TL;DR. The FAR is being rewritten while everyone is still using it. Think of it as a plane being rebuilt in flight, except you still have to land your contract on time.
- New to this? The rewrite cuts the FAR back to what the law requires. The purpose of each rule stays; the paragraph numbers move.
- Bidding DoD work? Since February 1, 2026, most DoD solicitations use the rewritten FAR and DFARS. Rebuild your clause matrix. (Yes, 52.204-21 is now 52.240-93.)
- Small business? The Rule of Two survived, but set-asides on orders under multiple-award contracts are now discretionary and not protestable. Comments on the latest proposed rules close October 19.
- Government PM? Ask your contracting officer which RFO deviations your office adopted, then read the Practitioner Album for the parts you lean on.
What the RFO is, in 60 seconds
In April 2025, Executive Order 14275 told the FAR Council to shrink the Federal Acquisition Regulation to what statute requires, plus whatever actually makes the system work better. That effort is the Revolutionary FAR Overhaul, or RFO. It is the first top-to-bottom rewrite since the FAR was born in 1984.
It runs in two phases. First, the FAR Council published rewritten text for each part as a model deviation, and each agency switched it on through its own class deviation. Second, the rewritten parts go through normal rulemaking so they become the permanent FAR.
The catch: nobody stopped buying while this happened. So the skill that matters is not memorizing the new FAR. It is knowing which version governs the contract in front of you.
Where things stand right now
| Piece | Status (September 2026) |
|---|---|
| Model deviations | Issued for essentially every FAR part during 2025 |
| DoD (Department of War) adoption | Most rewritten FAR and DFARS text effective February 1, 2026 |
| Proposed rules, set 1 | Published June 23, 2026; comments closed July 23 |
| Proposed rules, set 2 | Published September 18, 2026 (Parts 8, 12 to 17, 27, 28, 35, 36, 38, 44, 47, 51); comments due October 19 |
| Sets 3 and 4 | Still to come, then final rules |
| FAR Companion | Non-binding guidance, version 2.0, updated as parts change |
Treat every date and number in that table as "verify before you rely on it." That is not us hedging. That is the whole lesson of this period.
What actually changed for contractors
Most of the rewrite is deletion and reorganization. The statutes underneath (competition, truth in negotiations, cost accounting standards, procurement integrity, the small business programs) did not move, because a regulation cannot repeal a law. But a few changes land directly on your desk:
- Cyber and security clauses moved. They left 52.204 for a new Part 40 and a 52.240 series. Basic safeguarding is now 52.240-93. On the DoD side, DFARS 252.204-7019 was deleted and 7020 became 252.240-7997. Your compliance matrix and your subcontract flowdowns probably still cite the old numbers.
- The Rule of Two got looser at the edges. It still applies, but contracting officers no longer have to rank the socioeconomic set-asides ahead of plain small business, and setting aside an order under a multiple-award contract is now a judgment call nobody can protest.
- Size rerepresentation on orders is in limbo. The RFO text removes it; SBA's own regulations still allow it. Follow what each order asks and keep a record.
- More lives in SAM. Representations moved toward the entity level, so your annual SAM certifications carry even more weight. Read every one. Yes, all of them.
The free resources, ranked by usefulness
The Warfighting Acquisition University (WarU, the renamed DAU) organized an entire "RFO Learning Cycle," and most of it is open to industry. You do not need all of it. Here is the order we would go in:
1. Practitioner Albums on Acquisition.gov. One per FAR part: a summary of what changed and a line-out of what was deleted. The fastest way to update your mental model.
2. The FAR Companion. Non-binding advice for contracting officers on using their new discretion. For a contractor, it is a look at what the buyer across the table has been told.
3. ACQ 0330, Guide to the Revolutionary FAR Overhaul. WarU's foundation course, released August 2026.
4. The rest, as needed. One-day RFO workshops, FAR Forward Open Office Hours (FAI and GSA), the weekly CONNECT Live webinar on Thursdays, a side-by-side comparison tool, and a community of practice. Some WarU training needs a government account.
The one habit that keeps you safe
Before you cite any clause number, threshold, or procedure, ask: which version of the FAR governs this solicitation? The answer usually comes down to the solicitation date and whether the buying agency had adopted the deviation for that part by then. If Section I mixes old and new clause numbers, someone copied a template. Ask during the question period. It goes on the record and protects everyone.
Then keep a dated clause matrix for each contract. In this period, a matrix without a date is a guess.
Comment while it is cheap
The proposed rules are open for comment, and SBA's Office of Advocacy is specifically asking small businesses for input. A comment that says "this change costs my company this much, for this concrete reason" carries real weight. The window for the second set closes October 19, 2026. It is the cheapest influence you will ever have over rules you will live with for a decade.
Frequently asked questions
Is the old FAR still in effect?
For some acquisitions, yes. The published FAR still exists until final rules replace it, but agencies that adopted RFO class deviations use the rewritten text instead. For most DoD solicitations issued after February 1, 2026, that means the rewritten version. Check the solicitation.
Does the overhaul change my existing contract?
Generally not by itself. A contract keeps the clauses it was awarded with until a modification changes them. Watch for modifications that swap in new clauses, and read them before you sign.
Is the FAR Companion binding?
No. It is guidance for contracting officers. Useful for understanding their thinking, but no one can hold you to it.
What is WarU?
The Warfighting Acquisition University, which is the Defense Acquisition University under its November 2025 name. It runs most of the government's RFO training.
Where can I learn this properly without a government account?
Our free Foundations module now includes a full lesson on the RFO: the phases, what changed, how to read a solicitation during the transition, and a quiz to check yourself. No credit card required.
Sources: Acquisition.gov FAR Overhaul, Federal Register (June 23, 2026), SBA Office of Advocacy (September 21, 2026), WarU RFO resources. Not legal advice; verify current text before citing it.