FAR 2.0: Ambition, Ambiguity, and the Need for Human-Centered Reform
The Federal Acquisition Regulation (FAR), long criticized for being slow and cumbersome, is undergoing what some call a long-overdue overhaul. In a bold stroke of deregulation, President Trump’s April 15, 2025, Executive Order titled “Restoring Common Sense to Federal Procurement” mandates agencies to remove what are deemed unnecessary barriers within the FAR. The policy objective is clear: increase flexibility, accelerate acquisition, and refocus on practical business judgment. But as Jennifer Ogren highlights in her May 22, 2025 article Bluster or brilliance: Browsing the FAR 2.0 rewrite, the real determinant of success may lie not in words struck from the FAR, but in the competency and courage of those enforcing it.
Dubbed the “Revolutionary FAR Overhaul” (RFO), the effort began with a public webpage and two class deviations from the General Services Administration aimed at FAR Part 1 and FAR Part 34. These early changes strike at the very core of how the federal acquisition system is explained and how major systems are procured. As Ogren notes, these are not casual footnotes—particularly Part 1, which commercial vendors often overlook but must now revisit to understand why federal buying has been so burdened by ritualistic delay. The RFO seeks to replace that tradition-bound structure with something that allows for agility, but it remains a living document—full of strikethroughs, drafts, and interagency discord.
For government contractors, the consequences are immediate and real. Ogren wisely advises contractors to reread every clause of their existing awards and watch for administrative modifications—some unilateral, others bilateral—particularly where reductions in compliance obligations are used to justify contractual consideration. She predicts subtle but important changes in compliance requirements, from equal opportunity evaluations to commercial item subcontract flowdowns. In short, for prime contractors and subcontractors alike, vigilance is now a contractual obligation.
But perhaps the article’s most important contribution is its candid warning: the FAR rewrite may fail without investment in the acquisition workforce. The policy instruments—DAWIA Modernization, Better Buying Power, Balanced Workforce Strategy—have yet to produce a consistently agile, empowered acquisition corps. Online training modules and superficial certifications don’t teach procurement officials to apply critical thinking, challenge requirements, or take calculated risks. Ogren calls for a more rigorous, Socratic approach to acquisition training that not only arms the workforce with tools but grants them the protection to make hard, honest decisions without fear of career damage.
Ultimately, the RFO might succeed in deleting redundant words and clauses, but will that change the culture? Unless we prioritize professional judgment, protect those who exercise it, and invest in teaching adaptive reasoning, the FAR may remain an exercise in checkboxes and bureaucracy. As Ogren concludes, true reform lives not in a redline version of the FAR but in the space between the keyboard and the chair—in the people who must live the reform, not just read about it.
Disclaimer: This blog post is a summary and analysis of a publicly available article and is not guaranteed to be accurate. It does not constitute legal advice. Always consult qualified counsel for official guidance.
