Part 52, Recast: Why the FAR Overhaul’s Clause Architecture Matters for Contractors

The Revolutionary FAR Overhaul (RFO) reshapes Part 52—Solicitation Provisions and Contract Clauses—so thoroughly that contractors should treat it as a new landscape, not a touch-up. On the Acquisition.gov deviation page for Part 52, readers will immediately notice two sweeping signals: first, a large number of legacy entries are now marked “[Reserved],” and second, key clauses have been rewritten, renumbered, or relocated to align with the overhaul’s plain-language, risk-based structure. The index itself reflects these shifts, from the front-matter on using and incorporating clauses (Subpart 52.1) to the reorganized clause catalog in Subpart 52.2. (Acquisition.gov)

The most consequential re-plumbing is the migration of information-security content out of the familiar Part 4 ecosystem and into the new Part 40 framework, with corresponding clauses now housed in the 52.240 series. On the Part 52 deviation page, you will see 52.240-91 Security Prohibitions and Exclusions, 52.240-92 Security Requirements, and 52.240-93 Basic Safeguarding of Covered Contractor Information Systems—the new anchors that displace and consolidate prior security clauses in the 52.204 family, many of which now read “[Reserved].” In practical terms, this means contractors must update clause matrices, templates, and compliance checklists to reference 52.240-9x where they historically pointed to 52.204-2 or 52.204-21. (Acquisition.gov)

Part 40 itself explains the policy logic: it centralizes broad information- and supply-chain-security requirements that had been scattered across multiple FAR parts, and it is being implemented via model deviation text the workforce is directed to follow. Issued on August 14, 2025, the deviation package and agency class deviations (e.g., GSA and VA) instruct acquisition personnel to use the RFO Part 40 and the corresponding Part 52 model text in lieu of the codified provisions during the transition. This not only consolidates obligations for prime and subcontractors; it also clarifies the prescriptive basis for when and how these security clauses apply. (Acquisition.gov)

The overhaul’s signature technique—marking many legacy clauses as “[Reserved]” while introducing deviation-numbered replacements—also appears beyond security. Commercial-item language is standardized around “Commercial Products and Commercial Services,” with 52.212-1, -2, and -4 retained under updated titles and 52.212-5 now reserved, signaling a different approach to statutory implementations that historically lived in a single omnibus clause. Elsewhere, the page adds new identification provisions—52.204-90 Offeror Identification and 52.204-91 Contractor Identification—and a new small-business teaming clause for multiple-award contracts, 52.207-6, reflecting policy priorities around vendor transparency and MAC competition. For contractors, these are not cosmetic changes: they alter proposal representations, teaming strategies, and the orchestration of subcontract flows. (Acquisition.gov)

Why this matters now is twofold. First, compliance and performance risk move with the numbering. If your clause libraries, boilerplates, or automated compliance trackers still pull in 52.204-2 and 52.204-21 by default, you risk omissions or conflicts once solicitations invoke 52.240-92 or 52.240-93. Multiple agencies have already memorialized this shift via class deviations, making it operational reality even before codified text fully catches up. Second, the consolidation in Part 40 and the 52.240 suite streamlines what used to be a patchwork: requirements for safeguarding systems, supply-chain exclusions, and related representations are now centralized, easier to read, and more consistently applied across procurements. That coherence is an advantage—but only for contractors who adapt their internal controls, proposal content, and subcontract terms to the new structure. (Veterans Affairs)

The practical next steps are straightforward: refresh clause matrices; update proposal and subcontract templates to reference the 52.240 clauses; review commercial-item boilerplates in light of the 52.212 updates; incorporate the new identification provisions where prescribed; and brief capture, contracts, IT/security, and compliance teams on how the deviation numbering will appear in active solicitations and awards. Treat the Part 52 page as your authoritative index during the transition and tie it to your training and audit artifacts so the new taxonomy becomes second nature across your organization. (Acquisition.gov)

Credit: FAR Council/Acquisition.gov “Revolutionary FAR Overhaul” team and agency deviation issuances cited herein. (Acquisition.gov)

Disclaimer: This post is for general information only and does not constitute legal advice. It may not reflect the most current legal or regulatory developments. Contractors should review the primary sources and consult counsel regarding specific facts and solicitations. (Acquisition.gov)