The Federal Acquisition Regulation (FAR) is getting a plain-language rewrite under Executive Order 14275, removing most non-statutory rules and introducing practical buying guides. These updates will have far-reaching impacts across all federal contracting activities.
Our new website, FAR In Focus, is here to help you navigate this transformation while staying informed and prepared. Our
On September 9, 2025, GSA released version 1 of the FAR Companion, a living resource guide aimed primarily at assisting federal acquisition professionals. The FAR Companion is designed to provide guidance and recommendations to acquisition professionals to better understand the FAR and related procurement principles for planning, awarding, managing, and closing out contracts. It consolidates practitioner insights, innovation and vendor engagement strategies, handbooks, training materials, and problem-solving ideas into one source.Continue Reading FAR from Alone: GSA Releases New FAR Companion Guide
The System for Award Management (SAM, available at sam.gov) is set to incorporate Revolutionary FAR Overhaul (RFO) changes as early as the first quarter of 2026. The RFO process, which began earlier this year, will trigger matching changes to representations and certifications in SAM.gov.Continue Reading Not Just the FAR, SAM.gov Gets Overhauled Too
This week’s episode covers a DOD final rule most relevant to companies providing consulting services to DOD and the FAR Council’s revisions to FAR Part 8 (Required Sources of Supplies and Services) and FAR Part 12 (Acquisition of Commercial Products and Commercial Services), and is hosted by Peter Eyre, Laura Baker, and Rina Gashaw. Crowell
On August 14, 2025, the Office of Federal Procurement Policy (OFPP) and the Federal Acquisition Regulatory Council (FAR Council) issued draft revisions to FAR Part 8 and FAR Part 12 (as well as to FAR Parts 4 and 40). These are the latest rewrites under the Revolutionary FAR Overhaul (RFO) initiative pursuant to Executive Order 14275, “Restoring Common Sense to Federal Procurement,” which we previously reported on here.Continue Reading FAR Council Issues Rewrites to FAR Parts 8 and 12
On August 7, 2025, the FAR Council issued a final rule amending FAR 52.204-7 to clarify that, effective immediately, an offeror’s failure to maintain continuous System for Award Management (SAM) registration between proposal submission and contract award does not render the offeror ineligible for award, so long as the offeror was registered in SAM at the time of proposal submission and is registered at the time of contract award. The final rule should address situations like TLS Joint Venture, LLC, B-422275, Apr. 1, 2024, 2024 CPD ¶ 74, where an offeror’s SAM registration lapsed for a single day between the proposal submission and award dates, and GAO found the offeror ineligible for award.Continue Reading The End of the Continuous SAM Registration Requirement …. Almost
On May 2, 2025, the Office of Federal Procurement Policy (“OFPP”) and the Federal Acquisition Regulatory Council (“FAR Council”) issued the first round of promised FAR rewrites—to Parts 1, 34, and 52—alongside a guidance memorandum for agencies subject to the FAR, Deviation Guidance to Support the Overhaul of the Federal Acquisition Regulation (“FAR Council Deviation Guidance”). The Office of Management and Budget also released a guidance memo, Overhauling the Federal Acquisition Regulation (“OMB Guidance”), that addresses the proposed implementation roadmap for the FAR overhaul. These initial FAR revisions follow the April 15, 2025 Executive Order (“EO”), Restoring Common Sense to Federal Procurement, which we previously reported on here.Continue Reading First Round of FAR Rewrites Released
This week’s episode covers a proposed rule to implement the 2022 Preventing OCIs in Federal Acquisition Act, a proposed rule amending the FAR to implement federal government-wide Controlled Unclassified Information cybersecurity, training, and incident reporting requirements, and a final rule amending multiple aspects of the SBA’s small business size and status programs, and is hosted by
Last month marked the 16-year anniversary of the FAR Mandatory Disclosure Rule (MDR) going into effect, which created requirements for federal contractors to disclose violations of specific categories of federal criminal law and violations of the civil False Claims Act (FCA). But the passage of time has not simplified the analysis that government contractors must undertake when they learn of allegations about conduct that could be disclosable to the government. Rather, legal developments and new Department of Justice (DOJ) policies have created additional considerations for federal contractors as they navigate a complex disclosure landscape.Continue Reading The Evolving Landscape of Disclosure Considerations for Government Contractors
As previewed in President Biden’s State of the Union Address, the Office of Management and Budget (OMB) issued a proposed rule and notification of proposed guidance on February 9, 2023 to improve uniformity and consistency in the implementation of Build America, Buy America (BABA) requirements applicable to federally funded infrastructure projects pursuant to the Infrastructure Investment and Jobs Act (IIJA).
This proposed rulemaking builds on preliminary guidance OMB issued on April 18, 2022, shortly before the BABA requirements became effective in May 2022. While the preliminary guidance focused heavily on agency waivers (both in terms of process and criteria), the proposed rule describes how the requirements related to manufactured products, iron and steel, and construction material will be interpreted. Continue Reading Buy America, by Americans—Office of Management and Budget Solicits Industry Input on Harmonizing Domestic Preference Regimes