Key takeaways
- On August 15, 2025, the Office of Federal Procurement Policy (OFPP) announced major updates to the Federal Acquisition Regulation (FAR), known as the “Revolutionary FAR Overhaul” (RFO), designed to streamline procurement processes and promote efficiency within federal agencies.
- The RFO now allows agencies to remove non-statutory or non-executive order requirements from future contracts, which may reduce administrative burdens and inefficiencies in the long term.
- New and seasoned federal contractors should become familiar with the revised FAR structure and prepare for streamlined procurements and increasing competition in the federal marketplace.
Executive Order 14275
On April 15, 2025, President Donald Trump issued Executive Order 14275, “Restoring Common Sense to Federal Procurement” (EO 14275), initiating the most comprehensive overhaul of the FAR since its inception over 40 years ago. EO 14275’s stated policy objective was to “create the most agile, effective, and efficient procurement system possible” by revising the FAR to contain “only provisions required by statute or essential to sound procurement.” EO 14275 required each federal agency to designate a senior procurement official to work with the OFPP and imposed an aggressive timeline for completing the FAR overhaul. Specifically, within 180 days of EO 14275 (October 12, 2025), OFPP and the FAR Council must “take appropriate actions to amend the FAR to ensure that it contains only provisions that are required by statute” and identify all provisions not required by statute that will remain in the FAR.
The FAR overhaul
Following EO 14275, the OFPP and the FAR Council, together with the General Services Administration, established the Revolutionary FAR Overhaul webpage on Acquisition.gov. EO 14275 provided for a two-phase implementation of the FAR overhaul. First, the FAR Council is issuing model FAR deviation text by FAR Part on a rolling basis. Agencies are generally directed to issue agency-specific class deviations within 30 days of model text publication. Second, the FAR Council will undertake formal notice-and-comment rulemaking. The RFO site contains a central repository of revised FAR Parts and includes an OMB mailbox intended for feedback from stakeholders that will likely be used in developing proposed and final FAR rules.
In addition to FAR revisions, the FAR overhaul is moving non-statutory buying strategies out of the FAR and into OFPP-endorsed “buying guides.” The revised FAR and buying guides will be known as the Strategic Acquisition Guidance. The first buying guide will focus on software-as-a-service acquisitions, signaling the Trump administration’s emphasis on modernizing technology procurement.
Conclusion
The FAR overhaul allows agencies to immediately remove non-critical requirements – those not grounded in statute or executive order and deemed to have minimal impact on contract performance. This overhaul reflects a decisive shift toward a more agile, commercial-friendly federal acquisition system. The RFO initiative significantly reduces regulatory complexity and opens federal contracting to innovative small businesses and new entrants. New and seasoned federal contractors should become familiar with the revised FAR structure and prepare for ongoing changes. These reforms are positioned to yield streamlined acquisitions and expand competition for contractors in the federal procurement process.
Our Government Contracts and National Security attorneys continue to monitor these developments and are prepared to advise contractors on the implications of the FAR overhaul.
Client Alert 2025-222