DFARS Overhaul Class Deviations

On December 18, 2025, the Department of Defense/War (DOD/W) began the process of “overhauling” the Defense Federal Acquisition Supplement (DFARS). The DFARS overhaul is in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, Executive Order 14265, Modernizing Defense Acquisitions and Spurring Innovation in the Defense Industrial Base, and the Department’s Acquisition Transformation Strategy: Rebuilding the Arsenal of Freedom.  Like the overhaul of the Federal Acquisition Regulation (FAR), the overhaul of the DFARS is occurring in two phases: (1) issuance of class deviations to implement each revised DFARS Part, with an effective date of February 1, 2026; and (2) notice-and-comment rulemaking, after issuance of the class deviations, to finalize the revised DFARS. In addition, DOD/W will adopt the overhauled FAR via class deviation as of February 1, 2026.

The December 18 announcement was accompanied by overhauls of 31 DFARS Parts. The Department posted additional updated DFARS Parts on January 12, 20, 21, and 23 and intends to revise the remaining Parts by the end of January 2026. The overhauled Parts each have a class deviation memo, a revised version of the DFARS Part, and a line out of the DFARS Procedures, Guidance, and Information (PGI), if applicable to the specific Part. Unlike the Revolutionary FAR Overhaul, there are no Practitioner Albums or explanations of changes that accompany the overhauled DFARS Parts. 

As a companion to our FAR Overhaul Class Deviations site, we are created the DFARS Overhaul Class Deviations site. Our site will include a summary of each DFARS Part, highlighting those issues that are of most relevance to defense contractors.  We will continue to update the site as we work through the revised DFARS Parts to provide a one-stop shop for understanding the DFARS overhaul.

Table of Contents - Summary of Overhauled DFARS Parts

DFARS Part 201 (Federal Acquisition Regulations System)
DFARS Part 203 (Improper Business Practices and Personal Conflicts of Interest)
DFARS 204 (Administrative and Information Matters) 
DFARS Part 205 (Publicizing Contract Actions)
DFARS Part 206 (Competition Requirements)
DFARS Part 207 (Acquisition Planning)
DFARS Part 208 (Required Sources of Supplies and Services)
DFARS Part 209 (Contractor Qualifications)
DFARS Part 210 (Market Research)
DFARS Part 211 (Describing Agency Needs)
DFARS Part 212 (Acquisition of Commercial Products and Commercial Services)
DFARS Part 213 (Simplified Acquisition Procedures)
DFARS Part 214 (Sealed Bidding)
DFARS Part 215 (Contracting by Negotiation)
DFARS Part 216 (Selecting Contract Types)
DFARS Part 217 (Special Contracting Methods)
DFARS Part 218 (Emergency Acquisitions)
DFARS Part 219 (Small Business Programs)
DFARS Part 220 (Reserved in the original DFARS)
DFARS Part 221 (Reserved in the original DFARS)
DFARS Part 222 (Application of Labor Laws to Government Acquisitions) 
DFARS Part 223 Environment, Sustainable Acquisition, and Material Safety)
DFARS Part 224 (Protection of Privacy and Freedom of Information) 
DFARS Part 225 (Foreign Acquisition)
DFARS Part 226 (Other Socioeconomic Programs) 
DFARS Part 227 (Patent, Data, and Copyrights)
DFARS Part 228 (Bonds and Insurance) 
DFARS Part 229 (Taxes)
DFARS Part 230 (Cost Accounting Standards Administration)
DFARS Part 231 (Contract Cost Principles and Procedures)
DFARS Part 232 (Contract Financing)
DFARS Part 233 (Protests, Disputes, and Appeals)
DFARS Part 234 (Major System Acquisition)
DFARS Part 235 (Research and Development Contracting)
DFARS Part 236 (Construction and Architect — Engineer Contracts)
DFARS Part 237 (Service Contracting) 
DFARS Part 238 (Reserved in the original DFARS)
DFARS Part 239 (Acquisition of Information Technology)
DFARS Part 240 (Information Security and Supply Chain Security)
DFARS Part 242 (Contract Administration)
DFARS Part 241 (Acquisition of Utility Services)
DFARS Part 243 (Contract Modifications
DFARS Part 244 (Subcontracting Policies and Procedures)
DFARS Part 245 (Government Property)
DFARS Part 246 (Quality Assurance)
DFARS Part 247 (Transportation)
DFARS Part 248 (Part 248 is reserved in the original DFARS. The DFARS overhaul of this Part is limited to a class deviation memo instructing use of the overhauled version of FAR Part 48.) 
DFARS Part 249 (Termination of Contracts)
DFARS Part 250 (Extraordinary Contractual Actions) 
Part 251 (Use of Government Sources By Contractors) has been folded into Part 208, similar to how FAR Part 51 is combined into FAR Part 8)
DFARS Part 252 (As DOD overhauls each substantive DFARS Part, the class deviation text of that Part includes the implementing Part 252 clauses, either in their original form or as overhauled.)
DFARS Part 270 (Defense Contracting Programs)

Summary of Overhauled FAR Parts

DFARS Part 201 (Federal Acquisition Regulations System) - Updated September 11, 2026

The rewrite of DFARS Part 201 is less about changing contractor obligations directly and more about reorganizing the Part: It streamlines, renumbers, and moves granular procedural content out of the regulation text (often to Procedures, Guidance and Information (PGIs)), while adding a few clarifying rules. Some of the numbering is awkward as a result (e.g., DFARS 201.101 starts with paragraph (a)(2)).

• Commercial products/services applicability clarification: New 201.107 “FAR conventions” states that if a DFARS clause or provision prescription is silent with respect to commercial products and services, it does not apply to them and clarifies that Commercial-Off-the-Shelf (COTS) items are, indeed, commercial. 
• Publication/official source language modernized: The rewrite adds a dedicated section in DFARS 201.104-70 on where to access the official DFARS and DFARS PGI and where changes are published, and it cross‑references FAR 1.107(d) guidance on clause insertion timing.
• Peer review framework “collapsed” in the rule text: The original DFARS contained detailed peer review thresholds and mechanics in DFARS 201.170; the rewrite reduces 201.170 to a short directive to follow PGI 201.170.
• Removal of text on “Agency Acquisition Regulations” and “Deviations from the FAR”: Large parts of Subpart 201.2 regarding maintenance of and revision to the FAR and DFARS are removed. Similarly, large parts of Subpart 201.3 about FAR deviations are sliced. 
• Addition of Contracting Officer Representative (COR) Guidance. FAR 201.404 adds guidance on the designation of CORs.

On August 5, 2026, DOD updated its overhaul of Part 201 (Federal Acquisition Regulation System). First, DOD revised the numbering of the part. Second, DOD revised the purpose of the DOD acquisition system to focus on speed and maintaining military superiority: “the primary purpose of the defense acquisition system is to expeditiously provide the armed forces with the capabilities necessary to operate effectively, to address evolving threats, and to sustain the military advantage of the United States in the most cost-effective manner practicable (10 U.S.C. 3102).” Third, DOD updated DFARS 201.404-71, the instruction for the contract clause DFARS 252.201-7000 [Contracting Officer’s Representative (COR)] to indicate that the clause can also be included in FAR Part 12 contracts, when appointment of a COR is anticipated and also updated the clause itself to reflect the renumbering of the provision instructing its use. The clause was not substantively changed. 

DFARS Part 203 (Improper Business Practices and Personal Conflicts of Interest)

The overhaul of DFARS Part 203 makes few substantive changes and instead primarily makes similar plain-language updates that were seen in the FAR overhaul, such as swapping out the term “must” for “shall”.  The contract clauses found in DFARS Part 252 similarly remain the same and incorporate only plain-language updates.  This is because, like the FAR, DFARS Part 203 implements several statutes, including those related to whistleblower protections. 

• Plain Language: Through this Part, the terms “shall” and prepositional phrases were removed in favor of more active verbs.
• Slight Revision to DFARS 203.906, Remedies related to whistleblower protections for contractor employees: DFARS 203.906 previously provided that a complainant may bring an action in district court if the head of the agency fails to issue an order on a whistleblower complaint within specified time limits and “there is no showing” that the delay is due to the bad faith of the complainant.  Under the overhauled provision, the DFARS replaces the requirement for there to be “no showing” that the delay is due to bad faith with a requirement that “no evidence exists” that the delay is due to bad faith.  This change may be intended to be a plain language update, but the change arguably revises the standard for when an action may be brought in district court.
• Content Moved: The DFARS overhaul moves a list of organizations responsible for investigating possible kickbacks from the DFARS to PGI 203.  Other than that change, PGI 203 remains substantively the same.
  
  

DFARS Part 204 (Administrative and Information Matters)

Overhauled Part 204 was significantly reorganized, with several legacy subparts removed, renumbered, or relocated under a revised numbering and subpart structure. The revised Part 204 streamlines contract administration rules in the DFARS text and directs users to PGI for more detailed implementation guidance. Notably, Part 204’s cybersecurity and Cybersecurity Maturity Model Certification (CMMC) frameworks have been moved to Part 240; this is consistent with the movement of information security requirements from Part 4 to Part 40 of the FAR. The new Part 204 also includes the standard plain language drafting throughout.

• New Subpart 204.2: The overhaul adds a new Subpart 204.2 (Solicitation, Evaluation, and Award) and consolidates several administrative topics there, including multiple legacy Part 204 sections now reorganized and renumbered under the new structure. Section 204.201 focuses on unique procurement instrument identifiers (PIIDs), and a new series beginning at 204.202-70 establishes rules for uniform line-item structure and numbering, modification handling, accounting classification reference number (ACRN) traceability, and payment allocation and instructions, eliminating large swaths of prior text on these topics and pointing to PGIs for guidance and procedures.
• New Subpart 204.3: Overhauled Part 204 also includes a new Subpart 204.3 (Post-Award), focused on post-award reporting and administration. Section 204.301 addresses contract action reporting to the Federal Procurement Data System (FPDS) and directs users to the PGI for the procedures for reporting data. In addition, Section 204.303 establishes the service-contract inventory reporting framework and describes contractor reporting requirements. The subpart also covers SAM-based contract administration procedures and entity identifiers in 204.304 and contract file closeout procedures in 204.308.
• Relocation of Cybersecurity Requirements and CMMC to Part 240: Consistent with the reorganization of Parts 4 and 40 of the FAR, the overhaul moves Part 204’s subparts focused on cybersecurity requirements and CMMC to Part 240. Former Subpart 204.73, Safeguarding Covered Defense Information and Cyber Incident Reporting, is now in DFARS Subpart 240.3 and specifically DFARS 240.370.  Former DFARS  204.75, Cybersecurity Maturity Model Certification, is now at DFARS 240.371.  The prior Part 204 sections are now marked RESERVED.
  
  

DFARS Part 205 (Publicizing Contract Actions) - Updated August 28, 2026

The changes in the overhauled Part 205 are primarily organizational and make the same plain-language updates seen throughout the overhauled parts.  In addition, the overhauled parts remove some publication requirements.    

• Reorganization: Similar to the revisions made to the FAR in the FAR overhaul, DFARS Part 205 has been reordered to align with the acquisition lifecycle, tracking the phases of the acquisition rather than topic.  Other topics have been moved to PGI 203.  For example, DFARS 205.303 previously included a requirement that departments report certain contract information to the Office of the Assistant to the Secretary of Defense for Public Affairs.  That requirement is now in PGI 205.302.
• Removal of Notification of DOD Contacts: DFARS 205.205-70 previously required DOD to publish its intent to bundle requirements.  The overhauled DFARS deletes this requirement.
• Removal of Procedures when Solicitation to Only One Responsible Source: The prior DFARS and PGI included procedures when soliciting to only one responsible source, both of which are removed in the overhauled DFARS and PGI.
• Revision 1 to Deviation Text: On August 24, 2026, DOD updated the overhaul of Part 205 primarily to implement Section 875 of the National Defense Authorization Act for Fiscal Year 2025, which requires accessibility and clarity in covered notices for small business concerns, in PGI 205.002-70, Preparation and transmittal of notices. The update also incorporates at new DFARS 205.101-70, DFARS 205.301-71, and DFARS 205.302-70 exemptions from posting various solicitation-related notices for proposed contract actions that will be solicited, awarded and performed outside the United States. Lastly, the update replaced the term “synopsis” in favor of more “plain language” terms, such as “notice” or “award notice.”

DFARS Part 206 (Competition Requirements) - Updated September 11, 2026

The overhauled DFARS Part 206 makes minimal changes.  The primary changes involve renaming and renumbering the subparts and clauses; the substance is largely the same.  Additionally, similar to other overhauled DFARS parts, there are plain-language updates throughout.

• Renamed Subparts: The overhauled DFARS Part 206 has renamed subparts to track with the contracts-lifecycle based reorganization in other DFARS parts.  Subpart 206.1 has been renamed “Presolicitation,” and most of the clauses in Part 206 have been renumbered to fall under that subpart.
• Removal of Clause Related to Acquisitions in Support of Operations in Afghanistan:  DFARS 206.303-70 previously contained requirements for acquisitions that would support operations in Afghanistan.  That has been removed in the overhaul in light of the withdrawal of US troops from Afghanistan.

On August 5, 2026, DOD updated its overhaul of Part 206 (Competition Requirements). Most notably, DOD updated DFARS 206.104 (Justification and Approval) and DFARS 206.104-71 therein, including the table, to update the approval authorities for a justification of other than full and open competition and whether that authorization can be delegated (and if so, to whom). DOD also made revisions to section and paragraph numbering, added some paragraph titles, made plain language updates, and revised various cited statutes to streamline and simplify text.

DFARS Part 207 (Acquisition Planning) - Updated September 16, 2026

The overhaul of DFARS Part 207 provides plain language and cross-reference updates throughout the part. Substantively, there are updates in the areas of agency-head responsibilities, additional requirements for major systems, public-private competitions, component breakout, human research, and the additional quantities limitation:

• Agency-head responsibilities:Overhauled DFARS 207.103-70 removes the language stating that the program manager, or other official responsible for the program, has overall responsibility for acquisition planning. This text was originally in DFARS 207.103(g).
• Additional requirements for major systems:Overhauled DFARS 207.106-70(h) provides that when selecting contract type, the contracting officer must now look to Section 811 of the National Defense Authorization Act (NDAA) for Fiscal Year 2013.
• Public-Private Competitions:Section 207.170 is no longer reserved and now references the Procedures, Guidance, and Information (PGI) for the policy on the Governmentwide moratorium and restrictions on public-private competitions conducted pursuant to OMB Circular A-76. Original Subpart 207.3, which addressed the same issue, is deleted.
• Component Breakout:The overhaul removes the scope, definition of “component,” policy and procedures from original DFARS 207.171 and instead refers to PGI 207.171 for component breakout policy and procedures.
• Human Research:Overhauled DFARS 207.172 clarifies that the Human Research Protection Official must be identified in the written acquisition plan rather than just in “acquisition planning” more generally.
• Additional Quantities Limitation: Overhauled Subpart 207.70 reframes the limitation related to the use of other than competitive procedures in DFARS 207.7003 to tie it explicitly to 10 U.S.C. § 3069.

On September 2, 2026, the U.S. Department of Defense (DOD) updated the overhaul of this part. The changes include adding DFARS 207.107 on additional requirements, such as notice on sam.gov, for acquisitions that involve bundling or substantial bundling, and removing DFARS 207.470(b), as a result of the repeal of the statutory term limit for leases of vehicles, aircraft, and vessels in the FY2026 National Defense Authorization Act (NDAA). The update also modified DFARS 207.7002 and removed DFARS 207.7002(d) and 207.7003 to reflect Section 812 of the FY 2026 NDAA, which lowered the level of the determination authority for acquisition of an end item at a higher quantity and removed the approval requirements for additional quantities. Other minor numbering edits were also made.

DFARS Part 208 (Required Sources of Supplies and Services)

Overhauled DFARS Part 208 makes plain language revisions and moving requirements to the PGI. In addition, the overhauled DFARS Part 208 moves requirements previously found in DFARS Part 251 relating to contractor use of government supply sources. 

• Relocation of DFARS Part 251: DFARS Part 208 now includes Subpart 208.1, which governs a contractor’s use of government supply sources, including by using DLA as a source of fuel if fuel is funded by the Defense Working Capital Fund. New Subpart 208.75 incorporates the requirements previously found in Part 251 related to the contractor’s use of Interagency Fleet Management System vehicles.
• Revisions to PGI 208: The overhaul also makes changes to PGI 208. While PGI 208 previously provided guidance on limiting sources when making purchases off the federal supply schedule, the overhauled version of the PGI removes that guidance. The PGI has also been updated to incorporate guidance related to contractor use of government supply sources, previously found at PGI 251. In addition, some of the procedural directions previously found in the DFARS have been moved to PGI 208.
• Incorporation of Class Deviations: DFARS 208 incorporates DOD Class Deviation 2014-O0011- Determination of Fair and Reasonable Prices When Using Federal Supply Schedule Contracts, which requires ordering contracting officers to make their own determination that the pricing is fair and reasonable.

DFARS Part 209 (Contractor Qualifications)

Unlike many Parts that have been reorganized as part of the DFARS overhaul, Part 209 retains its original structure. Most of the changes are minor as well, reflecting replacement of “shall” with “must,” “insert” for “use,” and simplifying instructions.

• Definitions: Rather than pointing to definitions in DFARS 252 clauses for various subparts, the overhaul adds the definitions to the affected subparts.
• Reliance on Supplier Performance Risk System (SPRS) and removal of Federal Awardee Performance and Integrity Information System (FAPIIS): Original DFARS 209.105-1 directed contracting officers to consider Contractor Performance Assessment Reporting System records in assessing responsibility. The revised text instructs them to consider the supplier risk assessment in SPRS.  References to the now-defunct FAPIIS system are also removed and replaced with the Integrity module in the Contractor Performance Reporting System (CPARS).
• Reliance on PGIs: Like other overhauled Parts, the overhaul of DFARS Part 209 streamlines procedures (e.g., DFARS 209.406-3 re referrals to suspending and debarring officials) by directing users to PGIs.
• Implementing Clauses unaffected.  Like other overhauled Parts, the implementing DFARS clauses from Part 252 are restated in the class deviation text for DFARS Part 209. There are no updates to these clauses.
  
  

DFARS Part 210 (Market Research)

The overhaul of DFARS Part 210 is minimal (and the original part was also short). In addition to plain language updates, it removes a reference regarding the bundling notification publication requirement, as well as references to the PGI regarding potential offerors that express an interest in an acquisition and contract file documentation. For contract file documentation, the overhauled part refers to PGI 210.001(e) and for acquiring services, it refers to PGI 210.070 for “Market Research Report Guide for Improving Tradecraft in Services Acquisition.”

DFARS Part 211 (Describing Agency Needs)

The overhaul of DFARS Part 211 largely retains the original structure of the part. On a broader scale, the overhauled Part 211 makes clear where the statement of work or requirement document has to reflect a given policy. Notable revisions are identified below.

• NDAAs: The overhauled part adds references to various fiscal year National Defense Authorization Acts.
• Sections and Subparts Removed: Subpart 211.2, using and maintaining requirements documents, is removed but the substantive provisions remain in Subpart 211 as DFARS 211.273-1 and 211.273-2. In addition, references to previously removed and reserved parts are eliminated entirely. 
• Item Identification: The updated Part 211 removes the outcomes of item unique identification policy from DFARS 211.274-1, removes the specific circumstances where item unique identification is required from DFARS 211.274-2, and removes the exceptions to those requirements from the same provision.
• Primary Inventory Control Activity: The updated Part 211 also adds a requirement that primary inventory control activity (PICA) determines that an item requires unique item-level traceability. 
• Ozone Depleting Substances: Subpart 211.271 regarding the elimination of the use of class I ozone-depleting substances is now DFARS 211.275.
• Implementing Clauses: The implementing clauses, per the DFARS overhaul process, appear in the class deviation text of the Part. There appear to be no modifications to DFARS 252.211-7003 through -0008 based on the clause dates. Note that DFARS 252.211-7004 through -7007 are reserved.

DFARS Part 212 (Acquisition of Commercial Products and Services)

The Overhaul of DFARS 212 includes extensive changes. 

• Reorganization: Similar to the overhaul of the FAR, the part is reorganized to reflect the acquisition lifecycle. Subpart 212.1 (Presolicitation)* and addresses computer software, major weapons systems as commercial products, limitations on the acquisition of right-hand drive passenger sedans, and preferences for commercial products and services. Subpart 212.2 is retitled “Solicitation, Evaluation, and Award” (previously entitled “Special Requirements for the Acquisition of Commercial Products and Commercial Services” and removed from Part 212). There is no Subpart 212.3. Part 212 then returns to topics: Subpart 212.4 addresses Micro-Purchases followed by Subpart 212.70 addressing Defense Commercial Solutions Openings and Subpart 212.72 addressing laws, provisions, and clauses applicable to commercial and COTS purchases. *Deviation text has two Subpart 212.1 titles, a potential oversight.
• Nontraditional Defense Contractors: The Overhaul of DFARS Part 212 retains the authority to treat supplies and services provided by nontraditional defense contractors as commercial products or commercial services but deletes the rationale that previously appeared in original DFARS 212.102.
• Restricting Competition: The updated Part 212 adds a “Restricting Competition” section at DFARS 212.102-70, which references DFARS 206.104-71 for documentation requirements and the procedures at PGI 206.104-71 regarding non-competitive follow-on acquisitions of supplies or services previously awarded on a non-competitive basis. The provision also references Section 888 of the Fiscal Year 2008 NDAA as well as FAR 12.102 for documentation requirements for brand name or equal descriptions or proprietary specifications or standards.
• Only One Offer: The updated Part 212 adds a section directing contracting officers to follow the procedures at 215.202-71 when only one offer is received in response to a competitive solicitation issued using simplified acquisition procedures for commercial products and commercial services.
• Evaluation Factors and Supply Chain Risk: As noted above, the overhauled Part 212 consolidates evaluation guidance in a new 212.203 “Evaluation” provision, relocating the existing supply chain risk evaluation factor requirement for information technology from DFARS 212.301(c) and adding a cross-reference to PGI 212.203 for acquisitions of transportation or transportation related services.
• Desktop-Defense System: The updated Part 212 at DFARS 212.205 adds a section incorporating DOD Class Deviation 2023-O0008, “Commercial Products and Commercial Services Omnibus Clause for Acquisitions Using the Procurement Desktop-Defense System,” issued September 18, 2023, regarding the use of the Procurement Desktop-Defense System, which allows the contracting officer to use the PD2 clause logic capability to automatically select the clauses that are applicable to the specific solicitation and contract.
• Solicitation Provisions and Clause Tables: The updated version of DFARS Part 212 introduces three new tables: Table 212.2 listing provisions to be included in solicitations for commercial products and services; Table 212.3 listing clauses to be included in contracts for commercial products and commercial services; and Table 212.4 listing clauses to be included in specified categories of contracts and solicitations. Consequently, overhauled Part 212 removes the prior prescriptive “use the clause” instructions at former DFARS 212.301(f), relying on the new tables instead.
• Rapid Contracting for Combatant Commanders: Updated Part 212 adds a provision to Subpart 212.4 incorporating DOD Class Deviation 2024-O0011, “Special Acquisition Authority for Rapid Contracting for Combatant Commanders,” issued April 15, 2024, regarding the use of certain temporary special acquisition authorities for covered contracts that support covered operations. This authority includes higher micro-purchase thresholds.
• Governmentwide Commercial Purchase Card Program: The updated Part 212 adds a section at DFARS 212.403 on the Government-wide commercial purchase card, referencing procedures in the PGI for the program. The section provides guidelines for when the card is and is not to be used and who may use the card.
• Purchase orders: Updated Subpart 212.4 also adds a section on purchase orders, which addresses, among other things, modifications of purchase orders and clauses to be inserted in purchase orders.
• Applicability of Certain Laws, Provisions, and Clauses: As discussed above, updated Part 212 adds a new Subpart 212.72 containing sections 212.7201 through 212.7205 that largely directs contracting officers to the PGI for the applicability (and inapplicability) of certain laws, provisions, and clauses to contracts for the acquisition of commercial products and commercial services and COTS items.

DFARS Part 213 (Simplified Acquisition Procedures)

Similar to the overhaul of FAR Part 13, the overhauled DFARS Part 213 is reformulated to focus on “noncommercial” simplified acquisitions. Consequently, like the FAR Overhaul, much of the prior content regarding simplified commercial acquisitions is moved to DFARS Part 212.

The overhauled version of Part 213 adds a sole section for simplified procedures for noncommercial acquisitions that incorporates DOD Class Deviation 2024-O0011 regarding the use of certain temporary special acquisition authorities for covered contracts that support covered operations. This authority includes higher micro-purchase and simplified acquisition thresholds.

DFARS Part 214 (Sealed Bidding)

The revised DFARS Part 214 primarily reflects a reorganization and tightening of sealed bidding procedures with updated headings and cross-references.

• Subpart 214.2, Presolicitation: Subpart 214.2 has been rebranded from “Solicitation of Bids” to “Presolicitation.” Most revisions are conforming in nature, including renumbered sections, renamed headings, and updated cross-references. For example, DFARS 214.209 “Cancellation of invitations before opening” has been replaced with DFARS 214.209-70 “Policy,” which largely carries forward the prior approach while providing minor clarifications regarding when cancellations and resolicitations are required. The subpart also instructs contracting officers in DFARS 214.211-370 to include an evaluation factor for supply chain risk.
• Subpart 214.3, Evaluation and Award: Provisions formerly contained in Subpart 214.4 (Opening of Bids and Award of Contract) have been reorganized under Subpart 214.3, “Evaluation and Award.” Topics addressing cancellation after opening, mistakes in bids, and scenarios in which only one offer is received are now addressed within this subpart.
• “Other mistakes disclosed before award” now appears at DFARS 214.304-3, which directs readers to the PGI for delegation authority to approve determinations. The revised Subpart 214 also includes two provisions addressing situations in which only one bid is received (214.305-70 and 214.307-70). Both provisions direct contracting officers to follow the procedures at DFARS 215.371.
• The DFARS no longer includes DOD-specific procedures for two-step sealed bidding by removing former Subpart 214.5 in its entirety.
• The PGI to DFARS Part 214 now houses delegation authority for approving determinations related to mistakes in bids disclosed before award, rather than embedding that authority in the DFARS text.
  
  

DFARS Part 215 (Contracting by Negotiation) - Updated August 7, 2026

The overhaul of DFARS 215 included extensive changes. On July 22, 2026, DOD posted a revision to the overhauled part. Among other things, the revision implements:

• FY 2026 NDAA § 811(a)(5), which repealed 10 U.S.C. § 3455 regarding determinations and congressional notice for procurement of a major weapon system as a commercial product.
• Section 812(c) of the NDAA for FY 2026, which transfers the pilot program from Section 890 of the FY 2019 NDAA to a program codified at 10 U.S.C. §3709.
• FY 2026 NDAA § 1826(8) & (9), which exempts nontraditional defense contractors from submission of certified cost or pricing data and other special cost or pricing requirements, unless waived.

This summary reflects that revision.

• Reorganization: Similar to the overhaul of the FAR, the part is reorganized to reflect the acquisition lifecycle. Subpart 215.1 is retitled Presolicitation and Solicitation and addresses source selection approaches, the establishment of competitive evaluation factors, requests for cost or pricing data, and solicitation provisions and contract clauses. Subpart 215.2 is retitled Evaluation and Award and addresses source selection responsibilities, proposal evaluation, only-one-offer procedures, competitive negotiations, and preaward and award notices. A new Subpart 215.3 addresses Postaward matters, including postaward debriefings, voluntary disclosure of defective certified cost or pricing data, and estimating systems. Subpart 215.4 (Contract Pricing) is retained but its sections are renumbered throughout. The prior Subpart 215.5 on Preaward, Award, and Postaward Notifications, Protests, and Mistakes is eliminated, with its content largely relocated to the new Subpart 215.3. The former Subpart 215.6 on Unsolicited Proposals becomes the new Subpart 215.5.
• Renumbering: Most sections are renumbered to track with the renumbered FAR Part 15 sections. For example, competitive evaluation factors are moved from DFARS 215.304 to 215.104-70; the Selected Reserve evaluation factor is moved from 215.370 to 215.104-71; only-one-offer procedures are moved from 215.371 to 215.202-71; postaward debriefing requirements are moved from 215.506 to 215.301; cost estimating system requirements are moved from 215.407-5 to 215.305-70; and the profit and weighted guidelines provisions at former 215.404-4 are renumbered to 215.404-970, with much of the substantive content moved to the PGI.
• Peer Reviews: The overhaul removes the peer review requirement previously at DFARS 215.270, which had directed agency officials to conduct peer reviews in accordance with DFARS 201.170.
• Lowest Price Technically Acceptable (LPTA):The July 22 revision renumbered the LPTA provisions as 215.103-72; the provision retains the existing statutory limitations and prohibitions on LPTA source selection. The preference to avoid LPTA, to the maximum extent practicable, for acquisitions of information technology services, cybersecurity services, systems engineering and technical assistance services, advanced electronic testing, and other knowledge-based professional services is retained, as is the prohibition on using LPTA for auditing services (10 U.S.C. 240f), engineering and manufacturing development for major defense acquisition programs (10 U.S.C. 4232), and personal protective equipment or aviation critical safety items where quality or failure could result in combat casualties.
• Tradeoff Approach for Acquisition of Tents and Fuel for Overseas Contingency Operations: The July 22 revision moved the requirement to award best-value contracts when acquiring tents or other temporary structures for use by the Armed Forces from DFARS 215.101-70 to 215.103-70 and includes updated cross-references to the restructured FAR 7.103 and PGI 207.104-70. The preexisting requirement to consider a tradeoff approach when acquiring fuel for overseas contingency operations above the simplified acquisition threshold is renumbered DFARS 215.103-71 and retains the same list of potential evaluation factors (past performance, cost, anticorruption training, and anticorruption compliance), as well as the written-justification and one-level-above-contracting-officer approval requirements when a tradeoff approach is not considered.
• Make or Buy: The July 22 revision adds DFARS 215.105-5(c) regarding make-or-buy decisions, the most notable aspect of which is that nontraditional contractors are not required to submit a make-or-buy plan unless waived.
• Establishing Competitive Evaluation Factors: The consolidated evaluation factor requirements are relocated from DFARS 215.304 to 215.104-70. These include the requirement to address small business participation (including service-disabled veteran-owned, HUBZone, small disadvantaged, and women-owned small business concerns), consideration of capital assets manufactured in the United States, supply chain risk for information technology, sustainment factors and reliability and maintainability criteria for weapon systems, and Supplier Performance Risk System (SPRS) price-risk, supplier-risk, and item-risk assessments. The supply chain risk cross-reference is updated to DFARS Subpart 240.271 (replacing former Subpart 239.73). The past performance evaluation thresholds previously contained in DOD Class Deviation 2013-O0018 are incorporated at new DFARS 215.104-70(g) (systems and operations support exceeding $5 million; services and information technology exceeding $1 million; ship repair and overhaul exceeding $500,000).
• Only One Offer: The requirements and procedures that apply when only one offer is received in response to a competitive solicitation, including the obligation to consult with the requiring activity and resolicit for at least 30 additional days, the fair-and-reasonable-price procedures, exceptions, head-of-the-contracting-activity waiver authority, and the solicitation provision requirement, are consolidated and moved from DFARS 215.371 through 215.371-6 to DFARS 215.202-71. The exceptions list is retained, including exceptions for small business set-asides, acquisitions of science and technology, architect-engineer services, commercial solutions openings under Subpart 212.70, and acquisitions of commercial products and commercial services using FAR Part 12 procedures.
• Postaward Debriefings: The enhanced postaward debriefing requirements are moved from DFARS 215.506 to new DFARS 215.301 through 215.301-270. The section continues to require, for contract awards valued at $15 million or more, a written or oral debriefing upon timely request, and mandates disclosure (with appropriate redactions) of the agency’s written source selection decision document for awards in excess of $150 million, and upon request by a small business or nontraditional defense contractor for awards in excess of $15 million and not in excess of $150 million (Section 818 of the NDAA for FY 2018). The overhaul retains the structured follow-up-question process (with two business days to submit, five business days for Government response, and tolling of the debriefing conclusion until response).
• Cost Estimating System Requirements: The estimating system disclosure, maintenance, and review requirements previously at DFARS 215.407-5 through 215.407-5-70 are consolidated and moved to new DFARS 215.305-70. The corresponding clause at DFARS 252.215-7002, Cost Estimating System Requirements, is retained (with a January 2025 date) and now incorporates the definition of “material weakness” consistent with Section 806 of Pub. L. 116-283. The instruction for insertion of the clause at DFARS 215.110-70 has been updated to exclude the clause’s insertion into contracts awarded to nontraditional defense contractors.
• Pricing Policy and New Definitions: Pricing policy and contracting officer responsibility provisions previously at DFARS 215.402 and 215.403-3 are reorganized at DFARS 215.402-70 and 215.403-170, with much of the detailed procedural guidance moved to the PGI. The related prohibition on certified cost or pricing data provisions at former 215.403-1 are consolidated at DFARS 215.403-270.
• Certified Cost or Pricing Data: DFARS 215.403-3(a) implements the statutory increase of the certified cost or pricing data threshold to $10 million for prime contracts awarded after June 30, 2026 (10 U.S.C. 3702), unless an exception at FAR 15.403-2 or DFARS 215.403-271 applies. The $2.5 million threshold continues to apply to prime contracts awarded on or before June 30, 2026. Parallel thresholds apply at the subcontract level, and subcontractor certified cost or pricing data is required before the pricing of a change or modification when the price adjustment is expected to exceed $2.5 million. The July revision renumbers the prohibition on obtaining certified cost or pricing data to DFARS 215.403-71 and adds nontraditional defense contractors to those exempted, unless waived.

The July revision also includes a new DFARS 215.403-72 addressing certified cost or pricing data under the Program to Accelerate Contracting and Pricing Processes and inserts instructions in DFARS 215.110-70 for when to include two new related DFARS clauses: DFARS 252.215-7988, Requirements for Certified Cost or Pricing Data and Data Other Than Certified Cost or Pricing Data Under the Program to Accelerate Contracting and Pricing Processes, and DFARS 252.215-7989, Requirements for Certified Cost or Pricing Data and Data Other Than Certified Cost or Pricing Data—Modifications—Under the Program to Accelerate Contracting and Pricing Processes.

• Profit and Weighted Guidelines: The structured approaches for developing prenegotiation profit or fee objectives (the weighted guidelines method, the modified weighted guidelines method for nonprofits other than FFRDCs, alternate structured approaches, fee requirements for cost-plus-award-fee contracts, and fee requirements for FFRDCs) are renumbered from DFARS 215.404-4 to DFARS 215.404-970 to -975, with much of the content relocated to the PGI. The DD Form 1547, Record of Weighted Guidelines Method Application, requirement is retained.
• Renumbered and Reissued Solicitation Provisions and Clauses: The overhaul renumbers several of the Part 252 solicitation provisions and contract clauses associated with Part 215 and issues them as class deviations under DARS Tracking Number 2026-O0048. These include new DFARS 252.215-7990 (formerly 252.215-7003), Requirement for Submission of Data Other Than Certified Cost or Pricing Data (Canadian Commercial Corporation); 252.215-7991 (formerly 252.215-7004), the corresponding Modifications version; 252.215-7992 (formerly 252.215-7008), Only One Offer; 252.215-7993 (formerly 252.215-7009), Proposal Adequacy Checklist; 252.215-7994 (formerly 252.215-7010), Requirements for Certified Cost or Pricing Data and Data Other Than Certified Cost or Pricing Data; 252.215-7995 (formerly 252.215-7015), Program Should-Cost Review; and 252.215-7996 (formerly 252.215-7016), Notification to Offerors on Postaward Debriefings. The July revision updates modestly DFARS 252.215-7993; revises DFARS 252.215-7994 to eliminate (b)(1)(B) regarding subsystems of a major weapons system and spare parts of a major weapon system or subsystem that had not previously been sold as a commercial item and revise paragraph (d) regarding requirements for other than certified cost or pricing data. Similar changes are made to the alternate clause.
• Commercial Solutions Openings:The updated Part 215 confirms at DFARS 215.502 and 215.503-1 that the FAR policies and guidance at FAR 15.502(d)(3) and 15.503-1(a) apply to commercial solutions openings conducted under DFARS Subpart 212.70.

DFARS Part 216 (Selecting Contract Types) - Updated August 5, 2026

The original overhaul of Part 216 included few substantive revisions. Most changes were plain-language updates for readability or reorganization, or involved moving guidance to the PGI. In addition, some provisions have been internally renumbered, and the provisions on incentive contracts in Subpart 216.4 have been reorganized to match the corresponding subpart in overhauled FAR Part 16. The implementing DFARS clauses were not revised.

On July 15, 2026, DOD posted an update to its overhaul primarily to implement Executive Order 14402, Promoting Efficiency, Accountability, and Performance in Federal Contracting, issued April 30, 2026, establishing a “default” preference for fixed-price contracts. Rather than wholesale updates to the deviation text, the revision generally adds references to criteria or limitations in overhauled FAR Part 16. The bulk of the requirements regarding justifications of other than fixed-price contracts appears in PGI 216.104-70. 

In addition, although the prior deviation had lowered the threshold for postaward debriefings for task and delivery orders from $15 million to $10 million, the July 15 update restored the $15 million threshold in DFARS 216.507-5(c). Furthermore, DFARS 252.216-7010, Postaward Debriefings for Task Orders and Delivery Orders, was updated to reflect the $35 million threshold for protests of DOD task or delivery orders under IDIQ contracts. Unfortunately, the revision appears to have added a typographical error: It states that performance may be suspended upon receipt of GAO notice of a timely protest of a task or delivery order valued over $35 million “and the protest is on the grounds that the order increases the scope, period, or maximum value of the contract under which the order is issued.” The applicable statute, 10 U.S.C. § 3406(f), however, uses “or” to indicate that these are two separate jurisdictional bases. 

Finally, the revision also updated the approval authorities for exceptions to fair opportunity provided at DFARS 206.104 in lieu of the approval authorities at FAR 16.507(e), made numbering, organization, and “plain language” updates, and added additional reference to guidance moved to the PGI.

DFARS Part 217 (Special Contracting Methods)

• Reorganization: Overhauled Part 217 includes relatively minor updates for streamlining, reorganization, and plain language edits. As with other FAR and DFARS Parts, some Subparts are reorganized to follow the acquisition lifecycle (presolicitation, evaluation and award, and post-award, as applicable). To that end, it moves the congressional notification requirements to new 217.104-370. This section includes the requirements for DOD components to request authority to enter into multiyear contracts when submitting budgets, for DOD components to notify Congress before awarding multiyear contracts in certain procurements, and for the head of an agency to notify Congress before terminating a multiyear contract. While retaining the actual notification requirements, overhauled Part 217 removes text that previously required agencies to establish reporting procedures to meet those requirements.
• Multiyear Contracts: Overhauled Part 217 also removes the requirement for agency heads to consider the commercial life of any plant or equipment, desirability of an option to extend the contract term, and desirability of reserving the right to take title of the plant or equipment when entering into multiyear contracts for services. The new Part 217 removes language that specifically allowed agency heads to enter into a multiyear contract for supplies to promote the national security interest of the United States.
• Reliance on PGIs: Finally, the overhauled Part 217 moves prior information regarding ordering procedures, purchase requests, and solicitation and award to the PGI.
• Part 252: The class deviation also includes corresponding solicitation provisions and contract clauses in DFARS Part 252. The provisions and clauses cover topics such as exercising options in foreign military sales contracts, surge options, offering property for exchange, job orders and compensation, and inspections, changes, payments, and default for multiyear contracts with job orders. The numbering and substance is unchanged from the current DFARS.
  
  

DFARS Part 218 (Emergency Acquisitions)

Overhauled Part 218 moves almost all the prior language on available acquisition flexibilities to PGI 218.7001-1 through PGI 218.7001-7. The new Part 218 retains basic language indicating that flexibilities are available for acquisitions related to defense against or recovery from cyber, nuclear, biological, chemical or radiological attacks, and use of electronic business tools, but the descriptions of those acquisition flexibilities and when they can be used are now within the PGI. The acquisition flexibility content that moved to the PGI is identical to the prior language of Part 218, with some new language regarding the use of electronic business tools for automation such as the 3in1 Tool and Acquisition Cross-Servicing Agreements Global Automated Tracking and Reporting System.

DFARS Part 219 (Small Business Programs) - Updated August 28, 2026

The overhaul of DFARS Part 219 makes minimal substantive changes to small business policy, but it reorganizes and renumbers the Part to align coverage with lifecycle phases. There are also “plain language” changes to make retained rules and clauses easier to read, which in some cases also involves removing citations to laws or FAR provisions.

• Reorganization: DFARS Part 219 is reorganized from the prior topic-based structure (including the original DFARS subparts for policies, SBA cooperation, set-asides, status determinations, small business subcontracting, and the 8(a) program) into lifecycle subparts: Subpart 219.1 (Presolicitation), Subpart 219.2 (Evaluation and Award), and Subpart 219.3 (Postaward). As a result, some provisions are substantively unchanged but distributed into other subparts as part of the reorganization. Similar to other overhauled parts, discussion of “policies” is largely eliminated or replaced with a reference to a particular PGI. 
• Mentor-Protégé updates (DFARS 219.71): The Department’s Mentor-Protégé coverage remains a discrete subpart, but the subpart title removes the “Pilot” framing and deletes material in DFARS 219.7102, including the reference to a preliminary protégé cybersecurity readiness assessment as an element of the Program. Appendix I remains the location for Mentor-Protégé policy and procedures.
• Clause renumbering: The Small Business Subcontracting Plan and Small Business Subcontracting Plan (Test Program) clauses are renumbered, replacing the 252.219-7003 and 252.219-7004 numbering with 252.219-7996 and 252.219-7997; these clauses are also updated with relatively minor non-substantive “plain English” revisions and to reflect the reorganization of DFARS Part 219.

On August 24, 2026, DOD revised its overhaul of Part 219. First, DOD noted that in addition to replacing the prior deviation text for this Part, the revision supersedes Class Deviation 2024-O0002, Rev. 1, The Service-Disabled Veteran-Owned Small Business Program, dated March 14, 2024. Second, DOD added DFARS 219.106-70, Status as an SDVOSB concern, which applies in lieu of the procedures at FAR 19.106-1 for verifying the eligibility of an SDVOSB concern or joint venture. Third, DOD added a reference to Class Deviation 2014-O0007, Prohibition on the Use of the 8(a) Business Development Program for Acquisition of Military Simulation and Military Simulation Training, dated March 14, 2014, to DFARS 219.108-3, Selecting acquisitions for the 8(a) program. Fourth, DOD corrected the threshold in DFARS 219.208-2, contract negotiation, which states when SBA may not accept a DOD sole-source 8(a) contract for negotiation, lowering the threshold from $150 million to $100 million. Fifth, DOD updated DFARS clauses 252.219-7996, Small Business Subcontracting Plan (DoD Contracts) and its alternates, and 252.219-7997, Small Business Subcontract Plan (Test Program), to reflect the use of the Subcontracting Plan Reporting (SPR) system, which replaced the Electronic Subcontracting Reporting System, or eSRS. Finally, the revision also inserted statutory citations and made minor, non-substantive wording changes, spelling and numbering corrections, and cross-reference updates.

DFARS Part 220 (Reserved in the original DFARS overhaul)

DFARS Part 221 (Reserved in the original DFARS overhaul)

DFARS Part 222 (Application of Labor Laws to Government Acquisitions) 

Unlike many Parts that have been reorganized as part of the DFARS overhaul, Part 222 retains most of its original structure. Most of the changes are minor as well, reflecting replacement of “shall” with “must,” “insert” for “use,” and simplifying instructions.

• Reliance on PGIs: The biggest change to Part 222 is to streamline provisions by eliminating large portions of text with procedural direction in favor of references to PGIs.  This is most notable of these changes are in new DFARS 222.204-171, removal of items from contractor facilities affected by a work stoppage, new DFARS 222.104-172, acquisition of stevedoring services during labor disputes, and new DFARS 222.402-3, construction wage rate requirements statute.
• Modest Movement of Provisions: A handful of provisions have been moved. DFARS 222.406, previously entitled “Administration and enforcement,” has been renumbered 222.404-1, under DFARS 222.404 Postaward, and enforcement has been moved to its own provision: DFARS 222.404-2. Original DFARS 222.406-9, withholding from or suspension of contract payments, is streamlined and now subsumed within DFARS 222.404-2 in paragraph (e).
• References to Equal Employment Opportunity Deleted: Pursuant to the repeal of Executive Order No. 11246, references to equal employment opportunity and EO 11246 have been deleted.
• Implementing Clauses unaffected.  Like other overhauled Parts, the implementing DFARS clauses from Part 252 are restated in the class deviation text for DFARS Part 222. There are no updates to these clauses.
  
  

DFARS Part 223 (Environment, Sustainable Acquisition, and Material Safety) - Updated September 16, 2026

Although DFARS Part 223 has a new name, Sustainable Acquisition, Material Safety and Pollution Prevention, the part’s overhaul is modest in scope and consistent with the broader deregulatory and streamlining posture of the FAR and DFARS overhauls. The changes are largely limited to clarifying existing requirements and removing outdated or duplicative text.

• DFARS 223.1: Subpart 223.1 remains substantively the same with some conforming and technical changes. Existing DFARS provisions addressing products containing recovered materials and restrictions on ozone-depleting substances or products that contain or use high global warming potential hydrofluorocarbons are retained.
• DFARS Subparts 223.2, 223.4, 223.5, and 223.70: Subpart 223.2, which contained no text in the original DFARS, has now been removed. Subparts 223.4 and .5 are reserved, as is Subpart 223.70.
• DFAR Subpart 223.3: Subpart 223.3 has been simplified and retitled “Material Safety,” but remains substantively the same. Revisions primarily consist of clarified language and stylistic edits, including replacement of “shall” with “must,” without altering underlying obligations.
• DFAR Subpart 223.71: Subpart 223.71 has been amended to clarify contracting officer responsibilities when contracts authorize the storage, treatment, or disposal of non-DOD-owned hazardous materials on DOD installations. The revised text emphasizes that solicitations and resulting contracts must expressly identify the types and quantities of materials permitted and the conditions under which such activities are authorized.
• DFARS Subparts 223.72, 223.73, and 223.74: Subparts addressing safeguarding of sensitive conventional arms, minimization of hexavalent chromium, and prohibition on certain PFAS-containing firefighting agents have received minimal changes. Revisions are largely conforming, consisting of clarified language and non-substantive wording updates.
• Part 252: Like other DFARS Parts, the overhaul of FAR Part 223 includes the implementing clauses from Part 252. There are no changes to the dates of these clauses, which should signal no substantive changes.
• The PGI to DFARS Part 223 adds operational details to support the revised DFARS requirements. Most notably, PGI 223 formalizes pre-award and post-award safety procedures for ammunition and explosive contracts, including mandatory pre-award safety surveys (including for subcontractors), senior-level approval and disclosure of waivers to DOD Manual 4145.26, structured routing of post-award waiver and site-modification requests, enhanced subcontract oversight, and expedited notification requirements for imminent safety risks. The PGI also reinforces centralized data collection for sustainable products and approval requirements for the authorized use of hexavalent chromium.

On August 5, 2026, DOD updated its overhaul of Part 223 to incorporate a host of requirements from past National Defense Authorization Acts. First, DOD added a new subpart 223.4, Pollution Prevention. The new subpart includes the prohibition on requiring nontraditional defense contractors to disclose their greenhouse gas emissions or considering greenhouse gas emission disclosures as a condition of award to nontraditional defense contractors, along with an avenue for waiver of the exemption if such disclosure is related to contract performance. The subpart also includes a requirement to procure cleaning products, to the maximum extent practicable, under the EPA Safer Choice program or its equivalent. Second, DOD revised DFARS subpart 223.74 addressing prohibitions on procurement of certain items containing PFAS (perfluoroalkyl substances or polyfluoroalkyl substances) as well as prohibitions that start as of October 1, 2026, relating to perfluorooctane sulfonate (PFOS) or perfluorooctanoic acid (PFOA), particularly as it pertains to firefighting agents or equipment, with identified exceptions. These prohibitions result in revision to DFARS clause 252.223-7009, Prohibition of Procurement of Fluorinated Aqueous Film-Forming Foam Fire-Fighting Agent for Use on Military Installations, and the addition of three new DFARS clauses: DFARS 252.223-7994, Prohibition of Procurement of Certain Items Containing Perfluorooctane Sulfonate or Perfluorooctanoic Acid, DFARS 252.223-7995, Prohibition of Procurement of Personal Protective Fire-Fighting Equipment Containing Perfluoroalkyl Substances or Polyfluoroalkyl Substances, and DFARS 252.223-7996, Safer Choice Cleaning Products.

DFARS Part 224 (Protection of Privacy and Freedom of Information)

There are no substantive overhauls to this Part, which is comprised of two subparts with only one clause in each.

DFARS Part 225 (Foreign Acquisition) - Updated July 24, 2026

The substance of the overhauled Part 225 is mostly unchanged, with the revisions focusing on reorganizing rather than rewriting and a few updated dates and thresholds. DOD posted Revision 1 to its overhauled text on July 1, 2026. This summary reflects that revision.

• Removal of Afghanistan-Related Provisions: The most significant change to the overhauled Part 225 is the removal of provisions and clauses related to Afghanistan. This includes the removal of provisions and clauses related to procuring products or services in support of operations in Afghanistan, preferences for procuring products or services from Afghanistan, requirements to procure products or services from Afghanistan, restricting acquisitions to products or services from Afghanistan, and acquisitions for Afghan military and national police. This also includes removal of Afghanistan-adjacent constructs such as South Caucasus/Central and South Asian State-related definitions and treatment.
• Streamlining of DFARS 225.76018-2 and Clarification of Date for Restriction on Covered Materials: DFARS 225.7018-2 is streamlined to remove arguably duplicative text and to clarify that the prohibition on acquiring “covered materials mined, refined, or separated in any covered country” begins on or after January 1, 2027, not December 31, 2026. Covered materials are defined to include metals such as tantalum, tungsten, and certain magnets. The associated clause at DFARS 252.225-7961, Restriction on the Acquisition of Certain Magnets, Tantalum, and Tungsten, is similarly updated with respect to dates and to remove duplicative text.
• Threshold Adjustments
  • Increase in Thresholds: Additionally, certain thresholds for reporting requirements have been increased from $15 million to $20 million for DFARS 252.225-7003 and 252.225-7004, the provision and clause covering intended performance outside the United States and Canada.
  • Buy American Threshold: In Subpart 225.601, “Acquisition of Supplies,” the threshold for alternate clauses I, IV, VII, and X increases from $102,280 to $105,767. These revised thresholds determine when DOD must use certain alternate clauses in contracts and solicitations subject to the Buy American and Balance of Payments Program, Trade Agreements, or Buy American—Free Trade Agreements—Balance of Payments Program. The adjusted thresholds are also reflected in DFARS 252.225-7017, “Photovoltaic Devices.”
  • Balance of Payments Program – Construction Material Threshold: In Subpart 225.7503, the thresholds for using the basic and alternate clauses in solicitations and contracts for construction performed outside of the United States, including acquisitions of commercial products or components, are also adjusted. For purposes of determining whether to use the clause at DFARS 252.225-7044, Balance of Payments Program—Construction Material, or DFARS 252.225-7045, Balance of Payments Program—Construction Material Under Trade Agreements, and whether to apply the basic or alternate versions of those clauses, the original $6,708,000 threshold for the -7044 clause decreased to $6,683,000, and the original $13,296,489 threshold for the -7045 clause increased to $13,749,689.
• Structural Changes and Alignment with Overhaul of the FAR: Finally, the structural changes to the overhauled Part 225 include various removals and relocations of Subparts. Additional conforming changes include updates to definitions, cross-references, and numbering revisions to reflect the new organization and structure.
  • Subpart 225.11, “Solicitation Provisions and Contract Clauses,” is relocated to Subpart 225.6.
  • Consistent with the changes to FAR Parts 25 and 40 in the FAR overhaul, which consolidated prohibited source restrictions in Part 40, certain parts of Part 225 are moving to overhauled Part 240, specifically Subpart 240.2. This move to Subpart 240.2 includes original DFARS Subpart 225.7, Prohibited Sources; DFARS 225.770, Prohibition on acquisition of certain items from Chinese military companies; DFARS 225.771, State sponsors of terrorism; DFARS 225.772, Prohibitions on certain foreign commercial satellites; and related disclosure requirements. Additional conforming changes include updates to definitions, cross-references, and numbering revisions to reflect the new organization and structure.
  • In the July 2026 update to the overhaul of this part, DOD removed DFARS 225.7021, “Disclosure Requirements for Employment Transparency Regarding Individuals Who Perform Work in the People’s Republic of China,” and its corresponding clauses at DFARS 252.225-7057 and 252.225-7058, are now marked reserved. The related PGI subpart, PGI 225.7021, is also removed and marked reserved.

Also part of the July 2026 overhaul update, DFARS 225.7024, Restriction on Acquisition of Fuel for Overseas Contingency Operations, and its corresponding clause are deleted.

DFARS Part 226 (Other Socioeconomic Programs)

The substance of the overhauled Part 226 is mostly unchanged aside from minor plain language edits. The most change is moving the pre- and post-award procedures for demonstration projects to the PGI.

The three corresponding solicitation provisions and contract clauses in DFARS 252.226 are unchanged in substance and numbering.

DFARS Part 227 (Patent, Data, and Copyrights)

Like many of the other Parts that we have deconstructed, most revisions to Part 227 are focused on streamlining and the use of plain language. 

• Consolidation of Parallel Subparts for Technical Data and Computer Software: The current DFARS has parallel Subparts addressing rights in technical data (Subpart 227.71) and rights in computer software and computer software documentation (Subpart 227.72). As part of the overhaul, these parallel provisions have been regrouped into a Subpart for other than commercial products, components, services, processes, and computer software (new Subpart 227.71) and a Subpart for commercial products, components, services, processes, and computer software (new Subpart 227.72). Definitions that were previously spread throughout the DFARS are also consolidated as part of the overhaul.
• Deletion of Subparts: The overhaul deletes much of Subpart 227.6, Foreign License and Technical Assistance Agreements, but suggests that at least some of the deleted content will appear in the PGI. On the other hand, Subpart 227.70, Infringement Claims, Licenses, and Assignments, is designated as Reserved, without any apparent move to the PGI.
• Changes to Special and Existing Works: Following the FAR overhaul, the DFARS overhaul deletes the Special Works and Existing Works clauses at DFARS 252.227-7020 and -7021, respectively, in favor of negotiated licenses in such works.
• Expansion of the Government’s Right to Challenge Restrictive Assertions: The overhaul extends the time within which the Government may challenge the validity of a contractor’s restrictive assertions from the later of three years after final payment or three years after delivery of the data/software in question to the later of six years after final payment or six years after delivery of the data/software in question. Data/software that “[a]re the subject of a fraudulently asserted use or release restriction” are added as an additional category as to which there is no time limit on the Government’s ability to challenge the validity of a restrictive assertion.

• Other Changes: There are a handful of changes to the language that, although perhaps minor on their face, may have bigger consequences.
  • The overhaul directs contracting officers to “[r]esolve questions regarding the validity of asserted restrictions prior to contract award.” DFARS 227.7103-3(a)(2). This contrasts with existing guidance to “avoid challenging asserted restrictions prior to a competitive contract award unless resolution of the assertion is essential for successful completion of the procurement.” DFARS 227.7103-13(b); see also DFARS 227.7203-13(d)(1).
  • The overhaul adds that “Agencies should make the determination of the source of development funds” to language addressing the doctrine of segregability. DFARS 227.7103-4(b)(1) (emphasis added); see also DFARS 227.7103-4(b)(2). This begs the question of whether control over application of the doctrine of segregability has shifted from the contractor to the Government.
    
    

DFARS Part 228 (Bonds and Insurance)

The changes to Part 228 are minimal. There is no reorganization. “Must” replaces “shall,” “insert” replaces “use,” and a few other words are tweaked. There are slight changes to DFARS 228.371, which identifies when to insert various clauses. First, the instruction to use DFARS 252.228-7001, Ground and Flight Risk, is modestly changed to strike text from paragraph (b)(1)(iii), which applies to non-DOD customers, that stated to include the clause if the non-DOD customer “has not agreed to assume the risk for loss or destruction of, or damages to, the aircraft.” Second, paragraph (b)(1)(iv) in the same provision and addressing commercial derivative aircraft with an FAA certificate of airworthiness maintained to FAA standards deletes “when the work will be performed at a licensed FAA repair station,” presumably because similar text appears in the next sentence describing when the exception in paragraph (b)(1)(iv) applies. The implementing clauses for this Part are unchanged.

DFARS Part 229 (Taxes)

The only changes to this subpart are to replace the term “use” with reference to DFARS clauses with “insert,” to replace “shall” with “must,” and to update PGI references. There are no changes to the implementing clauses in DFARS Part 252. 

DFARS Part 230 (Cost Accounting Standards Administration) - Updated August 28, 2026

The Overhauled DFARS Part 230 and DFARS Procedures, Guidance, and Information (PGI) 230 makes very minor changes. DFARS Part 230 addresses Cost Accounting Standards (CAS) waivers, and the deviation mainly updates cross-references to the Overhauled FAR Part 30 structure. The new DFARS Part 230 also changes the threshold for the agency to report CAS waivers to the CAS Board and Congress for contracts of $100 million or more, up from $15 million.

On July 30, 2026, DOD substantially revised its overhaul of Part 230 to reflect changes in Cost Accounting Standard (CAS) coverage and recent National Defense Authorization Act requirements. For example, DOD added DFARS Subpart 230.1, General, and DFARS 230.101, Cost accounting standards, to replace the dollar values in the CAS at 48 C.F.R. 9903.202-1 to 9903.202-7 with the higher $100 million value from Section 1806 of the Fiscal Year 2026 National Defense Authorization Act. DOD also added DFARS 230.201-70, Applicability, to govern in lieu of FAR 30.201 regarding full and modified CAS coverage for DOD contracts and to reflect the higher dollar value threshold from the NDAA. Within this subpart, DOD also added new instructions for solicitation provisions and contract clauses in DFARS 230.204 and 230.205-70, respectively. DOD also added new Subpart 230.3, Evaluation and Award. Within the new subpart, it added DFARS 230.301, contractor disclosure statements, to incorporate the higher $100 million value in lieu of the standards in 48 C.F.R. 9903.201-3 and 9903.202 and added DFARS 230.70, Evaluation and award, and 230.470, Postaward, to reflect the new solicitation and contract clause instructions that were also added. Finally, DOD added several new clauses, primarily to reflect the application of the new DFARS rules (and higher CAS threshold) in lieu of the official version CAS or certain rules or clauses related to original FAR Part 30: DFARS 252.230-7993,  Alternate A, Cost Accounting Standards Notices and Certification; DFARS 252.230-7994, Alternate A, Proposal Disclosure - Cost Accounting Practice Changes; DFARS 252.230-7995, Alternate A, Cost Accounting Standards; DFARS 252.230-7996, Alternate A, Disclosure and Consistency of Cost Accounting Practices; DFARS 252.230-7997, Alternate A, Disclosure and Consistency of Cost Accounting Practices - Foreign Concerns; DFARS 252.230-7998, Alternate A, Administration of Cost Accounting Standards; and DFARS 252.230-7999, Alternate A, Cost Accounting Standards—Educational Institution.

DFARS Part 231 (Contract Cost Principles and Procedures) - Updated September 11, 2026

Most of the changes to Overhauled DFARS 231 are modest “plain language” revisions and updates to cross-references to the Overhauled FAR Part 31. One notable change is guidance that educational institutions, for simplicity, can request a waiver of the prohibition in DFARS 231.303 exempting such institutions from the 26% indirect cost limitation in OMB Circulate No. A-21.

On August 4, 2026, DOD updated its overhaul of Part 231 (Contract Cost Principles and Procedures).  Most prominently, DOD added a new DFARS 231.001-70 (Applicability) to state that neither Part 231 nor FAR Part 31 apply to contracts with nontraditional defense contractors, in accordance with Section 1826(a)(10) of the Fiscal Year 2026 NDAA. DOD also fixed a significant typo in DFARS 231.205-22 (Lobbying and Political Activity Costs) to state that costs associated with preparing information on the actual or projected economic or employment impact in a particular state or congressional district of an acquisition program are unallowable – not allowable – if all research, development, testing, and evaluation is not complete. Finally, the updated made a variety of plain language revisions, added some statutory references for requirements, and corrected some cross-referencing of other DFARS provisions. 

DFARS Part 232 (Contract Financing)

• Minimal, if Any, Substantive Changes: Overhauled DFARS Part 232 continues to provide DOD-specific contract financing policy, procedures, and clause prescriptions.
  • Plain Language: As with many other parts, the Overhauled DFARS Part 232 consolidates and updates text to plainer language, such as “shall” to “must.”
  • Shift to PGI: Procedural details related to fraud-related reporting (232.006-5), unusual progress payments approval (232.501-2), electronic payment processing procedures (232.7003), and various contract debt collection steps (232.603 through 232.671) have been removed from the DFARS into the PGI.
  • Fast Payment Procedures: A new DFARS 232.12 provision has been added to address the conditions for use of “Fast Payment Procedures” for individual orders exceeding the simplified acquisition threshold for brand-name commercial product commissary resale subsistence or medical supplies for direct shipment overseas.
    
    

DFARS Part 233 (Protests, Disputes, and Appeals) - Updated August 28, 2026

Part 233 is short in the original and overhauled DFARS. Two of the more notable changes appear to strive for greater clarity. First, original DFARS 233.102, then entitled General, provided that if the Government exercised its authority to limit disclosure of information because of supply chain risks with respect to a covered information system, “no action undertaken by the Government under such authority shall be subject to review” in a bid protest at the U.S. Government Accountability Office (GAO) or federal court. The revised provision states: “If the Government limits information disclosure under the authority provided in [new] DFARS 240.271-6(d), actions taken by the Government under such authority are prohibited from challenge in a bid protest” before GAO or federal court. This provision is also renumbered and retitled “Limited information disclosure,” which aligns more clearly with its topic. Second, original DFARS 233.104, Protests, is now DFARS 233.105, and its text is moved to new DFARS 233.105-370, Postaward. The revisions to DFARS 233.105-370 appear also to be aimed at clarity, attempting to provide instruction and timing requirements for suspending performance or terminating awards in response to notice of a GAO bid protest, except when the Department exercises its authority to override the automatic stay. The one implementing clause, Choice of Law (Overseas), is unchanged.

On August 24, DOD revised its overhaul of Part 233 to incorporate the increased dollar value for protests of DOD task or delivery orders in Section 885 of the Fiscal Year 2025 National Defense Authorization Act. This update is reflected in DFARS 233.105(b), which governs the suspension of performance after timely notice of a GAO bid protest and increases the dollar threshold for application of the suspension to a DOD task or delivery order to $35 million. The revision also made minor wording, numbering, and cross-reference updates.

DFARS Part 234 (Major System Acquisition) - Updated September 16, 2026

Overhauled Part 234 does not remove any of the current content but rather reorganizes that content. The most significant result of this reorganization is the creation of Subpart 234.72, Acquisition Strategy for Major Systems, with streamlined content from the current 234.004. Additional guidance on acquisition strategy was moved to the PGI. Other notable updates to the overhauled Part 234 include increasing the threshold for the requirement for an earned value management system (EVMS) from $20 million to $50 million and the threshold for an EVMS that is approved by the cognizant federal agency from $50 million to $100 million. The class deviation replaces the corresponding solicitation provision and contract clause for EVMS at DFARS 252.234-7001 and -7002 with DFARS 252.234-7998 and -7999, respectively, which update those thresholds but were otherwise virtually identical to the predecessor provisions until the August 2026 update, discussed below.

On August 5, 2026, DOD made numerous changes to its overhaul of this part and its implementing clauses. First, within subpart 234.2, Earned Value Management System, the update adds exemptions from the subpart for contracts primarily for software or awarded to nontraditional defense contractors; the latter exemption can be waived by the head of the contracting activity upon a written determination that applying the EVMS requirements is in the Government’s best interest.

Second, subpart 234.70, Acquisition of Major Weapons Systems as Commercial Products, is removed and marked “reserved” in response to the repeal of 10 USC 3455 in the FY2026 National Defense Authorization Act.

Third, subpart 234.71, Cost and Software Data Reporting, or CSDR, is substantially revised, among other things, to include Table 1 to DFARS 234.7101(a)(1) that identifies acquisition pathways to meet identified program criteria for the applicable dollar thresholds, and Table 2 to DFARS 234.7101(a)(2) is similarly added to identify acquisition pathways to meet program criteria for different dollar thresholds. The revised subpart also includes a waiver provision at DFARS 234.7103, stating that its requirements can be waived only by the Office of the Secretary of Defense, Director of Cost Assessment and Program Evaluation. And, a new DFARS 234.7104 is added to identify CSDR procedures for contracting officers to follow. These changes reflect updates to DoDI 5000.73, Cost Analysis Guidance and Procedures, and DoDM 5000.04, Cost and Software Data Reporting, dated May 7, 2021, both of which implement DoDI 5000.02, Operation of the Adaptive Acquisition Framework, intended to restructure defense acquisition guidance to improve effectiveness.

Fourth, DOD revised DFARS 234.7202, relating to major systems acquisition program procedures, to add paragraph (f) limiting the number of fixed-price options for low-rate initial production to no more than one lot, in accordance with 10 USC 4231. This limitation can be waived, as set forth in new DFARS 234.7202(f).

Fifth, the update also revises several DFARS clauses. For example, DFARS clause 252.234-7998, Notice of Earned Value Management System, is revised to exclude nontraditional defense contractors. DFARS clause 252.234-7999(i)(3)(iv), Earned Value Management System, is modified to state that a system disapproval will apply if the initial EVMS validation is not successfully completed within the timeframes approved by the contracting officer, and removes reference to material weaknesses in high risk guidelines in Electronic Industries Alliance Standard 748 standards. DFARS clause 252.234-7003, Notice of Cost and Software Data Reporting System, is removed and marked as “reserved.” DFARS 252.234-7004, Cost and Software Data Reporting - Basic, is significantly rewritten, as is the alternate version of the clause, with new requirements, including a CSDR-readiness review.

DFARS Part 235 (Research and Development Contracting)

Overhauled Part 235 contains one major change, which is moving the entirety of the section on special use allowances for research facilities acquired by educational institutions (currently in DFARS 252.235.015-70) to the PGI. The PGI text does not substantively differ from the previous DFARS, however. Apart from moving that section to the PGI, most of the overhaul to Part 235 consists of reorganizing to follow the acquisition lifecycle of presolicitation, evaluation and award, and post-award phases and plain-language revisions and updating the DFARS cites.

DFARS Part 236 (Construction and Architect — Engineer Contracts)

The changes made to DFARS Part 236 support the goal of streamlining and simplifying the DFARS.  The main changes are to reorganize Part 236 to be more chronological and moving provisions to PGI 236.    

• Reorganization: The primary changes in the overhauled DFARS Part 236 are organizational.  Similar to the other overhaul efforts, this Part has been reorganized to track the acquisition lifecycle.  Subpart 236.1 now focuses on Pre-Award issues, Subpart 236.2 involves provisions related to Evaluation and Award, and Subpart 236.3 relates to Postaward issues.  Those subparts are then further divided by the topic of the contract and include specific requirements for construction contracts and architect-engineer contracts. 
• Revised Definitions: The overhauled version removes the definition of “construction activity,” which had previously been defined as the DOD activity responsible for the technical aspects of construction.  This change appears to be aimed at streamlining, since that term was not used in the DFARS.  The overhaul also updates definition of “Marshallese firm” in DFARS 236.001 to define the term instead of simply referencing the definition in DFARS 252.236-7012, Military Construction on Kwajalein Atoll—Evaluation Preferences.
• PGI Changes: The overhaul also moves some provisions previously found in DFARS Part 236 to the corresponding PGI.  For example, PGI 236.371 has been added to include guidance for Architect-Engineer post construction evaluation.  That guidance was previously found at DFARS 236.604.  In addition, PGI 236 has been subdivided to align with the new subparts and similarly tracks the acquisition life-cycle.

DFARS Part 237 (Service Contracting) - Updated August 28, 2026

• Restructuring: One of the most visible changes is the restructuring of DFARS Part 237 to align more closely with revised FAR Part 37. Subparts have been renumbered and retitled, with legacy DFARS sections moved to new locations that track the overhauled FAR’s revised architecture. For example, material previously located in Subpart 237.1 has been redistributed to new subparts addressing personal services (Subpart 237.2), inherently governmental functions (Subpart 237.3), and other service considerations (Subpart 237.8) (e.g., prohibitions on contracting for firefighting or security-guard functions, and contracts for management services, among other things); original DFARS Subpart 237.2, addressing advisory and assistance services, is now Subpart 237.4. One change within the new Subpart 237.4 is removal of the prior admonition in original DFARS 215.101-2-70(b)(3) prohibiting use of lowest price technically acceptable source selection processes when acquiring audit services. 
• More content moved to PGIs or deleted: Several provisions that previously contained detailed requirements in DFARS text are now reduced to shorter DFARS statements plus Procedure, Guidance, and Information (PGI) references (notably for in‑sourcing notices, surveillance/quality assurance surveillance plan (QASP) guidance, and education service agreement format).
• Technical and administrative updates: The overhaul includes numerous technical edits, such as updated statutory citations, revised PGI references, and removal of obsolete provisions.
• Clauses renumbered but generally unchanged: DFARS 252.237-7000, Notice of Special Standards of Responsibility, is renumbered DFARS 252.237-7997. Its text is unchanged except to update how to obtain the Government Auditing Standards. DFARS 252.237-7019, Training for Contractor Personnel Interacting with Detainees, is renumbered 252.237-7998, and the PGI reference within the clause is updated. Other DFARS 252 clauses reprinted in the class deviation are not substantively changed.
• Revision 1 to Deviation Text: On July 24, 2026, DOD revised its overhaul of Part 237 to implement in revised DFARS 237.802 Section 335 of the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2026, which amended the prohibition on contracting for the performance of firefighting or security-guard functions. The revision adds DFARS 237.802-80 to implement Section 854 of the NDAA for FY 2025 and prohibits certain contracts for online tutoring services that could result in personal data of U.S. citizens being transferred to China. This revision also removed the reference to use of FAR clause 52.222-26, Equal Opportunity, from PGI 237.7204, relating to educational services agreements, consistent with Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity. The revision also made minor wording, numbering, and cross-reference updates and reorganized the Part 252 clauses, without substantively changing them.

DFARS Part 239 (Acquisition of Information Technology)

Like revised FAR Part 39, the overhauled version of DFARS Part 239 clarifies that it applies for acquisitions of information and communication technology, including information technology for national security. New DFARS Part 239.1 includes several changes for commercial products and services that mostly align with the statutory preference for acquiring commercial products and services to the maximum extent possible.  For example:

• Revised DFARS 239.1 adds that its requirements for commercial products and commercial services apply “Presolicitation.”
• Revised DFARS 239.170 eliminates any perceived discretion previously given to the contracting officer by changing the use of “may” to “shall” to obtain a written determination from the head of the contracting activity (HCA) that no commercial items can meet the agency’s needs based on the market research conducted. Under the new DFARS 239.170, a contracting officer “must not enter into a contract in excess of the simplified acquisition threshold for information technology products or services that are not commercial products or commercial services unless the head of the contracting activity determines in writing that no commercial items are suitable to meet the agency's needs, as determined through the use of market research appropriate to the circumstances.” This aligns with the statutory and Administration preference for acquiring commercial products and services “to the maximum extent practicable.”
• Revised DFARS 239.170 deletes “products” and “services” and replaces them broadly with “items”. This seemingly comports with the requirement under FAR 10.001(a)(3) to conduct market research to determine whether commercial products, services, nondevelopmental items, and commercial components—assuming all qualify as “items” under the new DFARS 239.170—are available to meet the Agency’s needs. But it also conflicts with prior statutory changes that revised references to “commercial items” to separate the categories of “commercial products” and “commercial services.”
• Despite its reference to overhauled FAR 10.001(a)(3), overhauled DFARS Part 239.170—like its previous version—appears to omit the requirement for the Agency to evaluate whether its requirements could be modified to acquire available commercial items and components, to the extent they cannot meet the Agency’s requirements as stated. See FAR 10.001(a)(3); see also 10 U.S.C. § 3453(b)(3).  

New DFARS Part 239 relocates the requirements for supply chain, security and privacy for computer systems under the original DFARS 239.71-73 to new DFARS Part 252.  The remaining changes are primarily limited to changing  “shall” to “must”. 

DFARS Part 240 (Information Security and Supply Chain) - Updated September 18, 2026

The DFARS overhaul created a new Part 240, Information Security and Supply Chain Security, to correspond to the expanded FAR Part 40 in the overhauled FAR. There is also a new PGI 240 to accompany the new DFARS Part. The provisions in new Part 240 were primarily relocated from old Parts 204, 225, and 239. Most of the prohibitions and restrictions are required by statute, and thus there is little substantive change to the provisions aside from plain-language edits. On July 16, 2026, an updated DFARS Part 240 class deviation that further revises Part 240 and supersedes the December 2025 class deviation was released (Revision 2). On September 3, 2026, another revision was issued (). This summary reflects the class deviation text through Revision 3, which supersedes prior versions.

Security Prohibitions and Exclusions: The new DFARS Part 240 begins with Subpart 240.2, Security Prohibitions and Exclusions, which includes the following:

• DFARS 240.270, Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services and Equipment, which implements Section1656 of the FY 2018 NDAA and Section 889 of the FY 2019 NDAA and was previously located at DFARS 204.21.
• DFARS 240.271, Requirements for Information Relating to Supply Chain Risk, which implements 10 U.S.C. 3252 and elements of Department of Defense (DOD) Instruction 5200.44, Protection of Mission Critical Functions to Achieve Trusted Systems and Networks (TSN) and was previously located at DFARS 239.73.

New Subpart 240.3, Safeguarding Information, relocates information security requirements from old DFARS Subparts 204.4, 204.73, 204.75, and 239.71, including the Cybersecurity Maturity Model Certification (CMMC) program. The substantive requirements are largely unchanged, although some procedures have been moved to the PGI. As of July 13, 2026, DOD suspended the November 2026 CMMC Phase 2 Transition. Per the suspension announcement, contractors must maintain baseline compliance with NIST SP 800-171 Rev. 2 under DFARS 252.204-7012, while preparing for solicitations to require only CMMC Level 1 (Self) or Level 2 (Self) assessments during the suspension period. Revision 3 implements this pause and instructs contracting officers to remove or revise the CMMC requirements in new and existing solicitations and contracts in accordance with the Department’s July 13, 2026 memorandum regarding suspension of CMMC Phase 2 requirements.

Prohibited Sources: The revisions also relocate DFARS 240.272, “Prohibited Sources,” to DFARS 240.70. Prohibited Sources addresses U.S. Department of the Treasury restrictions, prohibitions on acquisition of certain items from Chinese military companies, prohibitions on contracting with state sponsors of terrorism, and prohibitions on acquisitions of certain foreign commercial satellite services – this was previously located at DFARS 225.7.

Overseas Fuel Acquisition: The class deviation includes within DFARS Subpart 240.70 provisions still identified with Part 225, specifically DFARS 225.7006, restriction on acquisition of fuel for overseas contingency operations. The associated clause, DFARS 252.225-7964, is also included. Presumably, these provisions will be either renumbered or moved back to Part 225.

Entity Prohibition: Consistent with Section 805 of the FY 2024 NDAA, DFARS 240.7003-2(b) adds an “entity prohibition” related to Chinese military companies that incorporates the expanded definition above. The entity prohibition provides that DOD cannot “award, renew, or extend a contract (including by e.g., exercising an option)” with “a Chinese military company operating in the United States; or an [e]ntity that is subject to the control of a Chinese military company.” The prohibition does not apply to DOD’s procurement of “products or services that provide[] a service that connects to the facilities of a third party, including backhaul, roaming, or interconnection arrangements,” using terms defined in DFARS 240-7003-1 that are identical to those in overhauled FAR 52.204-90. The entity prohibition also does not apply to modifications, extensions, or renewals of contracts awarded before June 30, 2026, certain intelligence activities, or “components.”

Lobbyist Prohibition: Consistent with Section 851 of the FY 2025 NDAA, DFARS 240.7003-2(d) adds a prohibition on contracting with “an entity, a parent company of such entity, or a subsidiary of such entity that is a party to a contract with a covered lobbyist,” which is defined in DFARS 240.7003-1. The prohibition does not apply to any “entity that made reasonable inquiries regarding the lobbying activities of another entity and determined such entity was not a covered lobbyist.” The term “reasonable inquiries” is not defined.

Temporary Waiver for Alibaba: As explained in the Revision 3 deviation cover memo, as the result of ongoing litigation, DOD has temporarily waived the lobbyist prohibition and definition of Chinese military company under DFARS subpart 240.70, Prohibited Sources, as it applies to Alibaba Group Holding Limited and Alibaba Group (U.S.) Inc. The waiver remains in effect until the court rules on Alibaba's request for temporary injunctive relief or 60 days after the hearing on that request, whichever occurs first. For all other purposes, however, contracting officers must continue to treat Alibaba as a Chinese military company pursuant to its section 1260H designation.

Solicitation Provisions and Contract Clauses (Part 252): The implementing DFARS clauses for new Part 240 have mostly retained their numbering from the old DFARS Part 204 (e.g., DFARS 252.204-7012 and 252.204-7021 still reflect their prior association with DFARS Part 204 despite the move to Part 240). One exception is old DFARS 252.204-7020, NIST SP 800-171 DOD Assessment Requirements, which is relocated to overhauled DFARS 252.240-7997. DFARS 252.204-7012 was updated to add “Revision 2” in connection with NIST SP 800-171 controls in paragraph (b)(2)(i). The class deviation also includes a new DFARS 252.240-7007, Prohibitions Relating to Chinese Military Companies, DFARS 252.240-7995, Prohibition on Contract Awards with Entities that Contract with Lobbyists for Chinese Military Companies – Representation, and DFARS 252.240-7996, Prohibition on Awards to Chinese Military Companies – Representation, each of which must be included in all solicitations and contracts, including those for commercial products and services. Similar to representation clauses in the overhauled FAR, DFARS 252.240-7995 and -7996 provide that by submitting a proposal, the offeror makes the applicable representation.

DFARS Part 241 (Acquisition of Utility Services) 

The overhaul of DFARS Part 241 relocates the detailed connection and service charge procedure out of DFARS text and into PGI by cross-reference and updates the third-party financed project paragraph numbering and statutory citations, including the stated maximum contract period for renewable energy authority.

• Content moved (DFARS text to PGI): DFARS 241.202(1) contained the order of precedence for connection and service charges. The overhauled Part replaces that narrative with a cross-reference to PGI 241.202(1), moving the procedure to PGI.
• Third-party financed projects (241.102): The third-party financed project discussion is renumbered (241.102(b)(7) becomes 241.102(b)(3)), and the statutory citations are updated (including replacement of the previous 10 U.S.C. 2394 and 10 U.S.C. 2394a references with 10 U.S.C. 2922 and 10 U.S.C. 2992a). The stated maximum contract period for renewable energy authority is increased from 25 years to 30 years.
• Plain-language tightening (241.201): The phrase “as a matter of comity” is removed from the independent regulatory body compliance statement, and the provision is tightened into shorter statements while retaining the same policy.
  
  

DFARS Part 242 (Contract Administration)

Consistent with most overhauled DFARS parts, the revised Part 242 focuses primarily on streamlining, consolidation, plain-language modernization, and relocating procedural content from the DFARS text to PGI, along with renumbering and cross-reference updates to align with overhauled FAR Part 42. Notable changes include:

• DCMA Administration: The overhaul clarifies when DCMA should administer contracts and when contracting activities may locate contracting office personnel at contractor facilities. The class deviation renumbers DFARS 242.202 to 242.202-70 and provides that DCMA “must administer any contract that requires performance of any contract administration function at or near a contractor facility” unless an exception applies. Contracting activities generally may not locate personnel at contractor facilities except “in support of contracts retained for administration” by DOD activities or as permitted by DFARS Subpart 242.74. The deviation maintains the list of contracts that DOD activities must retain for administration (rather than a “shall not retain ... except” framing) and adds “[c]ontracts awarded to commercial entities for shipbuilding, conversion, and repair at the facilities of such entities” to that retained list. The deviation also breaks out secondary delegations of contract administration, previously embedded within 242.202(e)(1), into a new stand-alone section at 242.202-71.
• Relocation of Information to PGI: The deviation relocates criticality designator assignment procedures, production and surveillance reporting requirements, and guidance on mitigating accounting system deficiency risks to the PGI. It reorganizes postaward orientation from original Subpart 242.5 into a new Subpart 242.76 (sections 242.7600 through 242.7605), retaining certain conference-related text in the DFARS (e.g., use of DD Form 1484 and discussion items for contracts with the Cost and Software Data Reporting clause) while moving additional postaward conference content to the PGI. The subpart numbering scheme is realigned throughout to correspond with the revised FAR Part 42 structure – for example, Indirect Cost Rates moves from Subpart 242.7 to Subpart 242.5, and Subpart 242.14 (Traffic and Transportation Management), which contained no supplemental DFARS text, has been removed.
• Clause Revisions: Clause 242.1502 on past performance evaluations has been renumbered to 242.1102-70, with a new paragraph (b) directing contracting officers to use DFARS 215.104-70(g) thresholds instead of FAR 42.1102(b)–(d) when evaluating contractor performance. The contract clauses previously at DFARS 252.242-7004, -7005, and -7006 have been renumbered to -7997, -7998, and -7999, respectively, with conforming terminology and citation updates but without substantive changes to the core requirements. Other cross-reference updates include the small business subcontracting plan clause (252.219-7004 to 252.219-7997) and, consistent with the revised FAR Part 42, the CAS-related subpart references in 242.7301(c) (from FAR subparts 30.2 and 30.6 to 30.1, 30.2, and 30.4).
• No Change to Business System Requirements: Notably, the class deviation does not make any substantive changes to business system requirements. The criteria, withholding thresholds, and procedures for contractor business systems are unchanged.

DFARS Part 243 (Contract Modifications) - Updated September 16, 2026

• The overhaul of DFARS Part 243 primarily reorganizes and renumbers the part and updates internal cross-references, while retaining the same controls for unpriced change orders and REA certification. The overhaul also consolidates certain Part 252 clause text into Part 243.

  • Reorganization and renumbering:The prior 243.170 to 243.172 series is renumbered as 243.270 to 243.272, change order administration and definitization coverage in the prior 243.204 and 243.204-70 series is renumbered into 243.304 and 243.370, and clause prescription structure in the prior 243.205 series is renumbered into the 243.305 series.
  • Cross-reference updates:The “application of modifications” cross-reference is updated from 204.1671 to 204.201-72, and the employment-impact notification discussion is updated to reference the applicable Part 252 clause (252.249-7002) rather than prescription phrasing tied to 249.7003(c).
  • Clause text consolidated in-part:The overhauled Part 243 includes the text of 252.243-7001 and 252.243-7002 within the same Part 243 document, rather than presenting only the Part 243 prescription framework without clause text.

  On August 5, 2026, DOD updated the overhaul of this part. The update is minor, adding a provision and reference for unilateral changes to implement Executive Orders at DFARS 243.301-70, streamlining DFARS 243.370-7 regarding unpriced change orders, and making minor typographical fixes.
  
  

DFARS Part 244 (Subcontracting Policies and Procedures) - Updated August 28, 2026

The Part 244 deviation includes minor revisions. Updates include changing the titles of the subparts to conform to the acquisition lifecycle and plain-language revisions, such as changing “shall” to “must” or “will” and streamlining wording without substantive changes. The requirements and processes for the contracting officer’s consent to subcontracts and role in overseeing purchasing system reviews remains the same.

The Part 244 deviation also updates references to the clauses for Contractor Business Systems and Contractor Purchasing System Administration, which are now located at DFARS 252.242-7005 and 252.244-7998, respectively. Aside from minor wording edits, the Contractor Purchasing System Administration clause is unchanged from previous DFARS 252.244-7001, including the 24 system criteria for the contractor’s purchasing system.

On July 29, 2026, DOD updated its overhaul of Part 244 to implement Section 1826 of the National Defense Authorization Act for Fiscal Year 2026, which exempts nontraditional defense contractors from the requirements for establishing and maintaining acceptable purchasing systems and allows the head of the contracting activity to waive the exemption if in the Government’s best interests. The revision moves contract clause instructions to DFARS 244.070 and adds DFARS 244.071, restating the exemption and ability to waive the exemption as set forth in the NDAA. Similarly, DFARS 244.301, Contractors’ purchasing systems reviews, is amended to state that it does not apply to nontraditional defense contractors. Reviews of commercial product and service determinations and the adequacy of contractor counterfeit electronic part detection and avoidance systems are moved to DFARS 244.301-71. Finally, Alternate I of DFARS clause 252.244.7998, Contracting Purchasing System Administration, is modestly updated to fix typos and correct cross-references.

DFARS Part 245 (Government Property) - Updated September 16, 2026

The overhaul of DFARS Part 245 largely maintains the framework governing government property in contractor possession. The revisions focus primarily on streamlining the regulatory text, updating outdated language, and relocating detailed procedures to the PGI. Many sections are now shorter in length, with cross-references to PGI 245 for implementation procedures. The overhaul also incorporates plain-language drafting updates and clarifies certain requirements regarding government-furnished property (GFP), contractor property management systems, and reporting obligations.

• Subpart 245.1: Subpart 245.1 contains primarily plain-language revisions and clarifications. “Shall” has been replaced with “must” in many places, and “use” is replaced with “insert” with respect to clauses. Minor grammatical edits have also been incorporated into the policy statement to improve readability. Overhauled DFARS 245.105 clarifies the contracting officer’s responsibilities for making a final determination regarding a contractor’s property management system.
• Subpart 245.2: Subpart 245.2, which previously had one provision referring to PGI 245.201-70 for security classification, has been removed entirely.
• Subpart 245.3: Subpart 245.3 has experienced minor reorganization and renumbering but remains substantively the same. For instance, contracts with foreign governments or international organizations have been renumbered from DFARS 245.302 to 245.370, although the underlying policy remains unchanged. In addition, the definition of “major defense equipment” has been moved to DFARS 245.370(a).
• Subparts 245.4 and 245.5: There are no substantive edits to Subpart 245.4. Subpart 245.5, including Section 245.570 (Storage at the Government’s expense), has been removed entirely.
• Subpart 245.6: Subpart 245.6, aside from replacing “shall” with “must,” contains only minor revisions. Certain procedural information has been relocated to the PGI. For instance, the information formerly located at DFARS 245.602-1 (Inventory Disposal Schedules) has been moved to the PGI. Similarly, the procedures formerly located at DFARS 245.604 (Sale of Surplus Property) have largely been relocated to PGI 245.604, where the detailed procedures governing sales approaches, bidding procedures, and negotiated sales now reside.

On September 9, 2026, DOD made modest updates to its overhaul of Part 245 to include an instruction to exclude the DFARS clause 252.245-7003 and FAR clause 52.245-1 in contracts awarded to nontraditional defense contractors unless the exemption is waived. The update also fixed a handful of cross-references and deleted DFARS 245.602.70, which merely referenced a PGI for processing a plant clearance.

DFARS Part 246 (Quality Assurance)

As with the other DFARS parts revised in the overhaul, Part 246 adopts plain-language drafting throughout by replacing “shall” with “must” and “use” with “insert” in clause prescriptions. There are relatively few substantive changes to Part 246. Instead, the revisions largely consist of moving certain guidance to the DFARS Procedures, Guidance, and Information (PGI), updating related contract clauses, and reorganizing sections within Part 246.

• Deletions: The most significant change in the overhauled Part 246 is the deletion of Section 246.408 (Single-agency assignments of Government contract quality assurance) and its related Subsections 246.408-70 (Subsistence) and 246.408-71 (Aircraft). That section has been relocated to DFARS PGI Part 246. In connection with that change, a new Section 246.201 (General) was added to direct users to PGI Part 246 for the quality assurance procedures removed from the DFARS.
• Contract Clauses: The overhaul updates contract clause provisions and numbering. The prior “Warranty of Data” clause reference at 252.246-7001 has been renumbered to 252.246-7998, and its associated technical data rights clause has been renumbered and renamed to 252.227-7989 (Rights in Technical Data, Computer Software, and Computer Software Documentation—Other Than Commercial Products or Commercial Software). As part of the restructuring, the prior Alternate I to the Warranty of Data clause is deleted, and the former Alternate II is now the sole alternate to the clause. However, elsewhere in the overhauled Part 246, the Warranty of Data clause is referenced only generically as a “252.246-7XXX” clause.
• Organization: Overhauled Part 246 also includes several internal organizational adjustments. Former Section 246.407 (Nonconforming supplies or services) has been renumbered to 246.407-70. In addition, a new heading 246.703 (Criteria for use of warranties) has been added and former Section 246.704 (Authority for use of warranties) has been relocated to 246.703-1.
  
  

DFARS Part 247 (Transportation)

Part 247 retains most of its original structure. Most of the changes are minor as well, including minor streamlining changes (e.g., abbreviating to “NDAA”), plain-language modernization (“insert” instead of “use”), relocating procedural content from the DFARS text to PGI (such as guidance regarding technical provisions for stevedoring contracts), and renumbering and cross-reference updates to align with overhauled FAR Part 47. The implementing Part 252 clauses are unchanged.

DFARS Part 248 (It is reserved in the original DFARS. The DFARS overhaul of this Part is limited to a class deviation memo instructing use of the overhauled version of FAR Part 48.)

DFARS Part 249 (Termination of Contracts)

The overhaul of DFARS Part 249 makes targeted numbering and organizational changes, including renumbering within the termination contracting officer duties section, deleting an embedded class deviation reference in the congressional notification discussion, and consolidating certain Part 252 clause text into the Part 249 document.

• Renumbering within 249.105: “Termination status reports” is renumbered from DFARS 249.105-1 to DFARS 249.105-70, and “release of excess funds” is renumbered so that it appears at DFARS 249.105-1 rather than DFARS 249.105-2. The associated PGI cross-references are updated to match the revised numbering.
• Deletion in 249.7001: The embedded reference in the text to DOD Class Deviation 2011-00002 and the related Iraq and Afghanistan exception language is deleted from the congressional notification discussion.
• Clause text consolidated in-part: The overhauled Part 249 includes the text of clauses that Part 249 prescribes (including 252.249-7000 and 252.249-7002) within the Part 249 document, rather than limiting the Part 249 presentation to policy and prescriptions.
  
  

DFARS Part 250 (Extraordinary Contractual Actions)

The substance of the Overhauled Part 250 is mostly unchanged.  The primary change is in 250.102-1, Delegation of authority, which deletes the phrase “level of” that previously preceded “head” to preclude delegating applicable authority below the HCA generally: “Authority under FAR 50.104 to approve actions obligating $90,000 or less may not be delegated below the head of the contracting activity.”  The remaining changes to new DFARS Part 250 are limited to changing “shall” to “must.”

DFARS Part 252 (As DOD overhauls each substantive DFARS Part, the class deviation text of that Part includes the implementing Part 252 clauses, either in their original form or as overhauled.)

DFARS Part 270 (Defense Contracting Programs) – Overhauled as of August 4, 2026

On August 4, 2026, DOD posted its overhaul of Part 270 (Defense Contracting Programs). The overhaul primarily revises DFARS Subpart 270.1 (Pilot Program to Incentivize Contracting with Employee-owned Businesses) to remove the requirement for a justification and approval for contracts under the program and instructing the contracting officer in DFARS 270.102(b) to state that the award is made pursuant to FAR 6.103-5 and Section 874 of the NDAA for Fiscal Year 2022. Other changes are “plain language” and formatting related.