The Federal Acquisition Regulation (FAR) is the backbone of federal contracting. It governs how agencies purchase goods and services, sets the ground rules for competition, and establishes the compliance framework every contractor must follow. Since it was first issued in 1984, the FAR has been revised countless times, but most changes were incremental — updates layered on top of an already complex system.

Over time, this patchwork created a rulebook that was difficult to navigate, slow to adapt, and inconsistent across agencies. Contractors often faced unnecessary compliance hurdles, while agencies struggled to buy efficiently. The result was a system that met statutory requirements but lagged behind the realities of modern procurement.

The government’s decision to launch the FAR Overhaul 2025 is the most significant acquisition reform in decades. The effort stems from Executive Order 14275, “Restoring Common Sense to Federal Procurement”, which directs that the FAR should contain only statutory and essential requirements. The new framework has already been finalized, and contractors are now in the waiting period before it officially takes effect. Understanding what has changed — and how those changes will impact contract management and compliance — is critical for staying competitive and compliant in the federal market.

Over the years, the FAR turned into a dense rulebook, where every new statute, executive order, and policy was added on top of the existing text, but outdated rules were rarely removed. The FAR has been rewritten in plain English so contractors and contracting officers can more easily understand what’s required. To keep the regulation from getting bogged down again, non-statutory rules now come with an expiration date, forcing regular updates. For contractors, that means the transition is already underway, even before the phased rulemaking begins. You can follow these changes directly on the FAR Overhaul Hub.

FAR Overhaul 2025 Timeline: Phased Rollout and Key Milestones

The overhaul is complete, but implementation will be phased. Agencies are already applying class deviations to preview the new FAR in practice, which contractors can track through the FAR Class Deviation page. These deviations are essentially “early use” versions of the new rules, and contractors who pay attention to them now will be better prepared once the overhaul is fully codified.

• Early–Summer 2025: First revised parts began rolling out.
• Late Summer 2025: Major updates, including FAR Part 12 on commercial acquisitions and new cybersecurity rules.
• Fall 2025: Specialized areas such as ethics, socioeconomic programs, and the launch of the FAR Companion v1.0.
• 2026–2027: Phase II rulemaking codifies changes and refines language through public comment.
• By 2029: Any non-statutory text not reaffirmed will expire.

Coley GCS can help contractors stay ahead of these phased changes by monitoring deviations, interpreting updates, and preparing compliance programs during the rollout period.

FAR Overhaul 2025 Updates: Contractor Guide to Each FAR Part

The FAR overhaul is rolling out part by part, with some areas already updated, others still pending, and a few in progress. Contractors can review the official part-by-part breakdown on the FAR Overhaul Hub. Each part includes redlined comparison documents showing exactly what was removed, simplified, or rewritten, available on Acquisition.gov. These resources make it easier for contractors to understand the scope of changes and identify compliance risks. By tracking updates closely, contractors can anticipate adjustments before they become mandatory. Staying proactive also helps align training, proposal language, and internal controls with the evolving framework, reducing the risk of last-minute surprises.

Coley GCS works with contractors to align their GSA Schedule contracts with these FAR updates, helping ensure compliance during the transition.

Updated

• FAR Part 1 – The Foundation
  The FAR now opens with guiding principles written in plain language. Instead of dense legal jargon, it emphasizes empowerment, discretion, and accountability. It also introduces the new “sunset rule,” ensuring that unnecessary material doesn’t stick around forever.
• FAR Parts 3 & 17 – Ethics and Special Contracting Methods
  Ethics and conflicts of interest are emphasized as non-negotiable. The section on improper business practices has been rewritten in plainer language so it’s easier to apply consistently across agencies. Part 17, covering special contracting methods, explains tools like options and multi-year contracting in a clearer way.
• FAR Parts 4 & 27 – Administrative and Intellectual Property
  Part 4 (Administrative and Information Matters) has been streamlined, especially in areas such as reporting and contractor registration. Part 27 (Patents, Data, and Copyrights) has been rewritten for clarity and to reflect modern intellectual property practices.
• FAR Parts 5 & 6 – Publicizing and Competition
  Simplified rules clarify when notices are required and what counts as sufficient competition. The updates reduce paperwork while protecting fair and open competition.
• FAR Part 7 – Acquisition Planning
  Encourages mission-first thinking and smarter acquisition strategies rather than rigid compliance.
• FAR Part 8 – Required Sources of Supplies and Services
  A new tiered sourcing system provides a clear order for contracting officers:
  • Tier 1 – Mandatory Government Sources such as AbilityOne and Federal Prison Industries (UNICOR).
  • Tier 2 – Agency inventories and excess supplies.
  • Tier 3 – Federal Supply Schedules (FSS) with streamlined ordering procedures.
  • Tier 4 – Open Market Sources if mission needs can’t be met otherwise.
• FAR Part 9 – Contractor Qualifications
  Updates clarify how agencies assess responsibility and due diligence, making qualification reviews more straightforward and risk-focused.
• FAR Part 10 – Market Research
  Rules emphasize meaningful analysis over paperwork, making it easier to connect research to acquisition decisions.
• FAR Part 11 – Describing Agency Needs
  Streamlined guidance written in plain language makes it easier for contracting teams to describe requirements without chasing endless cross-references.
• FAR Part 12 – Buying Commercial Products and Services
  This centerpiece update reinforces a “commercial first” mindset, rules out cost-reimbursement contracts for commercial items, and expands simplified acquisition procedures. It also stresses using commercial warranties, industry quality systems, and accepting software licenses “as sold.” Contractors can read the full regulation in FAR Part 12.
• FAR Parts 13–16
  Simplified acquisition procedures (13), sealed bidding (14), contracting by negotiation (15), and contract types (16) remain in their legacy form until new guidance is issued.
• FAR Parts 19–23
  Small business programs (Part 19), labor rules (Parts 22–23), and foreign acquisitions (Part 25) are still pending. Contractors interested in federal small business contracting can also explore gov.
• FAR Parts 18, 24 & 26 – Special Situations and Socioeconomics
  Emergency acquisition flexibilities have been refreshed. Privacy and FOIA rules now reflect modern practices, while socioeconomic program guidance is written more clearly without changing statutory requirements. Contractors interested in federal small business contracting can also explore the SBA Federal Contracting page.
• FAR Parts 28–31 – Bonds, Insurance, and Cost Rules
  These retain their statutory backbone but have been slimmed down for clarity, making rules easier to apply.
• FAR Parts 33–36 – Disputes, Major Systems, and Construction
  Disputes and protests are reorganized for faster access. Major system acquisition, R&D, and construction contracting rules are modernized but remain tied to statutory requirements.
• FAR Parts 37–38
  Service contracting (37) and reserved Part 38 are not yet updated.
• FAR Parts 39 & 40 – Technology, Cybersecurity, and Supply Chain
  Technology and cybersecurity finally have a clear home. Part 39 covers IT, while the new Part 40 consolidates information security and supply chain risk management requirements. Contractors should also review CISA’s supply chain security guidance.
• FAR Parts 41–42
  Utility services (41) and contract administration/reporting (42) remain in pre-overhaul format.
• FAR Parts 43–46 – Modifications, Subcontracting, and Quality Assurance
  These sections are simpler and allow more risk-based judgment rather than rigid checklists.
• FAR Part 47
  Transportation contracting rules remain pending.
• FAR Parts 48–50 – Value Engineering, Terminations, and Extraordinary Actions
  These areas have been reduced to their statutory and practical cores, making them shorter and clearer.
• FAR Part 51
  Part 51 remains reserved in the updated FAR framework. This means there are currently no active rules or guidance under this rule, though it is being held for potential future use.

Partially Updated

• FAR Part 52 – Provisions and Clauses
  This remains a work in progress. Clauses are being renumbered, simplified, or reserved, with agencies issuing deviations to put cleaned-up versions into play. Many of the clauses in FAR 52 were redundant/referencing existing clauses and will be removed.

FAR Overhaul 2025 Impact: Compliance, Contractors, and Preparation

The FAR overhaul reshapes how agencies and contractors interact, and the impact looks different depending on the size of the business.

For small businesses, the new rules mean lower compliance burdens and fewer unnecessary hurdles. Requirements are written in plain language, making it easier to approach federal opportunities through SAM.gov with confidence.

Mid-sized and large businesses face a different challenge. With sharper compliance expectations and closer enforcement, internal systems and processes may need updating. Proposal templates, checklists, and training programs will all need to be refreshed so teams understand the new structure. Established contractors must ensure that every part of their compliance programs align precisely with the updated rules, leaving less room for interpretation or flexibility.

For all contractors, the message is the same: compliance now means paying attention to both the FAR and the new resource, FAR Companion. While the FAR holds enforceable rules, the Companion provides the practical guidance that agencies will expect contractors to follow. For contractors, the FAR Companion is just as important as the FAR itself. It explains how the streamlined rules are meant to work in practice and helps ensure consistent application across agencies.

During this transition period, the best preparation steps are clear—review current class deviations, train staff across teams, and update compliance policies and systems to match the leaner framework. Agencies are already signaling these expectations, and contractors who act now will be better positioned once the phased rulemaking begins.

Coley provides consulting and training for both small and large contractors, making it easier to adapt to the sharper compliance requirements introduced in the overhaul.

Compliance Support with Coley GCS for Federal Contract Success

The FAR overhaul and phased implementation are already underway. Whether you manage a GSA Schedule or other federal contracts, being prepared for these changes is critical. Contractors can expect to update policies, train teams, and should continue to closely monitor FAR updates to remain compliant.

Coley GCS offers hands-on support that helps GSA Schedule contractors update and manage their GSA contracts in line with the new FAR requirements. With over 24 years of experience, Coley GCS has helped thousands of companies successfully obtain and manage their GSA Schedule contracts. Our dedicated team of experts provides ongoing support to ensure your Schedule stays compliant, competitive, and positioned for long-term success in the federal marketplace. From initial acquisition to modifications and annual maintenance, we make the process easy and efficient—so you can focus on growing your government business.

Ready to get started or need help managing your existing Schedule? Contact us at hello@coleygsa.com, call 210-402-6766, or book time with our team to talk with a GSA expert.

If you’re a government contractor looking for business development resources, and exploring ways to grow in the federal market, check out FedMap.us, the #1 growth-focused online community for government contractors.

Note: The content of this article was created with AI assistance. Coley GCS advisors have edited, fact-checked, and taken full responsibility for its publication.