On April 15, 2025, President Trump issued an executive order, Restoring Common Sense to Federal Procurement, aimed at streamlining federal procurement. The Executive Order called for reforming the Federal Acquisition Regulation (“FAR”), the regulations that form the structure of most of the $1.5 trillion the federal government spends on contracts annually. Following the Executive Order, the Office of Management and Budget (“OMB”) issued guidance laying out expectations for the new FAR, and the Federal Acquisition Regulatory Council (“FARC”) began issuing new versions of various FAR clauses throughout the summer, with more rolling out in the coming weeks.
When a new version is issued, various federal agencies are issuing class deviations adopting those provisions prospectively. That means existing contracts will not be impacted by these new provisions unless the existing contracts are modified to insert the new version of a clause. Companies with existing contracts should still expect the previous version of the FAR to be applicable to their contracts.
This is not the end of the story, however. The adoption of a class-deviated version of a FAR clause does not mean that version will be the version of the FAR clause we should expect to see over the next few decades. Instead, the FARC has announced that there will be a notice and comment period for each FAR part that they are seeking to modify. The various parts of the FAR will be posted to the Federal Register, and the general public will have a period of time to offer comments to them. After that, the FARC and OMB will review the comments and issue final versions of the new FAR sections.
While this blog does not focus on the changes to the FAR (we expect future blog posts to do that), it does appear that the changes are mostly aimed at deleting provisions that are not statutorily required or helpful to the effective administration of government contracts (in the government’s view). The deleted provisions are largely being shuffled to practitioner guides and will be “guidance” instead of requirements. In other words, the FAR is slimming down, but provisions, for the most part, are not changing.
In the end, companies with existing contracts should stay the course, but be aware, moving forward, new provisions of the FAR will impact solicitations and contracts.
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