The Federal Acquisition Regulation (FAR) is undergoing historic revisions designed to streamline procurement processes and enhance efficiency within federal agencies. Executive actions including Executive Order (EO) 14275, “Restoring Common Sense to Federal Procurement,” set the stage for a comprehensive modernization of the Government’s acquisition system. The “Revolutionary FAR Overhaul” (RFO), launched in response to EO 14275, marks the first time the FAR has been comprehensively reviewed and updated since its inception in the 1980s. This ambitious two-phase process has proceeded quickly and immediately introduced changes to the federal acquisition landscape.
The first phase of the overhaul involved the issuance of Part-by-Part revisions to the FAR, posted to the RFO website, that agencies adopted via class deviation as each Part was overhauled. That phase is completed, and numerous agencies have issued solicitations and contracts with the overhauled terms.
The second phase of the overhaul started June 23, 2026, when the FAR Council published in the Federal Register proposed rules to revise 20 FAR Parts, including the contract clauses within FAR Part 52 associated with those Parts, through formal notice-and-comment rulemaking. This second phase will be continuing through 2026 with further notices of proposed rulemaking and an anticipated goal of completing the formal rulemaking process by the end of 2026. The revisions proposed in this second phase of the overhaul go farther than the revisions made in the class deviation text and have included other pending rulemakings, making it critical that contractors follow this rulemaking process. As a result of the phased implementation of the overhaul, contractors also may have contracts under the “original” FAR, the overhauled FAR adopted via class deviation, and eventually, contracts governed by the formally overhauled FAR.
Wiley’s Government Contracts Practice has been at the forefront of providing contractors with timely analysis to navigate this historic RFO process, and we’re continuing our thought leadership now that the RFO has moved to the second, formal rulemaking stage.
- At our FAR Overhaul Rulemaking site, you can find Wiley’s analysis of the proposed FAR overhaul, updated as the formal rulemaking phase of the overhaul progresses.
- At our FAR Overhaul Class Deviations site, you can find Wiley’s Part-by Part analysis of the notable RFO class deviation text changes, as well as information about the new FAR Companion, which includes non-regulatory guidance for government acquisition professionals.
- At our DFARS Overhaul Class Deviations site, you can find Wiley’s Part-by-Part analysis of the notable DFARS class deviation text changes.
![]() Visit the FAR Overhaul Rulemaking site |
|
![]() Visit the FAR Overhaul Class Deviations site |
![]() Visit the DFARS Overhaul Class Deviations site |
Learn more about Wiley's
Government Contracts practice
Get in touch with Wiley's
Government Contracts attorneys
To stay informed on all of the announcements from the Trump Administration, please visit our dedicated resource center below.



