FAR 2.0 Update: Deviations and FAR Companion Guide

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SmallGovCon readers may have read up on recent posts regarding the the Revolutionary FAR Overhaul, or simply RFO. For background, our earlier posts regarding various aspects of the RFO can be found here: Executive Order, Overview of FAR 2.0, FAR Part 6, FAR Part 19, FAR Part 12, FAR Part 15, FAR Part 33.

While the drumbeat of new FAR part revisions ended in October 2025, the RFO has not gone away. In fact, it’s kind of the opposite. The RFO revisions have now been adopted by many federal agencies as deviations, including the Department of Defense/War (DoW). Here is an update on the deviations and the FAR Companion guide.

Deviations

When agencies adopt the RFO through deviations, that means they instruct contracting officers to begin using the RFO provisions instead of the old FAR provisions. For instance, 24 agencies have deviations for Part 12 – Acquisition of Commercial Products and Commercial Services. The GSA deviation, for instance, says the “GSA acquisition workforce must follow the RFO part 12 and corresponding 52
model deviation text instead of FAR part 12 and 52 as codified at 48 CFR Chapter 1.”

DoW. The DoW issued a bevy of deviations incorporating RFO provisions in December 2025 through February 2026. The DoW has a website for its DFARS Revolutionary FAR Overhaul Class Deviations. As of this post, it lists deviations for FAR Parts ranging from Parts 1 through 52, basically all the relevant FAR parts. There are also revisions to the relevant DFARS provisions and PGI as well.

Per the announcement, “Effective on February 1, 2026, these class deviations retain DoW-specific statutory direction and direction determined necessary for sound procurement within the new, streamlined RFO structure.” And, “non-statutory policies and procedures are removed, revised, or relocated to the procedures, guidance and information (PGI).” The formal release on the federal register is slated for 2026: “Phase 2 of the RFO will continue throughout 2026 with our issuance of proposed FAR and DFARS rules for public notice and comment.”

It appears that some of the FAR parts deviations are not completed yet. For instance, FAR Part 15, dealing with Contracting By Negotiation and including rules on debriefings, has no DoW deviation.

FAR Part 19, dealing with small business rules, does have a deviation. That includes the following 7 documents, which make up the deviation:

Reading through these 7 documents, I located no changes of note (although there are certainly changes here and there). The take-home message is that, at least for FAR Part 19, the DoD is mainly incorporating the update RFO part 19, but not adding too many big changes.

FAR Companion

The FAR Companion is a document designed to “to help acquisition officials exercise their discretion. The FAR Companion provides context, additional information, and practical advice for planning, awarding, managing, and closing out contracts, consistent with the FAR’s core buying principles.”

It includes the following goals:

  • consolidating practitioner insights in one place from a variety of helpful sources (such as innovation and vendor engagement strategies, handbooks, training materials, and management memoranda) saving buyers time in finding and leveraging best practices;
  • preserving a number of policies and “how to” procedures formerly mandated in the pre-streamlined FAR that continue to reflect good stewardship but are more appropriately applied with discretion as part of problem-solving and are not a “one-size-fits-all” mandate;
  • building the confidence of the acquisition workforce to take managed risks, by providing advice – not direction – and avoiding compliance requirements that create a fear of protests; and
  • creating an agile and efficient governmentwide resource to highlight and evolve proven acquisition practices and reduce the amount of guidance needed from agencies.

This can be a handy guide for contractors. It has an overview and summary of changes to every part of the FAR. But it also reveals some of the thinking behind the changes and the strategies that contracting officers are encouraged to follow.

For instance, Part 8 guidance encourages

Strategic management of award notices, brief explanations, and protest windows”. To that end: “To avoid unnecessarily extending the protest window, the acquisition team led by the contracting officer should prepare to quickly provide a brief explanation when requested after making award decisions and notifying unsuccessful offerors. . . . Additionally, consider preemptively including the “brief explanation” in the award notice. This approach may start the GAO 10-day bid protest clock, marking the point at which “the basis of protest is known or should have been known.”

This advice is repeated in other sections, such as Part 12. Another section states: “When debriefings are requested, the acquisition team led by the contracting officer might consider providing technical evaluation documentation relevant to the requesting vendor. Providing this transparency may reduce the likelihood of protests due to lack of information.”

Clearly, agencies are being reminded of ways to reduce protest risk. Contractors (and their counsel) would do well to read up on these same strategies, in order to know potential approaches that an agency may use.

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