR requirements immediately. This allowed the government to test the streamlined rules in real-time while gathering feedback from industry.[4]

Now, Phase 2 is using the formal notice-and-comment rulemaking process to permanently embed these streamlined policies into the FAR. The first public comment period for these 20 revised parts closes on July 23, 2026, with the FAR Council appearing to have closely considered the 1,600 comments it received during Phase 1.[4]
A core philosophy of the overhaul is separating mandatory statutory rules from best practices. The proposed rules aggressively relocate non-regulatory, how-to guidance out of the FAR and into a separate, living document called the FAR Companion.[2][3]
This structural shift aims to produce a shorter, statute-aligned FAR that is easier for both contracting officers and commercial vendors to navigate. By moving practical strategies and buying guides to the FAR Companion, the government can update best practices rapidly without going through the years-long formal rulemaking process.[2][3]

The overhaul also replaces rigid, one-size-fits-all mandates with principle-based discretion. For example, a detailed five-page directive on preparing written acquisition plans is being replaced by a one-page tip sheet, granting agencies the authority to use oral acquisition plans when appropriate.[3]
The overhaul also replaces rigid, one-size-fits-all mandates with principle-based discretion.
Similarly, mandatory audits for termination settlement proposals above a certain dollar threshold are being replaced by a risk-based approach. Contracting officers will now decide if audit support is needed based on a factual risk analysis, a common-sense change that is already saving months of administrative delay on lower-risk settlements.[3]
For government contractors, one of the most anticipated changes is the reorganization of FAR Part 40, which consolidates supply chain risk and information security. This section now incorporates rules on TikTok bans, drone restrictions, and the Federal Acquisition Supply Chain Security Act.[4]
Crucially, the proposed rules attempt to establish a uniform, governmentwide approach to handling Controlled Unclassified Information. If successful, this would eliminate the persistent frustration of navigating conflicting, agency-specific cybersecurity frameworks, such as the Department of Defense's CMMC, providing massive compliance relief for vendors.[3][4]

The rulemakings demonstrate that Phase 2 is not merely a codification exercise for the 2025 deviations. The FAR Council is actively using the notice-and-comment process to refine and materially revise policies, proposing significant revisions to market research, emergency acquisitions, and service contracting.[4]
The proposals also clean house by removing numerous obsolete provisions. Expired American Recovery and Reinvestment Act provisions, outdated A-76 competition requirements, and duplicative publicizing rules are all being stripped from the books to create a leaner regulatory environment.
To prevent the FAR from slowly accumulating bloat again in the future, the overhaul introduces a mandatory regulatory sunset process. Under the new rules, the FAR Council must conduct a comprehensive review of the regulations, with public input, at least once every four years to identify and eliminate unnecessary requirements.[1]
The broader goal of the initiative is to prioritize commercial products and services over custom, government-developed solutions. By aligning federal procurement more closely with commercial business practices, the government hopes to attract a wider pool of innovative startups and non-traditional defense contractors.

While the drafting of the new rules has been widely praised, legal experts note that the true test will be implementation. The success of the overhaul depends entirely on whether the federal acquisition workforce embraces the new flexibility.[3]
Contracting officers, long trained to rely on prescriptive checklists to avoid bid protests, will need to undergo a significant cultural shift. If they remain risk-averse and continue to demand the old documentation out of habit, the promised agility of the overhaul will fail to materialize in actual contract awards.[3]
The FAR Council is expected to release two additional proposed rule packages later in 2026 to cover the remainder of the FAR. Once the public comment periods close and the feedback is integrated, the final rules will be published, officially cementing the new era of federal procurement and fundamentally altering how the government interacts with the private sector.[4]
How we got here
April 2025
President Trump issues Executive Order 14275, 'Restoring Common Sense to Federal Procurement,' initiating the overhaul.
May 2025
OMB officially launches the 'Revolutionary FAR Overhaul' (RFO) initiative.
Late 2025
Phase 1 begins as agencies implement 'model class deviations' to bypass outdated rules temporarily.
June 23, 2026
Phase 2 begins with the publication of four proposed rules covering 20 FAR parts in the Federal Register.
July 23, 2026
Public comment period closes for the first batch of proposed rules.
Viewpoints in depth
Federal Procurement Leadership
Focuses on accelerating mission delivery and cutting bureaucratic red tape.
For the Office of Management and Budget and the FAR Council, the overhaul is an existential necessity for the government's ability to function in the 21st century. They argue that the procurement system should be judged by how quickly it can deliver capabilities to end-users, not by how well contractors navigate paperwork. By stripping away non-statutory rules and implementing a four-year sunset review, leadership believes they can permanently shift the government's buying habits to mirror successful commercial enterprises.
Government Contractors & Legal Counsel
Focuses on compliance relief, standardization, and the practical realities of implementation.
Industry groups and government contracts attorneys are highly optimistic about the consolidation of cybersecurity rules and the uniform treatment of Controlled Unclassified Information (CUI). However, they caution that rewriting the rules is only half the battle. Legal experts warn that if contracting officers remain risk-averse and continue to demand the old, prescriptive documentation out of habit or fear of bid protests, the promised flexibility of the overhaul will fail to materialize in actual contract awards.
Federal IT & Mission Agencies
Focuses on prioritizing commercial tech solutions and modernizing the supply chain.
For agencies tasked with modernizing federal IT and cybersecurity, the overhaul is a critical tool for accessing the broader commercial market. By removing the onerous, government-unique accounting and compliance standards that deter Silicon Valley startups, mission agencies hope to rapidly acquire cutting-edge software, AI tools, and commercial off-the-shelf products without forcing vendors to build custom, government-only solutions.
What we don't know
- How effectively the federal acquisition workforce will adapt to their new discretionary authority, given decades of reliance on prescriptive checklists.
- Whether the attempt to standardize Controlled Unclassified Information (CUI) governmentwide will successfully supersede entrenched, agency-specific frameworks like the DoD's CMMC.
- The exact timeline for the publication of the final rules, which depends on the volume and complexity of the public comments received by the July 2026 deadline.
Key terms
- Federal Acquisition Regulation (FAR)
- The primary rulebook governing the purchasing process of the United States federal government.
- Class Deviation
- A temporary authorization allowing federal agencies to bypass or alter specific FAR requirements before a formal rule change is finalized.
- Controlled Unclassified Information (CUI)
- Information that requires safeguarding or dissemination controls pursuant to applicable law and policies, but is not classified.
- FAR Companion
- A new, non-regulatory resource guide created to house best practices, how-to guidance, and practical advice outside of the formal FAR.
- Notice-and-Comment Rulemaking
- The formal legal process by which federal agencies propose new regulations and accept feedback from the public before finalizing them.
Frequently asked
What is the Revolutionary FAR Overhaul?
It is a massive, government-wide initiative to rewrite and streamline the Federal Acquisition Regulation (FAR), stripping away decades of non-statutory bureaucracy to make federal buying faster and more aligned with commercial practices.
How will this affect government contractors?
Contractors should see a reduction in prescriptive paperwork, more standardized cybersecurity requirements (especially regarding CUI), and a greater emphasis on commercial products and services.
When do the new rules take effect?
The first batch of proposed rules is currently in the public comment period, which ends on July 23, 2026. Final rules are expected to be published and implemented later in the year.
What is the regulatory sunset provision?
It is a new requirement that forces the FAR Council to comprehensively review the procurement regulations every four years to identify and remove unnecessary or outdated rules.
Sources
[1]Federal RegisterFederal Procurement Leadership
Federal Acquisition Regulation: Revolutionary Federal Acquisition Regulation Overhaul Parts 1, 2, 4, 33, 39, 40, and 53
Read on Federal Register →[2]Acquisition.govFederal Procurement Leadership
Revolutionary FAR Overhaul
Read on Acquisition.gov →[3]Womble Bond DickinsonGovernment Contractors & Legal Counsel
FAR Council Releases First Proposed Rules for 'Revolutionary FAR Overhaul'
Read on Womble Bond Dickinson →[4]Sheppard MullinGovernment Contractors & Legal Counsel
The Revolutionary FAR Overhaul Enters Phase 2
Read on Sheppard Mullin →
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