Program Management

Government furnished property: the equipment you never bought and still answer for

The rules on GFP didn't change in 2026, but the way they reach your contract did, so check which version you're under.

TL;DR. You never paid for the Government's equipment, but you still have to account for every piece of it, like borrowing a neighbor's lawnmower and getting audited on the blades.

  • Property manager or program lead? The core GFP rules are unchanged in 2026. What changed is the version of the text your contracting officer uses, so confirm which one your contract follows.
  • Holding the same item on two contracts? Government property can be accountable to only one contract at a time. Fix any overlap before someone else finds it.
  • Signing more fixed-price work? Read the risk of loss language carefully, because more fixed-price awards may push more of that risk onto you.
  • Want a head start? Copy the property check table below and fill it out for each contract.

You hold it, they own it, you answer for it

Government furnished property (GFP) is anything the Government hands you to do the work: test equipment, tooling, vehicles, materials. The basic deal is simple. Contractors normally supply their own property, and the Government provides some only when it's clearly in the Government's interest. When it does, the Government keeps title until the item is properly disposed of.

That last part trips people up. You don't own it, so it's tempting to treat it as someone else's problem. But you're the one holding it, and that makes you the one who has to track it, protect it and report on it through your property management system. Think of it as a library book with a very serious late fee.

So what: Treat every GFP item as if your name is on it, because for accountability purposes, it is.

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The rulebook changed packaging, not contents

Since March 16, 2026, contracting officers have been using a rewritten version of FAR Part 45 and a rewritten DFARS Part 245 under DoD Class Deviation 2026-O0046. The old codified text still sits underneath, unchanged. This follows the executive order on restoring common sense to federal procurement.

The good news is that the rewrite looks light. Wiley's tracker calls the Part 45 changes minimal: plainer language, "shall" swapped for "must," and some procedural material moved into the non-binding FAR Companion. A separate analysis from WARU says the property clauses weren't changed and day-to-day practice stays the same.

The wrinkle is the revision history. DPCAP's class deviation page now lists "Revision 1" dated September 9, 2026. A third-party tracker shows a different date, and I couldn't open the Revision 1 text to see what changed. So don't assume it's cosmetic. Pull it up and compare.

Key insight: The question isn't "did the property rules change?" It's "which version of the rules does my contract actually use?" Inside Government Contracts flagged this back in May, and the answer can differ from contract to contract.

Mar 16, 2026 Part 45 and 245 deviation takes effect Jun 23, 2026 FAR rewrite Phase 2 proposed rules begin Jul 15, 2026 Fixed-price default deviation, Revision 1 Sep 9, 2026 DPCAP lists Revision 1 of the property deviation Oct 19, 2026 Comments due on second proposed rule set
The 2026 dates that matter for GFP: a deviation in March, a revision in September, comments due soon.

One item, one contract, one at a time

Here's a rule that sounds obvious until you're running three contracts out of one shop. DoD guidance says Government property must be accountable to a single contract, and only one contract at a time. That applies to GFP and to property you acquired for the Government.

In practice, the trouble starts when a tool gets "borrowed" across programs because it was sitting idle. Informal sharing feels efficient, but your records then show one item serving two masters. If you need to move something, get the paperwork moved first, not after.

So what: Walk your floor and match each item to exactly one contract number. Any item with two answers needs a conversation with your contracting officer.

The fixed-price wrinkle

A newer executive order makes fixed-price contracts the default, and DoD is implementing it through Class Deviation 2026-O0045, Revision 1, issued July 15, 2026. That's not a property rule on its face.

Here's my read, and it's analysis, not a sourced finding. On fixed-price contracts with progress or performance-based payments, risk of loss for Government property has historically leaned toward the contractor. If more of your work moves to fixed-price, more of your GFP could carry that risk. A missing or damaged item could then become your cost, not a pass-through.

So what: Before you sign, find the risk of loss language and ask your insurance and finance folks whether you're covered for property you don't own.

Copy this: the GFP property check

Fill out one of these per contract. It takes an hour and beats finding the gaps during a review.

CheckWhat to write downWhy it matters
Governing textCodified FAR/DFARS or the deviated version, with the revision dateYour obligations come from the version in your contract
Accountable contractOne contract number per itemProperty can sit on only one contract at a time
Item and sourceDescription, ID or tag, who furnished it, date receivedProves what you were given and when
TitleConfirm "Government retains title"You can't sell, scrap or trade it on your own
Custodian and locationNamed person and physical locationSomeone specific should be able to find it
Risk of lossContract type and payment method, plus any loss languageFixed-price work may shift loss risk toward you
Disposal statusIn use, excess, or awaiting instructionsOnly proper disposal ends your accountability
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What to do before October 19

Part 45 hasn't shown up in the FAR rewrite proposed rules I found, so I can't tell you when formal rulemaking arrives. I did see that the FAR Council is asking for comment on reorganizing and renumbering Part 52 clauses, with comments due October 19, 2026. If your property clauses move or get renumbered, your internal procedures may need new references.

  • Open Class Deviation 2026-O0046, Revision 1 on the DPCAP page and compare it with the March version.
  • Confirm with each contracting officer which version of Part 45 and Part 245 applies.
  • Run the property check table on your biggest GFP contract first.
  • Review any fixed-price award for risk of loss language.

One caveat: I didn't find GAO protests, audit reports or enforcement data on GFP for this post, so I won't pretend to know how reviewers are behaving. The safest assumption is the old one: if you hold it, you're expected to know where it is.

GFP Accountability Checklist

CheckWhy It MattersWhere It LivesWho Owns It
Is every item on the GFP attachment?Property not listed is not authorizedContract attachmentPM with the CO
Is it in your property system of record?An approved system is a contract requirementProperty management systemProperty administrator
Are loss, damage and destruction reported?Unreported loss becomes your liabilityWritten notice to the PA and COPM
Is disposition instructed in writing?Returning or scrapping without direction is a findingPlant clearanceProperty administrator

Drafted with AI from public sources. Spot a mistake? Email lucas@acqlerate.com and I'll fix it.

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