The Overview: How to Survive and Thrive Under FAR Changes

Interim Federal Acquisition Regulation (FAR) changes are now in effect, and they’re already influencing how agencies plan, evaluate, award, and manage requests for proposals (RFPs) and contracts. These updates will remain in place as the government reviews industry feedback submitted during the comment period, which closed on November 3, 2025.

This article tackles three critical questions:

1. How confident are industry professionals in applying the new FAR changes?
2. How are these updates transforming proposal development?
3. What’s new or changed across each FAR Part?

If you want to turn these new FAR updates into a competitive advantage, contact Lohfeld Consulting. We’ll help you apply the changes with confidence and precision to develop high-scoring proposals that win contracts.

How Confident Do Bid and Proposal Industry Professionals Feel About FAR Changes?

The scope of the FAR changes and how subparts interact is extensive. So, we asked bid and proposal professionals how confident they feel about understanding these sweeping changes and their impact on future bids and proposals. Here’s what our LinkedIn polls revealed:

• Very Confident: 4%
• Confident: 17%
• Somewhat Confident: 31%
• Not Confident: 48%

If you feel a bit overwhelmed, you’re not alone. It’s evident that the FAR overhaul has left many in the industry searching for clarity—proof that staying ahead now requires both knowledge and strategy.

What Is the Impact of the FAR Changes on Bids and Proposals?

Table 1 describes how the FAR changes are likely to influence your bid and proposal strategy. While many FAR changes target niche sectors, the items in Table 1 cut across industries and affect core capture, compliance, and proposal development tasks. We encourage bid and proposal professionals to carefully read each new RFP and determine how new FAR changes affect their proposal development.

Table 1: FAR Changes Impacting Bids and Proposals

Topic	FAR Part(s)	Impact
Plain Language and Digital Engagement	4, 5, 12, 44	The FAR Council is pushing for easier-to-read solicitations, standardized reporting, modern outreach tools, and streamlined subcontract oversight. Contractors should expect clearer RFPs, faster debriefs, greater digital engagement, and increased accountability for subcontractor performance.
Planning and Competition Begin Earlier	6, 7, 10, 11, 12	Planning and competition are no longer just box-checking. Market research, modular design, and outcome-based requirements are being institutionalized. Agencies must plan more realistically, test solutions through pilots and prototypes, and structure acquisitions to expand competition. For capture teams, this means more engagement with the government early to shape requirements before the RFP drops.
Shift from Lowest Price to Highest Mission Impact	6, 7, 10, 11	Under the new guidance, contracting officers are encouraged to look beyond price and evaluate outcomes, performance measures, and technical maturity. Parts 6, 7, 10, and 11 now require early market research and acquisition planning that emphasize results, meaning proposal teams must clearly link strengths to mission success in measurable terms.
Mandatory Sources & Vehicles	8	This change requires agencies to use excess personal property, Federal Prison Industries, and AbilityOne Programs to fulfill requirements. Agencies must maximize efficiency by using existing contracts, category management vehicles, and shared services to consolidate buying power and streamline procurement.
Simplified Acquisitions Get Smarter	13, 14, 15	Simplified and negotiated acquisitions now emphasize efficiency, flexibility, and transparency. Expect streamlined RFQs, expanded oral presentations, and clarified evaluation and debriefing procedures designed to speed awards while maintaining fairness.
Clarification of Best Value Determination	15	Updated FAR Part 15 requires detailed documentation of how evaluators apply the stated criteria. Agencies must show that every strength, weakness, and trade-off aligns precisely with Sections L and M. For proposal writers, this reinforces the importance of strength-based writing. Enhanced post-award debriefing rules give offerors clearer insights into how scores were assigned. Agencies must explain the rationale for trade-offs, rankings, and best-value decisions.
Innovation as a Competitive Differentiator	11, 12, 35	These changes encourage outcome-based requirements, modular designs, and proof-of-concepts. Evaluators can now assign higher scores to proposals that demonstrate innovation backed by credible execution plans and ROI. Proposals must balance creative approaches with data-driven proof of feasibility.
Non-Cost Factors	23, 36, 39, 40	The overhaul formalizes the weight of security (Parts 39, 40), sustainability (Part 23), and collaboration (Part 36) in source selections. These factors, once “nice-to-haves,” are now integral to the definition of value. Evaluators are directed to credit contractors who show proactive risk mitigation, transparency, and trustworthiness, especially in cybersecurity, supply chain, and quality systems.
Data Integrity, Privacy, and Transparency	24, 25, 30, 31	New standards for protecting data, applying cost accounting rules, and disclosing pricing reinforce transparency and accountability. Proposal teams must ensure that cost volumes, data submissions, and privacy practices align with the updated FAR requirements.
R&D and Innovation	35	Research and Development (R&D) acquisitions are shifting toward outcome-driven requirements, hybrid contracts, and peer review evaluations. Agencies are encouraged to avoid rigid specs and allow contractor innovation to flourish. Contractors will need to highlight technical merit, ROI, and innovative approaches over price alone.
Protests, Quality, and Terminations Demand Documentation	33, 46, 49	Clear evaluation criteria, bulleted documentation, and strong records are now critical defenses against protests. Agencies will tighten quality assurance and move quickly on terminations. Contractors must maintain meticulous records, anticipate potential risks, and be proactive in their communication to protect their interests.
Construction and Design-Build Prioritize Qualifications	36	The government is elevating past performance, collaboration history, and certifications over lowest price when evaluating design-build teams. Site visits, pre-award collaboration, and streamlined shortlists will reward firms that bring strong, experienced teams with a proven track record.
Cybersecurity and Supply Chain	39, 40	Cybersecurity, artificial intelligence (AI) risk, and supply chain integrity are now core evaluation factors. Contractors must demonstrate not only what they deliver but how securely they source, build, and protect it. Expect solicitations with tighter security requirements, ongoing compliance checks, and new opportunities for firms that can prove resilient supply chains.

Table 2 provides context for the FAR changes by categorizing their purpose across business development lifecycle functions.

Table 2: FAR Changes Across Business Development Lifecycle Activities

Lifecycle Phase	Primary FAR Parts
Capture	1, 5, 6, 7, 8, 9, 10, 11, 16, 17, 18, 23, 34, 35, 39, 40, 41, 50	Sets the foundation for competitive positioning and opportunity shaping. Encourages early market engagement, outcome-based requirements, and modular acquisition strategies. Expands use of digital tools and industry days, integrating cybersecurity, sustainability, and innovation as core capture themes.
Teaming	3, 8, 9, 19, 26, 44	Strengthens ethics, organizational conflict-of-interest (OCI) controls, and transparency in teaming arrangements. Reinforces small business participation and subcontracting compliance through set-asides, incentives, and reporting. Requires more disciplined partner vetting and structured teaming agreements aligned with FAR Part 9 responsibility standards.
Proposal Development	2, 4, 11, 12, 13, 14, 15, 16, 19, 22, 23, 24, 25, 27, 28, 29, 30, 31, 36, 37, 39, 40, 45, 46, 47, 48, 52, 53	Modernizes proposal design, formatting, and evaluation alignment. Promotes plain-language writing, digital submission standards, and modular section development tied to measurable results. Expands oral presentations, emphasizes best-value trade-offs, strengthens cost realism and quality assurance, and mandates cybersecurity and data protection narratives.
Proposal Evaluation	6, 7, 10, 11, 15, 23, 33, 36, 39, 40	Refines how agencies assess strengths, weaknesses, and best-value trade-offs. Prioritizes innovation, mission alignment, and non-cost factors such as security, sustainability, and past performance. Introduces more consistent scoring tied to Sections L and M, data-driven risk analysis, and transparent documentation of evaluation decisions.
Proposal Clarification and Negotiation	15, 32, 33	Expands the definition of clarifications, cost realism, and post-award debriefings. Clarifies rules for negotiations, cost/price adjustments, and financing arrangements. Promotes transparency and fair opportunity in discussions.
Contract Management (Post-Award)	24, 25, 27, 28, 29, 30, 31, 32, 37, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49	Emphasizes performance oversight, cost compliance, risk mitigation, and quality assurance. Strengthens property management, cybersecurity compliance, subcontractor accountability, and dispute resolution. Expands value engineering, termination guidance, and post-award transparency.

Summary of FAR Part Changes

The following paragraphs provide a high-level summary of each FAR Part change, particularly as it relates to the general capture of opportunities and the preparation of proposals. Please refer to the FAR 2.0 Companion posted on October 30, 2025, for details.

Part 1 – Federal Acquisition Regulation System (05/22/2025): The FAR Council encourages the government to engage in responsible and constructive exchanges with industry throughout the acquisition lifecycle, consistent with existing laws and regulations. FAR Part 1 also urges the government to gather feedback to continuously improve its procurement processes.

Part 2 – Definitions of Words and Terms: This change updated and clarified key definitions used throughout the FAR. This ensures that all stakeholders interpret terms (e.g., “commercial product” or “subcontract”) consistently. It also helps avoid disputes caused by differing interpretations of contract language.

Part 3 – Improper Business Practices and Personal Conflicts of Interest (09/11/2025): The Council restructured Part 3 to present safeguards, procurement integrity, kickbacks, contingent fees, whistleblower protections, contractor ethics programs, and personal conflict-of-interest controls in a streamlined subpart layout with updated clause usage.

Part 4 – Administrative and Information Matters (08/14/2025): This update simplified some reporting and administrative tasks required under contracts. Agencies are directed to collect data in a more standardized way, reducing burdens on contractors. It also introduced electronic tools for specific submissions. The goal is to improve efficiency and cut unnecessary paperwork.

Part 5 – Publicizing Contract Actions (08/08/2025): FAR Part 5 requires agencies to use plain language in solicitations and notices so businesses can quickly decide whether opportunities are a fit. Acquisition teams actively engage industry throughout the process by issuing draft documents and presolicitation notices and by hosting events such as industry days to refine requirements and enhance proposal quality. The government can issue draft documents to industry at any time up until the publication of the final solicitation. Agencies expand their reach by supplementing SAM.gov postings with modern digital platforms, social media, and virtual engagement tools while ensuring links point back to the official government point of entry (GPE). Contracting officers also strategically manage response times, prioritize digital outreach efforts over paid advertising, and use presolicitation notices and GPE postings to gather market intelligence and feedback that strengthen acquisition outcomes.

Part 6 – Completion Requirements (06/27/2025): FAR Part 6 emphasizes early acquisition planning to maximize competition and innovation by breaking down large requirements, standardizing specifications, and exploring commercial solutions. Agencies can use this proactive approach to identify barriers to competition, build multiple qualified sources, and reduce reliance on exceptions. When exceptions are necessary, contracting officers prepare clear, compelling Justifications and Approvals (J&As) that tell the story of mission needs, market analysis, and why alternatives will not work. Strong J&As align the cited authority with actual circumstances, demonstrate stewardship of taxpayer dollars, and withstand potential challenges or scrutiny from reviewers.

Part 7 – Acquisition Planning (09/04/2025): This change strengthens acquisition planning policies.  Part 7 emphasizes early, collaborative, and flexible acquisition planning to improve competition, innovation, and outcomes. When written plans are not required, oral acquisition plans developed through facilitated stakeholder discussions can document key decisions and guide progress. Agencies are encouraged to begin planning as soon as a need is identified, well before funding is received, to allow for market research, industry engagement, and needs statement development that align acquisitions with mission goals. Acquisition plans should be treated as living documents that are tailored to the complexity of the procurement, updated as conditions evolve, and detailed enough to ensure accountability, competition, and mission success.

Part 8 – Required Sources of Supplies and Services (08/14/2025, 8/29/2025): This change requires agencies to fulfill requirements by first turning to excess personal property, Federal Prison Industries (UNICOR), and the AbilityOne Program, ensuring compliance with mandatory sources while reducing cost and waste. Then, agencies must maximize efficiency by leveraging existing contracts and category management vehicles, such as Federal Supply Schedules, GWACs, and shared services, to consolidate buying power and streamline procurement. Contracting officers should enhance outcomes by applying Periodic Table of Acquisition Innovations (PTAI) streamlining techniques for RFQs, making balanced best-value determinations, and managing award notices, explanations, and debriefings strategically to control the protest window.

Part 9 – Contractor Qualifications (08/21/2025): This change recognizes contractor teaming arrangements, including partnerships, joint ventures, and prime-sub relationships, as legitimate ways to combine strengths, particularly for R&D or complex requirements, while keeping the prime fully responsible for performance. It also provides for defense production and R&D pools, which require approval from the Small Business Administration (SBA) or the Defense Production Act (DPA). It allows members to collaborate on specialized contracts while maintaining compliance with competition rules. Contracting officers must consider the total cost, not just the lowest prices, since poor performance or defaults can increase overall costs and reduce value to the government. Agencies may establish special standards of responsibility when acquisitions require unique expertise or facilities, provided the standards are justified and not unduly restrictive. Pre-award surveys are used only when necessary and are avoided for simplified or commercial buys, unless exceptional circumstances apply, ensuring that responsibility determinations are efficient and risk-based. Finally, for recurring procurements, agencies can maintain a Qualified Bidders List (QBL) to pre-clear vendors for legal, security, or IT requirements, streamlining future acquisitions without committing to price in advance.

Part 10 – Market Research (05/22/2025): FAR Part 10 treats market research as an incremental process, starting with internal capabilities, then checking shared services and existing contract vehicles, and finally looking to the open market. Acquisition teams use this research to determine whether commercial products or services can meet needs with little or no modification, and whether small businesses or new entrants can compete. Agencies rely on data-driven insights from systems like SAM.gov, Contractor Performance Assessment Reports (CPARS), and the Federal Procurement Data System (FPDS), along with industry publications, technical experts, and past procurements, to shape acquisition strategies. Market research also includes direct engagement with industry through industry days, presolicitation conferences, RFIs, and special notices, which helps refine requirements and inform competitive approaches. Contracting officers and program teams can hold one-on-one exchanges with vendors, provided they do not promise awards or disclose proprietary information. For smaller commercial acquisitions under simplified thresholds, a separate written market research report is not required; award documentation can serve as sufficient evidence.

Part 11 – Describing Agency Needs (06/18/2025): FAR Part 11 directs agencies to describe needs through modular strategies, breaking large requirements into smaller components that broaden competition, reduce integration risks, and support incremental modernization. It introduces rapid capability integration tools, such as pilots, proof-of-concepts, and milestone-based contracts, that allow agencies to test emerging technologies before moving to full production. The guidance emphasizes outcome-based contracting, where agencies define results and performance metrics rather than prescribing methods, thereby fostering innovation, stronger partnerships, and solutions directly tied to mission outcomes. Agencies are encouraged to use collaborative requirements development by sharing drafts, hosting industry days, and gathering feedback to ensure solicitations reflect real-world practices. They are also reminded to use existing standards, avoid assigning inherently governmental functions to contractors, and properly mark contractor-generated documents. While performance-based specifications remain the preferred approach, agencies may use brand-name or equal descriptions when necessary, provided they identify salient characteristics.

Part 12 – Acquisition of Commercial Products and Services (08/14/2025): Acquisition professionals determine whether a product or service is commercial by distinguishing minor modifications, which preserve commercial status, from major customizations, which eliminate it, and by ensuring that service pricing reflects true market rates. Agencies must adopt modular acquisition strategies to break complex requirements into smaller, manageable components, reducing integration risk and enabling more frequent technology refreshes. They must establish and regularly review blanket purchase agreements (BPAs) and rely on negotiated supplier license agreements whenever possible, engaging legal and technical experts when additional terms are needed. Contracting officers must apply simplified Part 12 procedures and PTAI innovations for acquisitions up to $7.5M (or $15M in some instances), emphasize best-value determinations, and manage award notices, explanations, and debriefings to avoid unnecessarily extending protest windows.

Part 13 – Simplified Procedures for Noncommercial Acquisitions (09/18/2025): FAR Part 13 implements noncommercial products and services valued at or below the simplified acquisition threshold (SAT) and emphasizes competition to the maximum extent practicable. It requires the government to follow procedures when procuring non-commercial products and services valued at more than the micro-purchase threshold (MPTO) or less than the SAT, with exceptions for A-E, construction, and R&D procurements. The updated structure follows the acquisition lifecycle: presolicitation, solicitation, evaluation, award, and post-award with clearer cross-references to other FAR parts. It defines the terms of post-award interactions, including notifications, cancellations/terminations, or payments.

Part 14 – Sealed Bidding (09/25/2025): Defines the rules for making a sealed bid. FAR Part 14 reaffirms sealed bidding as a contracting method that employs competitive bids, public opening of bids, and awarding. It approves the use of sealed bids whenever the conditions in 6.101(b) are met and requires the contracting officer to use firm-fixed contracts or fixed contracts with economic adjustment clauses when using sealed bidding. It defines conditions of use for sealed bids throughout the business development lifecycle and the provisions for Two-Step Sealed Bidding. FAR Part 14 defines the rules for submitting, modifying, or withdrawing sealed bids and receipts. It notes that the government has the authority to permit bid corrections, but that authority is limited to bids that are responsive to the invitation. The rule does not allow for correcting bids to make them responsive. Finally, the contracting officer must notify each unsuccessful bidder in writing or electronically within three days after contract award that its bid was not accepted. When the government awards a contract to someone other than the low bidder, it must state the reason for rejection in the notice to each unsuccessful bidder. Also, if fewer than three bids are received, the government must investigate why. The contracting officer may still award the contract, and if appropriate, consider taking corrective action to increase future competition, noting it in the contract file.

Part 15 – Contracting by Negotiation (9/30/2025): The scope of FAR Part 15 describes the changes to five major subparts: presolicitation and solicitations actions (15.1), evaluation and award (15.2), post-award (15.3), contract pricing (15.4), and unsolicited proposals (15.5), as summarized here:

Subpart 15.1 – Presolicitation and Solicitation contains nine subsections that describe key terms, rules for the government’s exchange with industry, competitive source selection, competitive evaluation factors, RFP amendments, proposal receipt, and contract formats. FAR Part 15 redefined a deficiency as “any part of an offer that does not conform to a material requirement of an RFP”.

Subpart 15.2 – Evaluation and Award clarifies how competitive proposals are evaluated, emphasizing that assessments must align strictly with the evaluation factors in the RFP. It expands the definition of “clarifications,” allowing contracting officers to request information to resolve ambiguities or minor errors at any point before award, as long as proposals are not materially changed. Oral presentations now require documented records that clearly reflect what information was relied upon in source selection, and any material terms discussed must be written into the contract. The revisions also reinforce requirements for fair and transparent evaluations of technical, past performance, and cost/price factors.

Subpart 15.3 – Post-award outlines post-award procedures for negotiated contracts, including debriefings, protests, and error corrections. It clarifies that offerors may request a post-award debriefing within three days of the award notice, during which agencies must provide key evaluation details, rankings, and the rationale for the award while protecting proprietary information. The subpart also establishes procedures for handling protests, processing mistakes discovered after award, and addressing defective certified cost or pricing data, ensuring the government can recover overpayments and enforce penalties when necessary. Finally, it requires regular audits and reviews of contractor estimating systems to improve proposal reliability, negotiation efficiency, and compliance.

Subpart 15.4 – Contract Pricing establishes comprehensive policies and procedures for determining, analyzing, and negotiating fair and reasonable contract prices for negotiated prime contracts, subcontracts, and modifications. It defines requirements for obtaining certified and non-certified cost or pricing data, performing price, cost, and cost realism analyses, and documenting negotiation results to ensure transparency and accountability. The subpart also covers special pricing areas such as unbalanced pricing, profit determination, subcontract pricing, make-or-buy programs, and should-cost reviews, thereby preventing inflated or distorted pricing and promoting efficiency. Overall, it provides contracting officers with structured methods and safeguards to ensure accurate pricing, mitigate risk, and protect the government’s financial interests in contract negotiations.

Subpart 15.5 – Unsolicited Proposals contains policies and procedures for the submission, receipt, evaluation, and acceptance or rejection of unsolicited proposals. It defines what constitutes a valid unsolicited proposal, specifies required content and data protection markings, and prohibits government personnel from using or disclosing proprietary information without consent. Agencies must review such proposals for innovation, mission relevance, technical merit, and cost realism before considering sole-source negotiations. Contracts based on unsolicited proposals may proceed only after a favorable evaluation, proper justification and approval, funding availability, and compliance with public notice requirements.

Part 16 – Types of Contracts (09/30/2025): FAR Part 16 directs agencies to select and document the most appropriate contract type during acquisition planning while prohibiting cost-plus-a-percentage-of-cost arrangements. It defines when each fixed-price and cost-reimbursement contract type may be used and requires approved acquisition plans, adequate accounting systems, and sufficient oversight. The rule strengthens the use of incentive structures by requiring clear targets, evaluation plans, and clauses that link profit or fee to cost, schedule, and technical performance. It governs indefinite-delivery contracts, promotes multiple awards, defines fair-opportunity ordering procedures, and limits protests to significant scope or value changes. Time-and-materials and labor-hour contracts are allowed only when the scope or duration cannot be reasonably estimated, with ceilings, surveillance, and justifications required. Finally, Part 16 clarifies that basic agreements and basic ordering agreements streamline repeat buys but are not binding contracts or funding obligations. It also urges fast, transparent debriefings to manage protest timelines and reduce risk, treating debriefs as learning opportunities for both industry and the government.

Part 17 – Special Contracting Methods (09/11/2025): The Council reissued Part 17 to organize multiyear contracting (Subpart 17.1), options (17.2), leader-company contracting (17.4), interagency acquisitions (17.5–17.7, including DOD-on-behalf rules), and reverse auctions (17.8), with updated procedures and clauses. Multiyear contracting, smart use of options, and inclusion of “continuity of services” and “option to extend services” clauses help agencies lower costs, stabilize performance, and bridge delays while maintaining flexibility to scale work.

Part 18 – Emergency Acquisitions (06/12/2025): FAR Part 18 directs agencies to plan ahead by awarding emergency response contracts in advance, ensuring they can respond immediately when disasters strike. Contracting officers may use the Emergency Procurement List flexibilities to act quickly, even without a formal emergency declaration. For acquisitions tied to defense or recovery from major threats, agencies may treat requirements as commercial buys, raising the simplified acquisition threshold from $7.5M to $15M. Simplified request for quote (RFQ)-to-purchase order procedures, supported by PTAI evaluation techniques, streamline procurement, reduce delays, and ensure agencies can deliver rapid and effective emergency response.

Part 19 – Small Business (09/26/2025): Subpart 19.1defines key terms (e.g., ANC, Indian tribe, subcontract, commercial/individual/master plans) and establishes the government’s policy to maximize small business participation, measure agency performance, and use SBA certifications and representations. It outlines roles with SBA/OSDBU, NAICS/size-standard assignments and appeals, and mandates or authorizes tools such as total/partial set-asides, sole-source awards, reserves on multiple-award contracts, and set-aside orders for HUBZone, SDVOSB, WOSB/EDWOSB, and 8(a), including associated thresholds and verification. The Part prescribes the HUBZone price evaluation preference, limitations on subcontracting, the nonmanufacturer rule, and the circumstances under which small business subcontracting plans (with clauses, incentives, liquidated damages, and eSRS reporting) are required. It also details 8(a) program eligibility/offer–accept processes, competitive vs. sole-source rules and thresholds, SBA appeal pathways, release of follow-on work, and ordering procedures under multiple-award contracts (e.g., NAICS at order level and fair-opportunity set-asides).

Subpart 19.2 – Policies governs how small business size and socioeconomic status are represented, verified, and protested before award, outlining procedures for SBA certification, eligibility reviews, and status protests for programs such as 8(a), HUBZone, SDVOSB, and WOSB. It ensures fair evaluation and award processes by defining when and how challenges can be raised, how SBA determinations are made, and how contracting officers must act based on those findings. FAR Subpart 19.3 covers post-award actions—requiring re-representation of business size after mergers or at specified intervals, enforcing subcontracting plan compliance, imposing penalties for nonperformance, and detailing ongoing administration of 8(a) program contracts, including terminations, waivers, and goal crediting.

Part 20 – Reserved

Part 21 – Reserved

Part 22 – Application of Labor Laws to Government Acquisitions (09/30/2025): Subpart 22.1summarizes basic labor policies for labor relations and overtime, indicating that solicitations must not specify delivery or performance schedules that may require overtime at government expense. During the evaluation of an award, the government should ascertain the extent to which offers are based on overtime and shift premiums and negotiate contract prices or estimated costs without these premiums or obtain the requirement from other sources. It notes the government must approve overtime and the conditions for its approval. Subparts 22.2-21 address specific labor terms, including the use of convict labor, work hours and safety, labor standards involving construction, and service contract labor standards.

Part 23 – Sustainable Acquisition, Material Safety, and Pollution Prevention (09/30/2025): FAR Part 23 establishes policies promoting sustainable acquisition, safe handling of hazardous materials, and pollution prevention in federal procurement. Subpart 23.1 directs agencies to prioritize purchasing sustainable products such as energy-efficient, biobased, or recovered-material items unless impracticable due to cost, performance, or availability. Subpart 23.2 authorizes energy savings performance contracts, allowing contractors to implement and finance energy conservation measures in exchange for a share of the resulting cost savings. Subpart 23.202 states that under an Energy Savings Performance Contract (ESPC), an agency can contract with an energy service company for a period of up to 25 years to “improve energy efficiency in one or more agency facilities at no direct capital cost to the United States Treasury.” Subparts 23.3 and 23.4 ensure contractors provide safety data for hazardous or radioactive materials and support federal compliance with environmental laws such as the Emergency Planning and Community Right-to-Know Act and the Pollution Prevention Act.

Part 24 – Protection of Privacy and Freedom of Information (09/04/2025): The FAR Council updated privacy protection requirements, revised rules on handling personally identifiable information, and clarified the applicability of the Freedom of Information Act (FOIA) to contract information. The updates also clarify what contract records are releasable under FOIA. Contractors may need to strengthen their own privacy protections to stay compliant.

Part 25 – Foreign Acquisition (09/30/2025): FAR Part 25 governs the acquisition of foreign products and services, ensuring compliance with Buy American laws, trade agreements, and other international policies. It requires preference for U.S.-made supplies and construction materials while allowing exceptions for non-availability, public interest, or unreasonable cost, and implements domestic content thresholds that increase over time. The Part also waives certain Buy American restrictions and provides nondiscriminatory treatment for eligible foreign products. Additionally, it outlines rules for contracts performed overseas, customs and duty exemptions, the use of foreign currency, and private security operations, promoting both fair competition and national security interests in international procurement.

Part 26 – Other Socioeconomic Programs (08/08/2025): FAR Part 26 clarifies procedures for the Indian Incentive Program, relying on subcontractor representations of eligibility unless challenged, with disputes referred to the Bureau of Indian Affairs (BIA) for resolution within strict timelines. It highlights the Disaster Response Registry in SAM.gov and the Emergency Procurement List, which help agencies quickly identify contractors ready to provide goods and services during emergencies. Contracting officers are also encouraged to support food donation programs, allowing contractors to donate excess wholesome food to nonprofits serving food-insecure populations. However, contractors bear full responsibility for costs, logistics, and safety, and food donations remain voluntary charitable contributions.

Part 27 – Patents, Data, and Copyrights (09/11/2025): The FAR Council streamlined Part 27 by removing lengthy policy narratives and relocating non-statutory “how-to” material, leaving a leaner core focused on statutory requirements. Contracting officers must actively oversee patent reporting, disclosure, and data rights to safeguard both government and contractor interests, ensuring proper utilization and compliance. Sections on royalties, special works, existing works, and proposal data were simplified and now direct agencies to negotiate license terms on a case-by-case basis. Core Bayh-Dole, infringement, and rights-in-data frameworks remain intact, but agencies must now specify data and license rights directly in the contract.

Part 28 – Bonds and Insurance (08/28/2025): The FAR Council modernized references, cut obsolete language, and simplified and clarified insurance and bonding requirements. Contractors may need to carry updated coverage levels. This ensures the government is better protected against financial losses, particularly in relation to construction and service contracts.

Part 29 – Taxes (07/17/2025): The FAR Council clarified how taxes are treated in pricing. They removed outdated cross-references and rewrote sections in clear, plain language.

Part 30 – Cost Accounting Standards (08/28/2025): The FAR Council revised the applicability thresholds of cost accounting standards (CAS). They clarified exemptions and waiver procedures, and they streamlined rules for better readability. The updates aim to enhance consistency in cost reporting. Contractors should prepare for increased oversight of accounting practices. To identify the cognizant federal agency official (CFAO) for a particular contract award, use the contractor’s CAGE code or contract number in the Award Management Team (AMT) section of Electronic Data Access (EDA).

Part 31 – Contract Cost Principles and Procedures (07/17/2025): The FAR Council reorganized cost principles by phase. They clarified which costs are allowable and which are unallowable, and they streamlined cost documentation requirements. Contractors must review the updated rules when developing cost proposals; failure to comply may result in rejected invoices or audits.

Part 32 – Contracting Financing (09/30/2025): Key FAR subparts include 32.007: contract financing payment instructions; 32.403: the ability of advance payments for other commercial acquisitions; 32.607: terms of collection; and 32.704: tailoring the limitations of the costs or funds clause. FAR Part 32 establishes policies and procedures for how the government provides, manages, and safeguards contract financing and payments. It covers all major financing methods, including progress, advance, performance-based, and commercial financing, as well as debt administration, funding limitations, and assignment of claims to aid private financing. The part also includes procedures for prompt and electronic funds transfer (EFT) payments, ensuring timely and secure contractor reimbursement. Additionally, it defines special programs, such as loan guarantees, expedited payment procedures, and protections against fraud or overpayments, to maintain fiscal accountability.

Part 33 – Protests, Disputes, and Appeals (08/21/2025): FAR Part 33 emphasizes that the strongest defense against protests is a clear, well-structured solicitation and strict adherence to the stated evaluation plan. Agencies are expected to safeguard trade-off evaluations by following published criteria, documenting whether proposal enhancements add value, and maintaining thorough, contemporaneous records to justify award decisions. Concise, bulleted documentation strengthens the record, while any misstatements or misrepresentations by an awardee may be referred to a suspending and debarring official. Contracting officers can reduce protest risks by providing timely debriefings and brief explanations, which start the Government Accountability Office (GAO) protest clock and avoid unnecessary extensions of the protest window. Debriefings are framed as opportunities for transparency and vendor learning, as well as for improving future solicitations. Finally, when disputes arise, contracting officers provide Boards of Contract Appeals with the necessary data and may employ Alternative Dispute Resolution (ADR) techniques to resolve issues more efficiently.

Part 34 – Major System Acquisition (05/02/2025): The FAR Council strengthened oversight requirements for large, high-dollar system acquisitions. Agencies must justify requirements more thoroughly and document risk management. This helps prevent waste in complex procurements. Contractors working on major systems should expect increased scrutiny of proposals.

Part 35 – Research and Development Contracting (07/24/2025): FAR Part 35 emphasizes that research and development (R&D) contracts differ from traditional procurements because they focus on advancing knowledge through flexible, outcome-oriented approaches rather than fixed deliverables. Part 35 strengthens oversight of R&D contracts with educational and nonprofit institutions by requiring clear roles for principal investigators, approval for changes in key personnel, and annual reviews of basic agreements to ensure alignment with government expectations. It reaffirms that the purpose of R&D contracts is to advance scientific and technical knowledge, often in areas of uncertainty, and calls for flexible contracting environments that minimize administrative burden and encourage innovation. Contract types must reflect the maturity and risk of the work, favoring cost-reimbursement contracts for exploratory projects, fixed-price level-of-effort contracts for short-term tasks, and hybrid approaches as requirements stabilize. Agencies are encouraged to craft outcome-focused requirements that define goals and milestones without prescribing methods, while requiring contracting officer approval for subcontracting of key scientific tasks to safeguard quality. Proposals are evaluated on technical merit, feasibility, innovation, and ROI, using peer reviews, scientific panels, and merit-based criteria rather than price alone. Finally, sponsoring agreements with Federally Funded Research and Development Centers (FFRDCs) establish missions, responsibilities, and restrictions on competition, with annual reviews and five-year renewals to ensure accountability and long-term success.

Part 36 – Construction and Architect-Engineer Contracts (07/24/2025): FAR Part 36 clarifies the distinction between design-bid-build (DBB) and design-build (DB) acquisitions. Under DBB, agencies issue separate contracts for design and construction, while DB integrates both into a single contract to streamline delivery. The updates emphasize the use of performance-based requirements and place greater weight on qualifications and past performance over price when evaluating design-build proposals. Part 36 expands and encourages pre-award site visits to help vendors assess conditions, reduce assumptions, and minimize costly modifications after a contract award. To strengthen competition while managing industry investment, agencies are advised to shortlist three vendors in Phase 2 of design-build procurements. Finally, Part 36 underscores the value of collaborative contract administration and experienced design-build teams, using practices such as co-location, structured partnering, and “over-the-shoulder” reviews to improve communication, reduce risk, and deliver better outcomes.

Part 37 – Service Contracting (09/25/2025): Establishes policies and procedures for acquiring and managing service contracts, emphasizing performance-based acquisition methods that focus on measurable outcomes rather than processes. It prohibits unauthorized personal services contracts and ensures contractors do not perform inherently governmental functions, maintaining clear boundaries between government and contractor roles. The Part also regulates advisory and assistance services, childcare, nonpersonal health care services, and dismantling or demolition work, requiring safeguards such as liability insurance, background checks, and labor compliance. Finally, it addresses other service considerations, including limitations on uncompensated overtime, use of temporary personnel, foreign severance payments, and continuity of critical services, ensuring efficiency, integrity, and accountability in all service acquisitions.

Part 38 – Reserved (08/14/2025): The FAR Council relocated material from this part into Part 8 and other sections. They reserved this Part for future use. Contractors should check cross-references to ensure compliance. No new rules were created, but information moved to more logical places.

Part 39 – Acquisition of Information and Communication Technology (ICT) (06/12/2025): FAR Part 39 directs agencies to strengthen strategic planning for ICT acquisitions by aligning procurements with agency technology roadmaps, federal information governance, and Office of Management and Budget (OMB) Circular A-130’s risk-based framework for security and privacy. To accelerate delivery, it promotes streamlined evaluation methods such as shorter proposals, oral presentations, and agile acquisition techniques that adapt to evolving mission needs. The rule emphasizes proactive risk management, urging agencies to use modular contracting, prototyping, and clear contract language to address risks tied to AI, cybersecurity, and supply chain vulnerabilities. Modular contracting is reinforced as a best practice, breaking large ICT projects into smaller, interoperable components that reduce risk, foster competition, and prevent vendor lock-in. Agencies are encouraged to adopt outcome-based contracting, focusing on performance metrics tied directly to mission outcomes rather than prescriptive methods to drive innovation and strengthen government-industry collaboration. Finally, the updates call for innovative solicitation and evaluation approaches such as discovery sessions, technical demonstrations, phased down-selects, and negotiated performance commitments to attract new vendors and ensure awarded solutions deliver real capability.

Part 40 – Information Security and Supply Chain Security (08/14/2025): This update focuses on cybersecurity and supply chain risk management. FAR Part 40 makes it clear: information security and supply chain integrity are now core to every phase of acquisition. For contractors, this means agencies expect more than technical capability; they want proof that your products, services, and vendors are secure, trustworthy, and resilient. Acquisition teams bring in Chief Information Security Officers (CISOs), supply chain specialists, legal counsel, and program managers to evaluate not just what you deliver, but how you source, manufacture, and safeguard it. Solicitations must increasingly include supply chain risk criteria, rewarding companies that show transparency into their supply chains, strong security architectures, and the ability to mitigate risks tied to foreign ownership, data access, or delivery reliability. Once awarded, agencies will perform ongoing oversight, random testing, code reviews, and compliance checks. For GovCon firms, the message is straightforward: integrate security into your solutions, document your supply chain practices, and be prepared to demonstrate compliance.

Part 41 – Acquisition of Utility Services (09/25/2025): This Part prescribes policies, procedures, and contract formats for the acquisition of utility services. It authorizes the General Services Administration (GSA) to oversee and delegate contracting authority for utility services, including the establishment of “areawide contracts” covering agency needs within a supplier’s franchise territory. Agencies must obtain utility services under conditions most advantageous to the government in terms of economy, efficiency, and reliability, while adhering to state laws governing electric utility service. The regulation outlines procedures for using GSA area-wide contracts, separate contracts, and interagency agreements, as well as requirements for market surveys, documentation, and GSA notifications. It also prescribes provisions, clauses, and forms to ensure compliance, rate review, and consistent management of utility service acquisitions and contracts.

Part 42 – Contract Administration and Audit Services (09/30/2025): Part 42 establishes policies and procedures for administering government contracts and conducting contract audits to ensure performance, compliance, and financial accountability. It outlines the responsibilities of the cognizant federal agency, Defense Contract Audit Agency (DCAA), and Contract Administration Offices (CAOs) for overseeing contractor systems, costs, and performance. Part 42 contains ten subparts that address contract audit, contract administration, contract administration office functions, corporate administration contracting officer functions, indirect costs rates, disallowance of costs, bankruptcy, production surveillance and reporting, novation and change-of-name agreements, suspension of work, contractor performance information, small business contract administration, and forward pricing rate agreements.

Part 43 – Contract Modifications (06/12/2025): The FAR Council simplified modification procedures, reduced text length, clarified responsibilities, and deleted redundant examples. Contractors now have clearer rights and responsibilities when modifications happen. This helps reduce disputes over scope changes.

Part 44 – Subcontracting Policies and Procedures (09/04/2025): The FAR Council simplified subcontracting requirements and updated the rules for managing subcontractors. Prime contractors must improve oversight and reporting; the changes are designed to ensure subcontractors meet performance and compliance obligations.

Part 45 – Government Property (09/11/2025): FAR Part 45 establishes that contractors provide their own property under normal circumstances unless it is in the government’s best interests to provide it. It outlines rules on liability, system compliance, and required clauses. It requires solicitations to list government-furnished property and use evaluation factors, including rental equivalents, to ensure fair competition. It governs the use, rental, and title of government property, clarifies accountability transfers between contracts, and provides detailed procedures for oversight, reporting, reutilization, transfers, abandonment, destruction, sales, and scrap management. If government property is lost under a contract, the contractor should act promptly, in consultation with the property administrator, to determine the extent of its liability based on the damage resulting from the loss. FAR Part 45 also addresses the oversight of contractor scrap disposal of government property.

Part 46 – Quality Assurance (08/21/2025): The FAR Council tightened quality assurance rules, requiring contractors to demonstrate robust quality control systems. Agencies will conduct increased inspections and audits to verify compliance.

Part 47 – Transportation (09/25/2025): FAR Part 47 establishes policies for acquiring transportation and transportation-related services, as well as for embedding traffic management into supply contracts. It prescribes clauses and procedures for stand-alone transportation/service contracts and for supply contracts’ delivery terms. It also prescribes that before initiating a new transportation or transportation-related services procurement, the government should first explore existing contracts and agreements established by agencies with specialized transportation contracting expertise. FAR Part 47 implements the Fly America Act and provides for potential disallowance when foreign carriers are used. It also implements cargo preference for ocean movements, prioritizing privately owned U.S.-flag vessels.

Part 48 – Value Engineering (08/28/2025): Part 48 streamlines the coverage of value engineering (VE). It defines VE as “a technique that serves to eliminate unnecessary acquisition, operation, or support costs without impairing essential functions or characteristics.” FAR Part 48 moved details of sharing arrangements to Part 52 and kept statutory minimums intact. It encourages contractors to suggest cost-saving or efficiency ideas.

Part 49 – Termination of Contracts (08/21/2025): FAR Part 49 emphasizes that contract terminations, whether for default or convenience, must be managed with efficiency, fairness, and minimal government liability. Contracting officers are encouraged to anticipate potential terminations by including clear clauses, documenting performance risks, and maintaining records that support defensible decisions. The updates reinforce the importance of early communication with contractors and favor negotiation or settlement to avoid costly disputes. Agencies are advised to consider partial terminations or contract restructuring as alternatives when they better protect mission needs and taxpayer resources. The guidance also stresses the timely resolution of termination claims through standardized formats and streamlined reviews. Finally, FAR Part 49 highlights close collaboration with legal, financial, and program offices to ensure compliance, reduce protest risks, and maintain continuity of mission support.

Part 50 – Extraordinary Contractual Actions and the Safety Act (07/31/2025): FAR Part 50 updates agency responsibilities under the Support Anti-terrorism by Fostering Effective Technologies Act of 2002 (SAFETY Act). When a program office determines that technology may qualify for SAFETY Act protection, it must request a pre-qualification designation notice from the Department of Homeland Security (DHS) once requirements are stable. This notice allows offerors to submit streamlined applications for SAFETY Act designation and receive expedited DHS review. The program office then provides the DHS documentation to the contracting officer for inclusion in the presolicitation notice, ensuring vendors are aware of the opportunity.

Part 51 – Resolved (08/14/2025): The FAR Council shortened this Part—they retained basic termination procedures and deleted repetitive language. Contractors should rely on new cross-references for guidance.

Part 52 – Solicitation Provisions Contract: The FAR Council refreshed standard solicitation provisions. They updated clause language for consistency and reduced the number of duplicative clauses. Updates ensure agencies use the current standard language.

Part 53 – Forms (09/30/2025): FAR Part 53 governs the use of standard, optional, and agency and acquisition forms. It defines “exception,” and points users to Parts 1–52 for specific forms. It centralizes the forms list at acquisition.gov/FARforms and allows continuation sheets with proper references and page numbering. Agencies must obtain exceptions from the prescribing authority (FAR Council for SFs), but computer-generated versions are permitted if the data elements and identifiers remain unchanged or are in ANSI X12–X12-compatible formats.

Conclusion

Plan early. Engage intelligently. Write with precision and purpose. The FAR Overhaul rewards teams that adapt fast, communicate clearly, and align every proposal element with the government’s evolving priorities. Lohfeld Consulting can help you craft capture strategies that win on contract vehicles, translate Sections L and M into evaluator-friendly language, and secure strengths. Partner with us and turn your FAR knowledge into a competitive advantage.

Relevant Information

Please refer to our previous blogs for deeper dives into selected FAR Part Changes:

• How to survive and thrive under FAR changes
• Far Part 1 Changes
• FAR Part 6 Changes
• FAR Part 10 Changes
• FAR Part 11 Changes
• FAR Part 18 Changes
• FAR Part 34 Changes
• FAR Part 39 Changes
• FAR Part 43 Changes

By Brenda Crist, Vice President at Lohfeld Consulting Group, MPA, CPP APMP Fellow

Lohfeld Consulting Group has proven results specializing in helping companies create winning captures and proposals. As the premier capture and proposal services consulting firm focused exclusively on government markets, we provide expert assistance to government contractors in Capture Planning and Strategy, Proposal Management and Writing, Capture and Proposal Process and Infrastructure, and Training. In the last 3 years, we’ve supported over 550 proposals winning more than $170B for our clients—including the Top 10 government contractors. Lohfeld Consulting Group is your “go-to” capture and proposal source! Start winning by contacting us at www.lohfeldconsulting.com and join us on LinkedIn, Facebook, and YouTube^(TM).