FAR Overhaul Timeline: 2026 Changes & 2027 GovCon Outlook

The Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) is the most significant rewrite of federal procurement rules in 40 years, and it’s moving faster than most GovCon teams can track. From executive orders to class deviations to formal rulemaking, the changes already on the books, along with those still coming in 2027, will reshape how your team competes. Business development, capture, and proposal teams that track the timeline closely will make faster, better-informed decisions.
Summarizing the FAR Overhaul Changes
The Revolutionary FAR Overhaul began on April 15, 2025, when the president signed Executive Order (EO) 14275, “Restoring Common Sense to Federal Procurement.” With a stated goal of removing non-statutory requirements and returning the regulation to its statutory roots, the order directs the Office of Federal Procurement Policy (OFPP) Administrator, in coordination with the FAR Council, to amend the FAR within 180 days. The Office of Management and Budget (OMB) followed with Memo M-25-26, which established the Strategic Acquisition Guidance (SAG) framework and set an agency testing window from July 15, 2025, through January 15, 2027.
Beginning May 2, 2025, the FAR Council published model deviation text part by part, and agencies adopted the changes on a rolling basis. By early August 2025, 31 agencies had issued deviations. The FAR Council closed out its final governmentwide deviation batch, covering FAR Parts 2 and 52, in October 2025. The Department of Defense followed with its own final batch, covering FAR Parts 8, 15, 16, 42, 45, and 47, through Defense Pricing, Contracting, and Acquisition Policy (DPCAP) in March 2026. This phase operated outside the formal rulemaking process, allowing agencies to move quickly but leaving the changes without the permanence of a finalized rule. On October 30, 2025, the government published the FAR Companion Guide 2.0, offering practical advice for planning, awarding, managing, and closing out contracts consistent with the FAR’s core buying principles.
Formal rulemaking began on June 23, 2026, when the FAR Council published its first set of proposed rules in the Federal Register. Four rules spanning 20 unique parts moved the overhaul from administrative deviations into binding notice-and-comment rulemaking. This shift matters enormously for GovCon companies. Deviations can be adjusted or reversed with relative ease, whereas formal rules, once finalized, carry the weight of the FAR itself.
Impact of 2026 FAR Overhaul Changes
The most recent rulemaking batch touches the parts of the FAR that most directly shape how bid and proposal professionals do their work.
- FAR Part 33 governs bid protests and would allow protesters to obtain a redacted technical evaluation and source selection decision during independent agency-level reviews. Agency-level protests have historically been a faster, less expensive forum than a formal protest filed with the Government Accountability Office (GAO). Under the proposed rule, protesters could use that insight to raise new grounds for protest, making agency-level review a genuine strategic option. Bid and proposal professionals should be aware that contracting officers have access to AI tools, such as AlphaSix’s Quantify, to help produce stronger RFPs less prone to protests, as described in our blog, How AI Acquisition Tools Are Reshaping Your Bids Now.
- Security and supply chain requirementsare consolidated under FAR Part 40, which combines Controlled Unclassified Information (CUI), Section 889 restrictions on covered telecommunications equipment, the Federal Acquisition Supply Chain Security Act (FASCSA), and prohibitions on covered foreign technology into a single, expanded part. Proposal teams juggling agency-specific interpretations of these requirements should see a more uniform standard once the rule is finalized.
- Information technology (IT) compliancebroadens under FAR Part 39, which expands the scope from IT to any acquisition that uses information and communication technology (ICT). This broadens the pool of solicitations that compliance teams need to screen for these requirements.
- Registration burdenshrinks under FAR Part 4, which trims System for Award Management (SAM) requirements by roughly half, a welcome reduction for teams managing representations and certifications across multiple entities.
The comment period for this batch closed on July 23, 2026.
Outlook for 2027 FAR Overhaul Changes
Formal rulemaking hasn’t reached Parts 12, 13, 15, or 19 yet, but the class deviations already in effect provide a strong preview of where the final rules are headed.
- Source selection standardsunder FAR Part 15 retain the four competitive source selection approaches already in the deviation text, including Highest Technically Rated with a Fair and Reasonable Price (HTR-FRP). They also clarify that a lack of relevant past performance cannot be scored favorably or unfavorably but must be assessed only for currency and relevance.
- Commercial acquisition proceduresunder FAR Part 12 absorb the simplified acquisition procedures from Part 13, eliminate roughly 30% of existing provisions and clauses, including the standard representations and certifications at FAR 52.212-3, and grant contracting officers discretion to accept late quotes or proposals.
- Small-business rules under FAR Part 19 carry forward updates and a revised Mentor-Protégé policy. At the same time, a related change in FAR Part 42 removes the restriction limiting past-performance write-ups to source selection use only. Contractor Performance Assessment Reporting System (CPARS) and past-performance data can now support business development throughout the acquisition lifecycle, rather than just a specific bid.
Until these parts move through formal rulemaking, companies bidding under current solicitations are effectively operating under a hybrid system: part legacy FAR, part class deviation, and part finalized rule.
OMB’s SAG testing and reporting window closes on January 15, 2027. That date marks the point at which agencies are expected to move beyond pilot testing and fully absorb the FAR Overhaul into standard acquisition practice. For capture teams building pipelines toward future indefinite-delivery, indefinite-quantity (IDIQ) contracts, that date is a useful planning horizon. Companies that position their qualifications, certifications, and past performance against the emerging rules now will be better positioned than competitors who wait for the dust to settle.
Conclusion
The Revolutionary FAR Overhaul has progressed from EO to binding rulemaking in just over a year, and the pace shows no sign of slowing. Lohfeld Consulting helps GovCon companies interpret each FAR Overhaul milestone and adapt capture and proposal processes accordingly. Contact us to learn how we can help your team stay ahead of the FAR Overhaul and adapt your proposals to the changes.
Continue Reading
Deepen your understanding of the FAR Overhaul with these Lohfeld Consulting resources:
- How AI Acquisition Tools Are Reshaping Your Bids Now: A look at how tools such as AlphaSix’s Quantify are changing source selection and what proposal teams should do to stay ahead of AI-informed evaluation.
- How to Decode Section M Evaluation Criteria: Learn how senior proposal managers read Section M for strategic intelligence—not just compliance—and use it to shape a sharper win strategy.
- How to Use Free GovCon Intel to Supercharge Capture Now: All 100 of the government websites, news sources, LinkedIn content, books, podcasts, and YouTube channels listed in our companion article, 100 Top GovCon Intel Sources to Keep You Updated, are mapped to a five-step intelligence workflow that you can execute to supercharge intelligence collection and analysis.
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).
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