Rewriting the Federal Procurement System
Within two weeks of inauguration, the Trump Administration began issuing an abundance of Executive Orders (“EO”), memoranda, and related documents addressing how the U.S Government purchases goods and services from industry. The actions taken to date indicate that this Administration intends for federal agencies to promote maximum efficiency in procurement and eliminate regulatory barriers to business conducted with the federal government.
Further actions released by the White House are applying these policy goals towards a complete overhaul of the federal procurement system for civilian agencies and the armed services alike. There can be no doubt that the Federal Acquisition Regulation (“FAR”) we know today, including agency-specific supplements and rules, is changing. The Administration already has taken rapid action towards this objective, following the principle of “move fast and break things.” The interim period of upheaval will create varying degrees of uncertainty for government contractors, subcontractors, and grantees of all sizes and across all industries. Based on the actions taken to date, industry can expect a significant degree of uncertainty as guidance, proposed “deviations” from the Code of Federal Regulations, and possibly eventual formal rulemakings which may be released in a piecemeal fashion. Both industry contracting professionals and government contracts officers will need to adjust to the new norm and interpret the actions coming out of the White House, the FAR Council, and the Office of Federal Procurement Policy.
PLG has assembled this information to serve as a repository and summaries of government actions affecting Federal procurement.
Below and linked is a chronological listing of PLG’s alerts regarding relevant Executive Orders, memoranda, and proposed FAR “deviations.” PLG’s FAR Overhaul Action Team will continue to monitor what the Administration has dubbed, the “Revolutionary FAR Overhaul” or “RFO.”
Please check this page for regular updates or follow us on LinkedIn to receive the most up to date resources.
State of the FAR Pre-Overhaul
The FAR (excluding agency-specific rule supplements) is 2,034 pages when viewing the .pdf version effective as of January 17, 2025. When searching, the word “shall”" appears 2,480 times and the word “must” appears 842 times. "Require” or “required” appears 2,333 times. The intentional use of these mandatory words conveys that there are strict requirements and processes that must be followed each time the federal government wishes to acquire goods or services.
Inside the Overhaul
Key Updates and What to Watch
The actions of the administration demonstrate that is keen to overhaul and reduce the size of the FAR, granting contracting officials greater flexibility and requiring fewer strict mandates unless required by statute.
- Government contractors should be aware that the Overhaul is expected to change the FAR and federal procurement in the following ways:
- Government officials will be using agency level “Buying Guides,” in addition to the FAR rewrite, in the procurement process - meaning that various agencies may adopt different guides and selling various products and the solutions may require referencing different types of guides when understanding approach and policy taken to a particular solicitation.
- Procurement officials will apply deviation guidance and memos to be adopted by agencies in government procurement opportunities, even before the FAR is formally revised through the appropriate rulemaking processes – meaning that you may not see the actual FAR changes on Acquisition.gov until a later date and your proposal & contracting managers should be checking various GSA and specific agency websites routinely
- Strikeouts, line updates, and changes to the FAR are expected to be released on a rolling basis to the FAR, using a FAR part by part basis; such as these examples for FAR Part 1 and FAR Part 34- meaning you have the ability to see the likely changes that may be coming to an agency near you soon. **Note that these documents may not fully reflect that actual finalized language and may only identify high level changes**
- In May 2025, Acquisition.gov published the FAR Overhaul webpage that released the first two FAR Parts and Agency deviations and calling this the Revolutionary FAR Overhaul (RFO) initiative. The first RFO areas for review are FAR Part 1 (Federal Acquisition Regulation System) & FAR Part 34 (Major System Acquisition).
FAR Overhaul Chronology
Click here to view the PLG FAR Overhaul Chronology Update.
FAR Model Deviations
Click here for our full Deviation Resource & Tips Guide.
FAQs
Click here for our full list of FAQs.
We expect to continue seeing updates and changing guidance throughout the year.
This report and research was compiled by Michael Mendelson and Courtney Edmonds of PLG, along with assistance from Jennifer Ogren.
Jennifer Ogren is a consultant to PLG and specializes in information technology spaces and legal knowledge associated with federal contracting in her 20 years career at various defense, rocket and satellite companies. Jennifer has held various leadership roles in space focused corporate organizations, both in the commercial and international contracting spaces.
