The Revolutionary FAR Overhaul: Where It Stands

On September 18, 2026, the Federal Acquisition Regulatory Council published four proposed rules that rewrite seventeen parts of the Federal Acquisition Regulation. Comments are due October 19, 2026. Eight of the twelve planned rules are now out for public comment.

What is the Revolutionary FAR Overhaul?

The Revolutionary FAR Overhaul is a complete rewrite of the Federal Acquisition Regulation, the rulebook that governs how the federal government buys goods and services. It is the first end-to-end overhaul of the FAR in its roughly 40-year history.

It began with Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025. The order found that the FAR had grown into "an excessive and overcomplicated regulatory framework," and directed the FAR Council to produce a regulation containing only what statute requires or sound procurement demands.

The Office of Management and Budget then issued Memorandum M-25-26, which named the effort and set the plan. Two ideas drive it: cut the FAR down to statutory requirements and essential guardrails, and move the "how to" material out of regulation into non-binding guidance. A rule you must follow becomes advice a contracting officer may weigh.

When did it start, and when will it be finished?

The work is split into two phases, and the first one is already done.

Phase one ran through fiscal year 2025. The FAR Council issued model class deviations replacing each part of the FAR. A deviation lets an agency depart from the written rule before it is final, and agencies adopted them one at a time. Much of the overhaul is already operating, even though the formal rules are still proposals.

Phase two is the formal rulemaking now underway. Twelve proposed rules will cover the entire FAR, each with a public comment period, each followed by a final rule.

The FAR Council has not published a finish date. Four proposed rules are still to come, and each of the twelve needs a final rule after its comment period closes.

What the September 2026 rules cover

The rules published in June dealt mostly with how agencies plan and advertise work before anyone bids. These four reach the transaction itself: how an offer gets solicited, what a bidder has to hand over, and how the award gets made.

How the changes affect small businesses

The representations and certifications block would go away

If you have bid a commercial solicitation, you have filled out FAR 52.212-3. It is the long block of representations and certifications covering your size status, ownership, certifications, tax status and about thirty other items. Its companion, FAR 52.212-5, lists every statute and executive order that might apply.

The FAR Council proposes to remove both. In their place, each provision and clause in the FAR would state plainly whether it applies to commercial buying, and the contracting officer or an agency clause system would work from those statements. The change "shifts the burden of determining which provisions and clauses are applicable to the commercial acquisitions from the offeror or contractor to the Government."

That second change matters more over time. If a clause is not on the prescribed list, an agency would have to process a formal deviation to use it. Today a contracting officer can pull in clauses Part 12 never listed, and that is how noncommercial terms end up in commercial contracts.

Simplified procedures get a harder push

Three dollar figures set the shape of federal buying for a small company.

That last line rises to $15 million in declared emergencies and major disasters.

Those numbers are not new. They took effect in October 2025, and our 2026 guide to the FAR overhaul has the full threshold table. What changes is how firmly the FAR pushes buyers to use them. The $9 million authority sits off to one side in subpart 13.5 today. The proposal moves it into Part 12 and tells contracting officers they "should not be using the burdensome procedures associated with conducting negotiations or sealed bidding."

Part 13 narrows to match, covering only noncommercial buys at or below the SAT. The FAR Council's own analysis says the streamlined Part 13 would have "a positive economic impact on small businesses competing for such contracts."

This is where a small firm wins without writing a full proposal. A $300,000 award under simplified procedures can come down to a quote, a past performance reference and a price.

Buyers would be pointed toward new suppliers

For buys at or below the SAT, a contracting officer could post a short presolicitation notice instead of a full solicitation, then "solicit quotations from at least three sources, which should include two new sources, whenever practicable." That instruction would sit in the regulation itself, not in guidance.

The FAR Council explains why. Roughly 45 percent of contract dollars in fiscal year 2025 went out without competition or with only one offer, and the federal supplier base has been shrinking for twenty years, small businesses fastest of all.

A rule cannot make a contracting officer find you. Your SAM registration, your NAICS codes and your past performance write-ups are what make you findable when one goes looking.

Construction could be bought as a commercial service

A companion rule would change the definition of "commercial services" in FAR Part 2 so construction can qualify. Agencies could then buy it using the Part 12 commercial procedures rather than the heavier path.

The contracting officer has to make a finding first: the work must be "of a type offered and sold competitively in substantial quantities in the commercial marketplace based on established catalog or market prices." Routine, repeatable, priced work fits. A one-off federal facility build does not.

Part 36 still applies. Bonding, wage rates and the construction-specific clauses do not disappear because a buy is commercial.

What is not changing

Part 19, Small Business Programs, is not in any of the eight rules published so far. Set-asides, 8(a), HUBZone, SDVOSB and WOSB are untouched by this batch. That rewrite is still coming, and it is the one to watch hardest.

Size standards are a separate SBA rulemaking, covered in our post on SBA's proposed size standards. Your SAM registration, certifications and renewal dates are unaffected.

What to do before October 19

Comment if any of this touches your work. Comments go to regulations.gov citing the FAR case number. A short comment describing what a rule does to a real company carries more weight than a long one arguing policy, and small firms are underrepresented in these dockets every time.

Look at what you sell through a commercial lens. If your work is commercially available and priced from a catalog or standard rate, the Part 12 path is the one getting faster. Construction firms should read the commercial services definition and decide whether their routine work fits.

Get your multiple-award contract strategy current. The Part 16 proposal writes on-ramps and off-ramps into the rules for multiple-award contracts, which is how a company gets added to a vehicle it missed the first time. It also adds order-level explanations for unsuccessful offerors, so you can learn why you lost a task order. Our post on diversifying contract vehicles covers the wider picture.

The bottom line

The overhaul started in April 2025 and is two thirds of the way through its proposed rules, with no announced finish date. Deviations already shape how agencies buy while the formal rules work through comment.

This batch reached the parts small businesses live in: fewer clauses, less paperwork on the offeror, more buying under simplified procedures, and an explicit nudge toward suppliers the government has not used before. Comments close October 19, 2026.

The firms that benefit are the ones already easy to find and quick to buy from: work that reads as commercial, NAICS codes that match what agencies buy, and past performance a contracting officer can check in minutes. If you are not sure your company clears that bar, talk to a FEDCON advisor.

This post covers proposed rules. We will update it when the FAR Council publishes the remaining four rules, issues final rules, or changes the comment deadline.