Faster, Smarter Buying: New FAR “Companion”

The Federal Acquisition Regulatory Council’s new FAR Companion (Version 1.0, Sept. 9, 2025) is a management document designed to sit alongside a leaner FAR and restore greater reliance on contracting-officer judgment. Issued under Executive Order 14275 and OMB Memorandum M-25-26, it signals the removal of non-statutory mandates and provides practical guidance that agencies can use without creating new protest exposure. For federal contractors, the implications are immediate: more commercial buying, more RFQs, and faster award timelines that reward clear operational discriminators over lengthy narrative submissions.

The centerpiece change for industry is an explicit directive to use FAR part 12 simplified procedures for commercial acquisitions up to $7.5 million—via RFQ followed by a purchase order—and, importantly, a prohibition on using part 15 procedures for commercial buys at or below that threshold. For cyber/CBRN emergency contexts, the ceiling rises to $15 million. This formalizes a shift many teams have sought for years: shorter solicitations, comparative evaluations, and accelerated award cycles.

The Companion also operationalizes comparative evaluation approaches—drawing on the Periodic Table of Acquisition Innovations—so evaluators focus on discriminators and best-value outcomes rather than re-creating part 15-style scorebooks. The guidance explicitly encourages agencies to adopt these methodologies to reduce time, complexity, and cost while safeguarding integrity and mission outcomes.

For ordering off existing vehicles (FSS, GWACs), the Companion emphasizes that price reasonableness is already established at the vehicle level, so ordering officials should concentrate on comparative analysis among quoters’ solutions and document a concise best-value rationale.

Timing around debriefings and protests is another noteworthy, practice-level change. The Companion advises agencies to prepare rapid debriefings and, where only a “brief explanation” is required (e.g., many part 12 RFQs or FSS orders), to include that explanation directly in the award notice—an approach that can start the GAO’s 10-day protest clock immediately. For contractors, that means award notices may now carry more actionable information, and internal go/no-go protest decisions need to be triggered the same day those notices arrive.

Emergency acquisition flexibilities—usable even without a formal emergency declaration—explicitly tie back to part 12’s commercial framework and the $15 million ceiling in cyber/CBRN contexts. Teams supporting disaster feeding or contingency operations should pre-position commercial RFQ packages with rapid ordering pathways, clearly defined assumptions, and scalable labor and logistics plans.

Finally, the Companion addresses supplier license agreements, urging use of pre-negotiated baselines on Schedules and GWACs and coordinated legal/IT reviews when agency needs diverge.

Disclaimer: This post summarizes a government document for general informational purposes only and does not constitute legal advice. Readers should consult the underlying FAR Companion and applicable regulations or engage qualified counsel before relying on this summary.