It’s not the first time and it won’t be the last time the Federal Acquisition Regulation (FAR) comes under fire for revision. As of April 15, 2025, President Trump signed the Executive Order (EO) Restoring Common Sense to Federal Procurement, directing the removal of unnecessary barriers and regulations in the FAR. This is in addition to various other previously released EOs that also purport to change how the government buys services and items. Different agencies and offices will be taking various actions within the EO’s mandated 180 days. While the EO is quite clear on the challenges federal procurements currently face and the reasons for issuing the EO, how Sections 4 and 5 are implemented will be key for government contractors and government procurement teams.
In May 2025, the FAR Overhaul webpage was released to the world. Along with the release, the government started calling the project the Revolutionary FAR Overhaul (RFO) initiative. Others have been calling this the FAR 2.0 Rewrite.
The first RFO areas up for review are FAR Part 1 (Federal Acquisition Regulation System) and FAR Part 34 (Major System Acquisition), places in the FAR that many government contractors breeze past reading. Particularly for FAR Part 1, many commercial teams wishing to break into the government world should be reading this part to better understand why acquisition can be so long, brittle, and part of an intricate song & dance that must conform to regulations, requirements and processes. Then perhaps they’ll see why long-time FAR veterans are eagerly waiting for a more open and flexible FAR in lieu of the current slow pomp and circumstance, “awaiting clearance to proceed from the chain of command.”
Shortly after the webpage was released, the General Services Administration issued two class deviations (CD-2025-09 for FAR Part 1 & CD-2025-10 for FAR Part 34), signaling the intent to use this guidance while pending final conformed copies of the FAR being posted to Acquisition.gov. Clearly, the government is continuing to move to complete a few actions against the EO’s clock.
Government contractor impact
But what does this mean for government contractors? Should they be reading all the buying guides? Should they run to their nearest and dearest lobbyist to ask for help? Should they pretend nothing is happening? Navigating a living document filled with strikethroughs, drafts and inter-agency coordination steps is no easy task. It’s an exercise in controlled chaos. Over the next few months, supply chain complexities are likely to add to the known lurking administrative acquisition challenges.
If they haven’t already done so, government contractors should be reading their previously awarded contracts and any modifications very carefully. Experienced contract managers should be able to pick out central themes and clause areas ripe for change to proactively predict what the government might throw at them over the next few months via administrative modifications. Some of these may be unilateral and some may be bilateral, with the government asking for consideration for the reduction in compliance clauses/administrative overhead to keep a contract ongoing.
Have a proposal in with a required pre-award on-site equal opportunity compliance evaluation? It’s unlikely to be enforced but may still lag in the proposal and pre-award process while contracting officers figure out if/how they must document ghost requirements. Redoing your system for award management (SAM) representations and certifications? Be prepared for a system note that may prompt or override required compliance topic areas with various offeror representation and certification. Performing as a prime, but have a commercial subcontractor performing on the contract? Expect the required subcontract flowdowns for commercial products and services to change soon. For government contractors, the priority right now is quite clear. Read everything thoroughly and remain compliant with the contract terms and conditions.
Why the RFO shouldn’t happen without investing in people
In spite of all the transactional changes that can happen through the EO and the following activities, those who have been steeped in federal contracting since the beginning know that acquisition workers must be treated and trained to be critical thinkers. We’ve had Pathways to Transformation, DAWIA Modernization (Basics), Balanced Workforce Strategy, Better Buying Power, etc. — efforts that advocated for reforms of the industrial base workforce. Better procurement requires and craves efficient government and industry workers.
This doesn’t mean sending a procurement official to an online training course or a click-through PowerPoint about the Buying Guide. We have universities. We have on-the-job training. We have courses. We have warrants and certifications. None have yet turned the tides on preparing the acquisition workforce to challenge the requirement, argue why a process still exists, or take risk if sound business judgment is being used.
Today, nothing in a contracting specialist or manager’s toolkit gives them comfort or care that even if a decision proves unsuccessful (like the Delaware business judgment rule), that they are safe from at-will termination or career regression. Arm these folks with acknowledgment that they are shielded from liability and career punishment for decisions made with due diligence and in good faith. Reward those acquisition staff members that don’t ask poor questions and who can communicate clearly. Also expect and require more out of the staff being invested in and trained, including variations of teaching methods. Go back to the days of including various Socratic methods that will require acquisition professionals to use logical defending of their thoughts and positions on contracting and procurement topics.
So will the RFO be a success?
Only time will tell if this next bite at the apple will finally reform the FAR and transform the workforce. Having a struck out FAR only provides the computer ones and zeroes that turn into words that can be accessed online. The problems that exist between the keyboard and the chair won’t also be reformed. If we continue to neglect the investment in shaping the minds and challenging both industry and government contracting workforces, the status quo and culture is likely to remain. The RFO will tout statistics about how many words it removed from a book while the checklist and signoff-based acquisition system clunks onwards. But those who can read, think and apply professional judgment in grey situations just might see the blossoming of some changes to a system that will allow them flexibility and an ability to focus on meaningful acquisition issues to solve instead of mountains of paperwork and memorandums.
Jennifer Ogren specializes in federal and commercial contracting, global compliance, and overseeing legal operations with 20+ years at various defense, rocket and satellite companies. She holds dual masters degrees in the study of law and applied information management.
The post Bluster or brilliance: Browsing the FAR 2.0 rewrite first appeared on Federal News Network.