FAR

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Photo of Lorraine M. CamposPhoto of Peter J. EyrePhoto of Rebecca SpringerPhoto of Ellen Moran DwyerPhoto of Kris D. Meade

As discussed in our March 30, 2026, client alert, Déjà Vu: New Executive Order Outlines Restrictions on Contractor and Subcontractor DEI Activity, President Trump issued Executive Order 14398 (EO 14398), Addressing DEI Discrimination by Federal Contractors, on March 26, 2026. The EO declared DEI activities “unethical and often illegal,” required a new mandatory contract clause for federal contracts and subcontracts, and directed the Federal Acquisition Regulatory (FAR) Council to issue an implementing deviation. That deviation has now arrived. At the same time, a coalition of higher education and government contractor associations has filed suit seeking to block the underlying executive order.

Continue Reading FAR Council Issues Deviation Implementing EO 14398 With FAR 52.222-90 — DEI Restrictions on Federal Contractors
Photo of Adelicia R. CliffePhoto of Stephanie CrawfordPhoto of Alexandra Barbee-GarrettPhoto of Riley Delfeld

On February 17, 2026, the Federal Acquisition Regulatory Council (FAR Council) released a Proposed Rule (Proposed Rule) to implement Section 5949(a) of the James M. Inhofe National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2023 (Section 5949), following the FAR Council’s May 3, 2024 Advanced Notice of Proposed Rulemaking (ANPR).  Comments on the proposed rule are due by April 20, 2026.

Continue Reading Section 5949 Proposed Rule Puts the FAR Council’s Chips on the Table
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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…

Photo of Peter J. EyrePhoto of Laura J. Mitchell BakerPhoto of Rina GashawPhoto of Brittany Kouroupas

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
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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
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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…

Photo of Lorraine M. CamposPhoto of Laura J. Mitchell BakerPhoto of Rina GashawPhoto of Allison SkagerPhoto of Lillie Drenth

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
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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
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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
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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…