Many federal contractors have heard about the revamping of the Federal Acquisition Regulation. Variously called FAR 2.0, the Revolutionary FAR Overhaul, or simply RFO, this project has been undertaken by the Office of Federal Procurement Policy (OFPP) and the Federal Acquisition Regulatory Council (FAR Council). An executive order got the ball rolling, setting forth the mandate to create FAR 2.0 by October 12, 2025. We wrote about it in our earlier post, and described it as two parallel tracks. Track 1 involves a rewrite into “plain language” and removing non-statutory and unnecessary content. Track 2 involves the development of the non-mandatory guidelines to guide procurement officials.
The revision of the FAR sections has continued over the past few months, with the most recent proposed revisions being released on September 4, 2025. In this post, we’ll review a proposed revision that seems to make some significant changes to the language: Part 6 – Competition Requirements.
Part 6 – Competition Requirements
Part 6 of the FAR covers “procedures for full and open competition.” The updated language was issued June 27, 2025 and it has been adopted in 26 agency deviations. Per the Practitioner Album, much of the language is remaining, including the following that are based in statutory language, including:
- Advocates for Competition (41 U.S.C. § 1705)
- Full and Open Competition (41 U.S.C. § 3301 and 10 U.S.C. § 3201)
- Exclusion of Particular Source or Restriction of Solicitation to Small Business Concerns (41 U.S.C. § 3303 and 10 U.S.C. § 32030)
- Use of Noncompetitive Procedures (41 U.S.C. § 3304)
- Use of Procedures Other than Competitive Procedures (10 U.S.C. § 3204)
- Aid to Small Business (15 U.S.C. Chapter 14A)
- Major Disaster and Emergency Assistance, Use of Local Firms and Individuals (42 U.S.C. § 5150)
The updated language, however, removes certain sections, or at least appears to. The proposed revision notes that the entire Subpart 6.2 will be reserved, as shown below. That is the cross-reference to FAR subpart 19.5, dealing with small business set-asides including for the 8(a) Program.
However, the lineout only shows certain parts of subpart 6.2 are being removed, as shown below:
But the lineout still includes this provision: “To fulfill the statutory requirements relating to small business concerns, contracting officers may set aside solicitations to allow only such business concerns to compete.”
Does this mean that the small business rule of two is going to be eliminated as well as socioeconomic set-asides? At this point, it’s unclear. After all, the small business rule of two is found in FAR 19.502-2, in part stating that the “contracting officer shall set aside any acquisition over the simplified acquisition threshold for small business participation” under certain circumstances including “two responsible small business concerns” and fair market pricing.
The RFO summary states: “CO retains discretion to set aside solicitations to allow only small business concerns to compete. The prescriptions around socioeconomic concerns have been removed from FAR part 6.” The guide also notes: “The list of specific small business socioeconomic categories was removed and replaced with a reference to FAR part 19.” That proposed language in FAR 6.102-2 states: “Contracting officers may set aside acquisitions for small business concerns. This authority also includes . . . Contract actions set aside for specific small business socioeconomic categories (see part 19).”
So, based on this language it appears the small business and socioeconomic set-aside rules will be included in Part 19, but removed from Part 6. If that is true, the small business rule of two could remain in Part 19 and the changes to Part 6 are just to cut down on cross-referencing between parts. We at SmallGovCon will be watching for the release of the proposed language for FAR Part 19 and the language it includes pertaining to the small business rule of two.
Conclusion
This updated Part 6 represents some key changes for federal contractors to both the structure and substance of the FAR. We will stay tuned to the RFO revisions as they are rolled out and continue to summarize them on SmallGovCon.
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