In what is sure to be an on-going series, we have the latest update regarding the FAR 2.0 rollout.

You can see my opening thoughts on the FAR 2.0 initiative and how it will affect federal contractors here.

Releasing the First Rollout

On May 2, 2025, the FAR Council released substantive rewrites of FAR Parts 1 (Federal Acquisition Regulations System), 34 (Major System Acquisition), and 52 (Solicitation Provisions and Contract Clauses).

The updates align with Executive Order 14275 Restoring Common Sense to Federal Procurement’s stated goals of streamlining federal procurement processes, reducing regulatory burdens, and aligning acquisition practices to more closely track with modern agency needs.

Responding to the Executive Order, the Office of Management and Budget (OMB) issued memorandum M-25-26 informing Agencies that they should issue their own class deviations modeling the FAR Council’s language within 30 days of the release of the rewrite.

Alongside the substantive rewrites, the FAR Council will also release buying guides to replace non-statutory regulations. The cumulative effort to rewrite the FAR and produce the buying guides is referred to as the Strategic Acquisition Guidance (SAG).

Before diving into the specifics of the FAR 2.0 rollout to date, let’s address the opportunities and challenges for federal contractors:

  • Simplified Compliance: The push toward increasingly streamlined regulations can reduce the complexity of compliance, making it easier for contractors to understand and meet contractual expectations.
  • Increased Competition: Lower compliance thresholds may lead to increased competition in federal contracting opportunities.
  • Touchpoints Required: Contractors must stay informed about regulatory changes and double down on staying connected with agency touchpoints. Contractors can track Agency deviations as they are published on acquisition.gov.

FAR Part 1: Federal Acquisition Regulations System

FAR Part 1, as revised, emphasizes guiding principles that prioritize efficiency, innovation, and mission effectiveness. Key changes include:

  • Delegated Decision-Making (1.102(a)(7)): Encouraging decision-making at the lowest appropriate level to enhance responsiveness.
  • Commercial Solutions Preference (1.102(a)(3)): Promoting the use of readily available commercial products and services over more government-unique solutions.
  • Innovation and Risk Management (1.102(c)): Shifting focus from perceived prior attempts to “eliminate all risk” in favor of “risk management” to foster innovation.

The revision also includes the anticipated “Regulatory Sunset” provision (1.109) aimed at eliminating all non-statutory provisions after four years, unless renewed by the Council.

FAR Part 34: Major System Acquisition

Updates to FAR Part 34 focus on simplifying the government process for acquiring major systems.

The revisions aim to reduce administrative burdens and encourage commercial solutions. The expectation is that – by streamlining requirements – agencies can more effectively procure complex systems that meet operational needs.

FAR Part 52: Solicitation Provisions and Contract Clauses

For now, the revisions to Part 52 only track corresponding changes in other sections.

Moving forward, contractors should expect more changes aimed at eliminating non-statutory provisions and increasing procurement efficiency.

What Happens Next?

The FAR Council is seeking informal input on the revised parts through September 30, 2025.

Stay tuned here for more updates as the FAR 2.0 rollout continues.

Nick Solosky is a Partner in Fox Rothschild’s Government Contracts Practice Group.  You can reach Nick directly at NSolosky@FoxRothschild.com or 202-696-1460.