Revolutionary FAR Overhaul (RFO): Key Highlights and Updates for MAS Contractors
GSA Schedule | New Administration | 6 Min Read
The Federal Acquisition Regulation (FAR) has been the foundation of federal contracting for over four decades, and the government is looking to completely overhaul it for the first time since its creation. More commonly referred to as the Revolutionary FAR Overhaul (RFO), the Trump Administration plans to take a magnifying glass to FAR regulations and return it to its “statutory roots”. According to an Executive Order (EO) released in April 2025, the new administration plans to modify the FAR so it’s written in plain language and mostly scrubbed of non-statutory rules. This is not the first time a presidential administration has set out to review the FAR in its entirety, but GSA is sure that this time is different with the added support of technology and Artificial Intelligence (AI).
Since the GSA Multiple Award Schedule (MAS) Program is governed by FAR 8.4 and the General Services Administration Manual/Regulation (GSAM/GSAR) supplement, this will impact you as a contractor. In this blog, we’ll cover key highlights and recent updates you need to be paying attention to when it comes to the RFO.
What is the Revolutionary FAR Overhaul (RFO)?
Executive Order 14275 directs a rewrite of the FAR so it only includes statutory/essential requirements, focuses on plain-written language, and puts a larger emphasis on commercial buying. The EO tasks agencies with streamlining and cutting non-statutory mandates to their supplements.
The RFO was further set in motion by the Office of Management and Budget (OMB) Implementation in May that laid out a two-phase plan and clarified that the Office of Federal Procurement Policy (OFPP) is going to lead the effort. The two phases include:
- Phase I includes issuing revised FAR parts on a rolling basis that would go into effect immediately. These revisions would remove most non-statutory language and ensure the FAR is written in plain language.
- Phase II is going through the formal notice and comment rule making process allowing industry to commend and give feedback. We expect there to be additional changes after this phase.
Proposed FAR Revisions
The FAR Council has been issuing revised FAR Parts and their agency deviations on a rolling basis on acquisition.gov. It’s important to note that GSA has posted deviations for several of these changes. Here’s a summary of the most notable proposed parts so far (as of August 8, 2025, which is when the last revisions and deviations were posted).
FAR Part I: Federal Acquisition Regulation System (Issued May 2, 2025)
The FAR Part I revision focuses on simplifying the FAR. The key highlight in this revision is adding a regulatory sunset provision, meaning non-statutory FAR sections will expire after 4 years unless they are renewed.
FAR Part 5: Publicizing Contract Actions (Issued Aug 8, 2025)
FAR Part 5 speaks to publicizing contract actions, so the revisions in this part are all about streamlining the process and making it more transparent. An example action in this revision is mandatory Government Point of Entry (GPE) posting. Unless an exemption applies, Contracting Officers are now required to post solicitations on the GPE.
FAR Part 6: Competition Requirements (Issued Jun 27, 2025)
In FAR Part 6, the revision consolidates a large section of the language removing and rewriting entire subparts. The consolidation includes small business set-asides. Once separate sections, all small business set-asides have been consolidated into two sections:
- FAR 6.102-2: covers all small business set-asides, including Small Business Innovation Research and Small Business Technology Transfer (SBIR/STTR) programs and socioeconomic categories and refers to Part 19 for the details.
- FAR 6.102-3: mentions set-asides for local firms during major disasters or emergencies and references the two categories of set-asides from 6.102-2 (SBIR/STTR and “specific small business socioeconomic categories”).
Additionally, the “Other Than Full and Open Competition” Authorities have been renumbered and simplified, and the Justification and Approval (J&A) Requirements have also been streamlined.
FAR Part 10: Market Research (Issued May 22, 2025)
FAR Part 10 was cut down significantly to simplify the market research process. Notable mentions in this revision include requiring agencies to consider commercial products and services first as well as existing governmentwide contracts before soliciting additional bids. This provision could be very useful for GSA Multiple Award Schedule (MAS) contractors if agencies start utilizing the vehicle more often.
FAR Part 11: Describing Agency Needs (Issued Jun 18, 2025)
FAR Part 11 has been streamlined to keep only statutory requirements, emphasizing commercial standards, promoting competition, and reducing restrictive language. Non-statutory guidance, such as detailed instructions for writing statements of work, delivery schedules, and brand-name requirements, has been removed.
FAR Part 18: Emergency Acquisitions (Issued Jun 12, 2025)
In Part 18, the FAR Council focused on making the language clearer and faster for agencies to buy what they need in emergency situations. The updated language keeps only the statutory rules as expected, and it also reinforces the use of local area set-asides for disaster responses like the Stafford Act. As a reminder, GSA Schedule contractors can sell to state and local entities through Disaster Purchasing, which is enacted through the Stafford Act.
Part 26: Other Socioeconomic Programs (Issued Aug 8, 2025)
This revision was just released last week and consolidates several programs, including the Indian Incentive Program, local firm preferences in disaster areas, and initiatives for Historically Black Colleges and Universities (HBCUs) and minority institutions.
FAR Part 43: Contract Modifications (Issued Jun 12, 2025)
FAR Part 43 was simplified under the RFO to make it clearer when and how changes to a contract should be made. The revised version keeps the statutory requirements but uses plainer language to explain things like when to issue a modification, how to handle definitization, and when to use a Standard Form (SF)- 30.
Impacts of the FAR Overhaul on MAS Contractors
What does all this mean for GSA MAS contractors? The RFO’s streamlined FAR parts will inevitably reshape how agencies buy through the MAS program. The hope is by cutting non-statutory requirements and shifting guidance to companion documents, Contracting Officers can move faster and lean more heavily on commercial practices, making MAS an even more popular vehicle. GSA has several deviations to these parts already, meaning GSA is thinking about how the changes will impact the MAS Program and how they can adopt them into their acquisition rules.
However, as the parts are rolled out there are still some concerns on how taking out specific language can impact certain acquisitions, especially as it relates to small business set-asides. We’ll learn more as industry is able to comment and the FAR Council revises further based on their feedback.
What’s Next for MAS Contractors?
The Revolutionary Far Overhaul (RFO), while a major undertaking, is only a piece of the plans the Trump Administration has for federal contracting. It’s important you are adapting to the current changes we are seeing in the MAS Program and preparing for future actions that may impact your contract. To stay on top of contracting news and insights, subscribe to our blog and monthly newsletter. If you need help managing your contract throughout all these updates, or you have questions about how the changes are affecting your company, we are here to help.