FAR Overhaul UPDATE: A Look at Key Changes to Parts 11, 18, 39, and 43
In April 2025, President Trump signed Executive Order 14275, Restoring Common Sense to Federal Procurement, triggering the most sweeping rewrite of the Federal Acquisition Regulation (FAR) in over four decades. Now known as the Revolutionary FAR Overhaul (RFO), this initiative seeks to modernize the FAR by removing outdated provisions, simplifying regulatory language, and aligning acquisition procedures with the commercial marketplace. Over the past month, the General Services Administration (GSA) has issued a series of class deviations that illuminate how the new FAR is taking shape, beginning with Parts 11, 18, 39, and 43.
FAR Part 11: Describing Agency Needs
The revisions to FAR Part 11 reflect a shift toward commercial standards and competition-friendly practices. GSA has eliminated many prescriptive requirements, including those mandating brand name or equal descriptions, ecolabels, and numerous delivery-related clauses. In their place, the focus is now on encouraging market research and maximizing the use of commercial products and services. The requirement to follow standard delivery schedules has been relocated to the FAR Companion Guide, giving contracting officers more flexibility. Importantly, statutory requirements—like preferences for commercial items and liquidated damages clauses—remain intact.
FAR Part 18: Emergency Acquisitions
The overhaul of FAR Part 18 is equally significant. GSA has streamlined emergency procurement procedures and centralized emergency flexibilities at Acquisition.gov/emergencyprocurement. By doing so, the agency intends to keep FAR concise while still supporting acquisition agility during disasters, contingencies, and cyber or radiological events. Statutory authorities such as the Stafford Act and special emergency procurement thresholds have been preserved, as have waiver provisions related to U.S.-flag vessel requirements. However, references to non-regulatory guidance documents, like the National Response Framework, have been removed from the FAR text.
FAR Part 39: ICT Modernization
Among the most forward-looking reforms is the update to FAR Part 39, now retitled Acquisition of Information and Communication Technology. The revision reflects the growing prominence of cybersecurity, the Internet of Things, and artificial intelligence in federal procurements. The rule clarifies applicability to emerging technologies, reinforces the use of modular contracting, and upholds Section 508 accessibility standards. It also removes outdated references to OMB circulars and eliminates clause 52.239-1, which addressed privacy and security safeguards now covered elsewhere. These changes aim to speed up the procurement of secure, modern tech while reducing regulatory overlap.
FAR Part 43: Contract Modifications
FAR Part 43 (GSA) has been tightened to emphasize the essentials of contract modification practice, shedding roughly 300 words through plain language editing. Key statutory guardrails, such as the Anti-Deficiency Act and the Contract Disputes Act, are preserved. The guidance on definitizing change orders and documenting modifications remains in place but has been streamlined to reduce bureaucratic friction and better reflect real-world contracting workflows.
Across all four parts, the unifying theme is clarity, speed, and relevance. The Trump Administration’s RFO effort seeks to break with decades of FAR accretion by replacing complexity with core principles grounded in statutory authority and commercial sensibility. Contracting officers are being directed to realign internal templates, remove obsolete clauses, and rely more heavily on discretionary judgment within a simplified regulatory framework. These changes are already in effect for all GSA procurements and foreshadow broader reforms as the FAR Council continues its phased rollout of revised parts.
Whether these changes will deliver on their promise of restoring “common sense” to procurement remains to be seen. But one thing is clear: the FAR as we know it is undergoing a profound transformation.
Disclaimer: This blog post is for informational purposes only and is not guaranteed to be accurate or current. It does not constitute legal advice. Contractors should consult the official FAR text and agency guidance or seek professional counsel before taking action based on these summaries.