Public Sector Procurement News: The federal government is in the middle of the largest rewrite of the Federal Acquisition Regulation (FAR) in its history, and the details matter for any business that sells or wants to sell to a federal agency. Some of that rewrite is already in effect for defense contracts. Some of it is still an open proposal that could change before it becomes binding. Getting that distinction right is the difference between updating your compliance program too early and missing a deadline entirely.
What’s actually happening
In May 2025, the Office of Management and Budget (OMB) launched an initiative called the Revolutionary FAR Overhaul (RFO), following Executive Order 14275, “Restoring Common Sense to Federal Procurement.” The goal, as described on the Federal Acquisition Regulatory Council’s official RFO page, is to return the FAR to its statutory roots, rewrite it in plain language, and eliminate most rules that aren’t required by law. The Council running this effort, known as the FAR Council, is made up of the Office of Federal Procurement Policy (OFPP), the Department of Defense, the General Services Administration, and NASA.
The rewrite is happening in two tracks that businesses need to tell apart.
The first track is a series of Defense Department class deviations. These are interim instructions that already change how DoD contracting officers operate, without going through the full federal rulemaking process. The Department of War’s DFARS Revolutionary FAR Overhaul deviations page lists dozens of these deviations covering DFARS parts across the board, with some issued as early as January 2026 and others revised as recently as September 2026. If your company holds or bids on defense contracts, these deviations are operative now, not pending.
The second track is formal rulemaking to make equivalent changes permanent and government-wide, covering civilian agencies as well as defense. On June 23, 2026, the FAR Council published four proposed rules in the Federal Register, covering 20 parts of the FAR. According to Federal Register documents for FAR Case 2026-001, the public comment period for these four proposed rules closed on July 23, 2026. As of this writing, the Department of Defense’s open FAR cases list still shows these cases as open, meaning the FAR Council has not yet issued final rules incorporating them. That makes this second track proposed policy, not current law, however far along it is.
What’s confirmed versus what’s still proposed
CONFIRMED and already in effect:
- The RFO exists, is underway, and is being led by the FAR Council under OFPP, per the official Acquisition.gov FAR Overhaul page.
- DoD class deviations tied to the RFO are currently operative for defense contracts, with deviations issued and revised on a rolling basis through at least September 2026.
- Separately from the RFO, Federal Acquisition Circular (FAC) 2026-01, a final rule, took effect adjusting the dollar thresholds that trigger the World Trade Organization Government Procurement Agreement and various Free Trade Agreements, as published in the Federal Register notice for FAC 2026-01. These threshold adjustments happen periodically and are unrelated to the broader RFO rewrite, but they’re a live compliance detail for any contractor doing cross-border government work.
PROPOSED, not yet final:
- The four June 23, 2026 proposed rules (FAR Cases 2026-001, 2026-002, 2026-005, and 2026-007), which would permanently revise 20 FAR parts including provisions on System for Award Management (SAM) representations and certifications, bid protest procedures, and the 8(a) small business program framework for civilian agencies. A legal analysis from Schwabe’s summary of RFO Phase Two notes these rules would also introduce a four-year sunset provision: any FAR section not required by statute would automatically expire four years after its effective date unless the FAR Council affirmatively renews it.
- Whether, or in what form, these proposed changes become final. The FAR Council received roughly 1,600 comments during the earlier deviation phase, according to a legal update from Sheppard Mullin, and a similar volume of feedback on these proposed rules could shift the final text.
Who this affects
Any business that currently holds a federal contract, subcontracts on one, or is preparing a bid should be tracking this. The practical split is by agency type. Companies working primarily with the Department of Defense are already operating under the class deviations described above, so their compliance teams need current information now, not once a final rule is published. Companies working with civilian agencies, or planning to, are in a different position: the changes that would apply to them are still proposed, so acting as if they’re already binding risks overcorrecting on a rule that could still change.
Small businesses have a specific reason to pay attention to FAR Case 2026-001, since it touches the civilian 8(a) program framework directly. A change to how that framework is structured could affect eligibility, set-aside procedures, or reporting requirements for companies that rely on that certification.
What to do while this is still moving
Because the rulemaking isn’t finished, the most useful posture for most contractors right now is preparation rather than immediate overhaul. A few concrete steps make sense regardless of how the final rules land:
- Confirm whether your current contracts are DoD or civilian agency, since that determines whether the class deviations already apply to you directly.
- Review your SAM.gov representations and certifications now, since FAR Case 2026-001 touches this area and keeping that information current is good practice independent of the rulemaking outcome.
- Track the FAR Council’s own Acquisition.gov news and announcements page rather than relying on secondhand summaries, since it posts primary updates as the Council releases them.
- If your compliance program was already updated to match the Phase 1 DoD deviations, treat that as a head start rather than a finished task. The Schwabe analysis linked above notes the Phase 2 proposed rules go beyond simply making the deviations permanent in several areas, so a compliance program built only around the deviations may still need adjustment once final rules publish.
What to watch next
The FAR Council has indicated it will continue releasing additional proposed rules in batches as the overhaul progresses, based on the pattern established with the first four cases. Watch for the FAR Council’s response to the comment period that closed July 23, 2026, since revisions made in response to those roughly 1,600-plus comments will show up in whatever final rule eventually publishes. Watch also for whether DoD’s class deviations get folded into the same final rulemaking timeline as the civilian-facing proposed rules, or continue on a separate track. Given the scale of this rewrite, spanning most of the FAR’s core structure, this is not a single event with one effective date. It is an ongoing process that will keep generating individual final rules over the coming months, each with its own effective date that contractors will need to track separately.
