FAR Overhaul 2025: What Contractors Need to Know About the New Federal Acquisition Landscape
The Federal Acquisition Regulation (FAR) — the rulebook that governs nearly every federal contract — is undergoing its biggest rewrite in decades. Over the past few months, the FAR Council has rolled out a sweeping series of updates touching nearly every corner of federal procurement — from socioeconomic programs and contract disputes to organizational conflicts of interest (OCI) and Controlled Unclassified Information (CUI) requirements.
For federal contractors, these changes aren’t just administrative. They reshape compliance obligations, eligibility rules, and even how contractors compete. If you want to stay ahead of your competitors, now is the time to get familiar with the “new” FAR.
1. The Big Picture: The FAR Council’s Modernization Push
The FAR Overhaul initiative is part of a multi-year effort to simplify, streamline, and modernize acquisition rules for a faster, more transparent government buying process. The Council’s recent publications on Acquisition.gov reveal model deviation texts and finalized revisions for multiple parts — including Parts 3, 15, 16, 19, 22, 23, 25, 27, 32, 42, 45, and 53.
The intent is clear:
While these are regulatory refinements on paper, their downstream impact on small businesses, primes, and subcontractors is significant — especially where eligibility and compliance certifications come into play.
2. FAR Part 19: The “Rule of Two” Survives — But with a Twist
One of the most closely watched updates is the revised FAR Part 19, which governs small business programs. The Council reaffirmed that the “Rule of Two” — the requirement that contracting officers set aside acquisitions for small businesses when at least two capable firms exist — remains intact.
However, the overhaul also reflects a philosophical shift. As reported by Washington Technology, socioeconomic programs now take a “back seat” to the goal of simplifying acquisition. The FAR now leans toward a market-based approach — emphasizing data-driven decisions rather than mandatory set-asides in every scenario.
What this means for contractors: Small businesses must be proactive in marketing their capabilities and ensuring visibility through SAM.gov, FPDS data, and agency vendor portals. The days of relying solely on set-asides for access are over — competitive readiness is the new compliance.
3. FAR Parts 3, 27, and 45: Ethics, IP, and Property Rules Refined
According to a JD Supra analysis, the Council has finalized long-awaited revisions to Parts 3 (Improper Business Practices), 27 (Patents, Data, and Copyrights), and 45 (Government Property).
These changes emphasize:
For contractors, this means revisiting your internal compliance programs. Expect more scrutiny on ethics disclosures, subcontractor certifications, and how you handle data generated under contract.
4. CUI and OCI Rulemakings Narrow the Agenda
In a separate but related move, the FAR Council is advancing focused on rulemakings on Controlled Unclassified Information (CUI) and Organizational Conflicts of Interest (OCI). (Source: JD Supra – FAR Agenda Narrows with CUI and OCI Updates)
Both issues have become top-of-mind as agencies ramp up cybersecurity and integrity requirements across the federal supply chain.
For small and mid-tier firms, this is both a risk and an opportunity. If you can demonstrate clean compliance and transparent governance, you’ll gain credibility with contracting officers who are increasingly cautious about conflict risk.
5. Protests, Disputes & Appeals: FAR Part 33 Gets a Refresh
As outlined by Holland & Knight, the FAR Council’s proposed revisions to Part 33 to modernize how contractors can file and manage bid protests and contract disputes.
Key highlights include:
For contractors, this update is a double-edged sword. While it promises faster resolution, it also demands sharper documentation and communication at every stage of the contracting process.
6. What’s Next: Continuous Releases via Acquisition.gov
The FAR Council isn’t slowing down. New “Model Deviation Texts” for additional parts — including 15 (Contracting by Negotiation), 16 (Contract Types), and 32 (Financing) — are being published in waves on Acquisition.gov.
Each deviation will serve as a live preview of how future FAR versions will look — giving industry early visibility into compliance changes before they become final.
You can monitor updates directly on: Acquisition.gov FAR Overhaul Resources
7. The Contractor’s Checklist: Stay Ready, Stay Competitive
Here’s how your business can stay ahead in the new FAR era:
8. Final Thoughts from Contragenix
At Contragenix, we track these developments closely because they directly affect how our clients compete, comply, and win in the federal space.
The FAR overhaul isn’t just about cleaner language — it’s about redefining the rules of engagement between agencies and industry. Contractors who adapt early will gain an edge not only in compliance, but in credibility and readiness.