On June 23, 2026, the Federal Acquisition Regulatory Council (FAR Council) published in the Federal Register its first set of proposed rules to revise the entire Federal Acquisition Regulation (FAR), thus initiating the second formal notice-and-comment rulemaking phase of the “Revolutionary FAR Overhaul” (RFO). This first set of proposed rules included 20 FAR Parts and the associated clauses from Part 52 of the FAR. On September 18, 2026, the FAR Council issued its second set of proposed rules, this time covering 16 FAR Parts and the associated FAR Part 52 clauses. Each time, the FAR Council has issued four notices of proposed rulemaking covering multiple FAR Parts, with a 30-day public comment period. The final set of four notices should come out in 2026 and include the proposed overhaul of the remaining FAR Parts.  

The revisions proposed in this second rulemaking phase of the overhaul have gone farther than the revisions made in the RFO class deviation text. In some instances, the proposed rules have included other pending rulemakings as well. These changes, and the historic effort to rewrite the FAR, make it critical that contractors follow this rulemaking process closely.

Wiley’s Government Contracts Practice has been closely following the RFO process since its inception, using its thought leadership to identify those changes that are most impactful to industry. Here, you can find Wiley’s ongoing analysis of the RFO as it proceeds through the formal rulemaking process.

Insights

ALERT | September 25, 2026

FAR Council Issues Second Round of FAR Overhaul Proposed Rules Covering 16 FAR Parts: Analysis of Proposed Parts 8, 12, 13, 15, 16, 17, 35, 38, 44, and 51, Plus Associated FAR Part 52 Clauses

ALERT | September 23, 2026

FAR Council Issues Second Round of FAR Overhaul Proposed Rules Covering 16 FAR Parts: Analysis of Proposed Parts 9, 14, 27, 28, 36, and 47 plus associated FAR Part 52 clauses

ALERT | July 7, 2026

FAR Council Updates Class Deviation Text for Part 16 to Implement Executive Order on Preference for Fixed-Price Contracts; Wiley Updates FAR and DFARS Overhaul Site

ALERT | July 2, 2026

FAR Council Proposes Revised CUI Framework as Part of Revolutionary FAR Overhaul With Important Guidance and Clarifications

ALERT | June 30, 2026

FAR Council Proposes Consolidated Part 40 Framework for Security and Supply Chain Compliance

ALERT | June 23, 2026

FAR Council Begins Rulemaking to Implement FAR Overhaul, Proposing Revisions to 20 FAR Parts

To stay informed on all of the announcements from the Trump Administration, please visit our dedicated resource center below.

Wiley's Trump Administration Resource Center

Resources

- FAR Overhaul Class Deviations

- DFARS Overhaul Class Deviations

- Related Insights

- Government Contracts Practice Page

- Government Contracts Attorneys

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