If you follow federal contracting, you know that the Federal Acquisition Regulation (FAR) is the rulebook we all live by. But anyone who has read through the FAR knows it can be overwhelming because of the dense language, overlapping sections, and sometimes requirements that feel more like paperwork than real guidance. That’s why the Revolutionary FAR Overhaul (RFO) project has been in the works: to modernize the FAR, make it clearer, and shift away from prescriptive checklists toward outcome-based, plain-language rules.
GSA, in its latest update, has issued class deviations that make the RFO versions of FAR Parts 7, 24, and 44 live for use in acquisition. These deviations go into effect on November 3, 2025, giving contracting officers the option to apply the new model text instead of the legacy FAR. This is a significant update because these three parts touch the daily work of agencies, prime contractors, and subcontractors alike.
So, what changed? Let’s break it down.
FAR Part 7 - Acquisition Planning
Part 7 is one of the most widely used parts of the FAR. It guides how agencies plan for contracts, including the requirement for written acquisition plans, small business considerations, and decisions like lease vs. purchase.
What’s new in the RFO version?
- More flexible planning: Instead of one-size-fits-all checklists, the text now emphasizes that planning should be scaled to the size, complexity, and risk of the acquisition. For smaller task orders, less detail is needed; for large, high-risk contracts, more structure still applies.
- Bundling and consolidation simplified: Small-business considerations from the old Part 10 are folded in. Analysis requirements for bundling and consolidation are consolidated into one section.
- Plain-language refresh: Terminology has been modernized. Think “teleworking” instead of older phrasing, and sections rewritten for readability.
- Streamlined responsibilities: Agency head responsibilities (7.103) are shorter, clearer, and easier to follow.
What’s been removed?
- Contents of Written Acquisition Plans (7.105). The detailed template has been deleted. Instead, this kind of instruction will appear in the new FAR Companion, which is designed for practical “how-to” guidance.
- Contractor vs. Government performance (Subpart 7.3). Since OMB Circular A-76 has been suspended for years, this section is now reserved.
- Old clauses. Clauses like 52.207-1 through 52.207-3 have been retired, while 52.207-4 through 52.207-6 remain in place.
Impact: Acquisition planning becomes less about filling in a mandatory form and more about tailoring the plan to fit the need. This could mean less administrative burden for contracting officers and more thoughtful planning aligned to mission outcomes.
FAR Part 24 - Protection of Privacy and Freedom of Information
Part 24 is smaller, but critical. It implements the Privacy Act and FOIA obligations in contracting.
What’s new in the RFO version?
- Minimal changes: The part has been rewritten in plain language, but the statutory backbone remains the same.
- Privacy training streamlined: Section 24.301, which required agencies to provide training, is deleted because the same requirement already exists in clause 52.224-3.
Impact: This is more of a cleanup than a rewrite. Contractors and agencies should notice little operational change, but the text is now easier to navigate.
FAR Part 44 - Subcontracting Policies and Procedures
Part 44 is where things get interesting for primes and subcontractors. It governs consent to subcontract, purchasing system reviews, and flowdown requirements.
What’s new in the RFO version?
- Reorganized structure: Subparts are reshuffled into a cleaner flow: evaluation and award, post-award administration, and commercial items.
- Simplified consent to subcontract: The old 13-point checklist has been replaced with a higher-level test. The detailed “how-to” will now be carried in the FAR Companion, not the regulation itself.
- Commercial products/services: Flowdown requirements are clearer. Sections are reorganized into categories - preferences, required flowdowns, and inapplicable laws.
- ACO designation dropped. Instead of calling out Administrative Contracting Officers separately, the text just uses “Contracting Officer” for consistency.
Clauses retained or updated:
- 52.244-2 (Subcontracts) remains in place, with updated references.
- 52.244-4 (Architect-Engineer Associates & Consultants) and 52.244-5 (Competition in Subcontracting) are unchanged.
- 52.244-6 (Subcontracts for Commercial Products and Services) is retained, with cross-reference cleanups.
- 52.244-1 and 52.244-3 are reserved (retired).
Impact: This is a shift away from rigid rules toward flexibility. Contractors may face fewer prescriptive requirements in consent reviews and CPSRs (Contractor Purchasing System Reviews). But responsibility shifts: contractors will need to exercise judgment, with COs relying more on business outcomes than on checkboxes.
Why This Matters
The FAR Overhaul is not just a style edit. It’s a cultural shift in acquisition. By removing overly prescriptive detail from the FAR itself and moving it into a supporting “FAR Companion,” the regulation becomes leaner, clearer, and easier to navigate. Agencies and contractors get more flexibility, but also more responsibility to apply judgment.
For contractors, especially small businesses and subcontractors, this could mean:
- Faster and simpler acquisition planning processes.
- Clearer expectations in privacy and FOIA compliance.
- More streamlined subcontracting procedures, reducing the administrative burden of CPSRs and consent reviews.
For agencies, it means:
- Less time spent filling in templates.
- More time aligning acquisitions with mission needs.
- Clearer, outcome-driven language that can adapt to new technologies and business practices.
Change in federal procurement rarely comes quickly, but this is one of the most significant updates in years. For now, agencies and contractors alike should start familiarizing themselves with these deviations. November 3, 2025, is around the corner, and these changes will soon be part of day-to-day acquisition.
Additional Resources
FAR Overhaul - FAR Part Deviation Guidance | Acquisition.GOV
GSA_RFO_Deviation_Part-7.pdf
GSA_RFO_Deviation_Part-24.pdf
GSA_RFO_Deviation_Part-44.pdf