Over one year ago, on May 2, 2025, the FAR Council took the first concrete step in the administration’s “Revolutionary FAR Overhaul” (“RFO”) initiative by issuing the initial round of rolling model deviation guidance—a deliberate move to translate reform of the Federal Acquisition Regulation (“FAR”) from an abstract policy goal into acquisition text. That moment marked the beginning of a new implementation reality: rather than waiting for a single, comprehensive rulemaking, the government began operationalizing the overhaul in increments, part by part, through deviations. Now, a year later, the question for contractors is no longer whether the overhaul is “coming,” but how it is being implemented across agencies and systems. This is therefore a good time to take stock of where implementation stands, where friction is emerging, and what sophisticated contractors can do to stay ahead of the curve. For additional information, our prior coverage of the RFO roll-out can be found here and here.
The RFO’s “Phase 1” Is Not Theoretical—It’s the New Operating System
The RFO was launched under Executive Order 14275, Restoring Common Sense to Federal Procurement (Apr. 15. 2025) and implemented through OMB Memorandum M-25-26, Overhauling the Federal Acquisition Regulation (May 2, 2025), which together direct a streamlined FAR anchored in statutory requirements. As part of the RFO, many non‑statutory provisions were shifted out of the FAR into non-regulatory resources, including the FAR Companion Guide and Practitioner Album. The mechanism for making the RFO real—before formal rulemaking—was explicit: as explained in a FAR Council memorandum, the Council would publish model deviation text by FAR part; agencies were expected to implement the new text within 30 days via class or individual deviations.
For contractors, this means “the FAR” is now increasingly contract‑ and agency‑specific. Whether your contract is governed by the codified FAR or a deviated RFO version is no longer a given—it is an issue to be verified.
The Patchwork Is Measurable—and Growing
Acquisition.gov now maintains a centralized FAR Parts and Agency Deviations hub, accessible from a dedicated RFO site, listing overhauled parts, updates, and the number of agency deviations associated with each part. Over the last year, the FAR Council issued model text for all FAR parts in stages. Even now that the full set has been released, updated iterations may continue to appear on an “as needed” basis in response to executive orders or other regulatory developments—for example, revisions to implement the March 2026 DEI executive order or to reflect updated value thresholds for trade agreements clauses.[1] Agencies are implementing the model text and subsequent revisions at different speeds, producing a landscape where the “applicable FAR” can differ by agency, bureau, and—in some cases—buying activity.
The bottom line is that RFO implementation is no longer mere background context—it now has concrete implications for which clauses appear in contracts and how clause prescriptions operate.
A Preview of the Practical Friction: “Systems Lag Policy”
One of the most telling implementation notes appears repeatedly across agency deviations: contract writing and registration systems may still prompt for legacy representations and provisions that have been removed or relocated under RFO deviations. For example, GSA’s August 2025 RFO deviation for FAR Part 4 instructs the workforce to follow RFO text “instead of FAR part 4 and 52 as codified,” and flags that “system updates may lag policy updates,” advising contracting officers to rely on the solicitation’s deviated provisions even if the System for Award Management (“SAM.gov”) prompts for legacy reps. Similar language is included in the Department of Commerce’s April 2026 deviation, indicating that legacy systems lag is an ongoing issue.
This matters because contractors that rely on “what the system asked for” (SAM.gov, templates, auto‑generated clause lists) risk being disconnected from the agency’s actual expectation.
Defense Is Not Standing Still—DFARS/PGI Alignment Adds Another Layer
The Department of War’s (“DoW”) RFO implementation is not limited to FAR text by design—DoW is subject to its own executive order governing the review and revision of its acquisition regulations and guidance.[2] DoW has published extensive Defense Federal Acquisition Regulation Supplement (“DFARS”) RFO Class Deviations, often accompanied by revised Procedures, Guidance, and Information (“PGI”) and “line‑out” documents showing what is being removed or retained. The DFARS RFO deviations also instruct users to apply RFO definitions in lieu of FAR 2.101 definitions in many contexts—another subtle but consequential shift for compliance and disputes over interpretation. For contractors operating in defense procurements, the landscape may include deviated FAR parts, deviated DFARS parts, and revised PGI guidance, with the controlling text depending on the specifics of the contract.
What Contractors Should Do Now: A Practical “RFO Readiness” Playbook
Below are concrete steps contractors can take immediately to reduce risk during the RFO transition.
- Build a deviation “truth table” for each target agency (and refresh it frequently). Create a simple internal register that records FAR part deviations for each target agency, including whether the deviation adopts model text verbatim or adds agency‑unique statutory language.
- Treat clause review as a two‑step: (1) “what’s included” and (2) “what version?” To understand compliance requirements and minimize compliance gaps, it is important to consider not only whether certain clauses are present, but also which version, and whether they were relocated, consolidated, or replaced. For a given contract, build an internal checklist that compares the document’s incorporated clauses and (i) the codified FAR, and (ii) the agency’s RFO deviation text for that FAR part.
- Ask for the agency’s “authoritative clause set” early and in writing. Because agencies acknowledge that templates and systems can lag, contractors should not be shy about asking: “Please confirm the authoritative set of provisions/clauses for this contract, including any RFO deviations incorporated.”
- Update your operational documents. RFO changes reach operational documents, including representations, compliance crosswalks, and subcontract flowdowns. Regularly updating checklists and templates will ensure better alignment with the new regulatory structure and the agency’s expectations.
- Monitor the Federal Register. The RFO will be formally codified through notice-and-comment rulemaking, which could introduce changes to the RFO in its current form. Contractors would be advised to closely monitor updates on the rulemaking as they develop.
Bottom Line
The RFO is not a distant reform project—it is already changing what clauses mean and what “compliance” looks like in practice. Contractors that treat RFO implementation status as a living input—rather than a footnote—will be better positioned to avoid preventable missteps during a period of rapid procurement change.
[1] Although the express intent of the RFO is to streamline and remove non-statutory requirements from the FAR, there are instances in which the RFO has been used as a vehicle to implement new requirements stemming from recent executive action, such as RFO 52.222-90, Addressing DEI Discrimination by Federal Contractors.
[2] Executive Order 14265, Modernizing Defense Acquisitions and Spurring Innovation in the Defense Industrial Base (Apr. 9, 2025).