Finalized Increases to Micro-Purchase, Simplified Acquisition, and Other Thresholds

Last year, we noted that the FAR Council (DoD, GSA, and NASA) issued a proposed rule to adjust the statutory acquisition thresholds for inflation. Under 41 U.S.C. § 1908, the federal government must adjust these thresholds every five years to account for inflation. Effective October 1, 2025, the updated thresholds have gone into effect. In this post, we’ll look at the new thresholds.

The finalized rule, issued on August 27, 2025, mostly matches the proposed rule from 2024, although there are some differences.

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Breaking: EO Mandates “FAR 2.0” & Deep Dive Into Federal Procurement Efficiency

Yesterday, the new administration issued a new Executive Order (EO) officially requiring a reformation of the Federal Acquisition Regulations (FAR) and a thorough review of the federal procurement system in general. Along with related EOs, they direct the Office of Federal Public Procurement Policy (OFPP), the FAR Council, and the heads of and “senior acquisition and procurement officials” from our federal agencies to create the “FAR 2.0”–as it has aptly been deemed. And they have 180 days to do it.

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Watching the Watchman – New FAR Rule Opens Door to Further Feedback on Acquisition Process

In Fiscal Year 2022, 1,595 bid protests were filed with GAO. While that seems like a large number, it pales in comparison to the number of federal contracts the federal government awards in a given year. On average, the government awards over 11 million contracts per year. That’s a lot of acquisitions that are not subject to any feedback from outside the agency. But things might change now with the new rule that the FAR Council enacted. Today, we’ll take a look at what this entails.

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Final FAR Amendment Encourages Procuring Agencies to Engage with Industry

DoD, GSA, and NASA are issuing a final rule that amends the Federal Acquisition Regulations (FAR), effectively implementing a provision of the 2016 National Defense Authorization Act. The rule permits and encourages agency acquisition personnel to engage in responsible and constructive exchanges with the industry, provided that such exchanges remain consistent with the applicable law and refrain from promoting any unfair competitive advantages.

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Buy American Act Thresholds Are Going Up

As we’ve written about, it seems like there have been more changes to the Buy American Act and domestic preferences in the last few years than in decades before that. Recently, the FAR Council issued a final rule that spells out how the domestic content thresholds will increase over the next few years. This rule is effective October 25, 2022, so contractors need to be preparing for it now.

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FAR Council Seeks to Address Climate Change in Federal Contracting

In response to an Executive Order, the FAR Council has recently proposed to amend the FAR in an effort to ensure that major federal procurements will minimize the risk of climate change. And DoD, GSA, and NASA sought the public’s input on the issue. Let’s take a closer look.

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Is the Revision to the FAR’s Limitations on Subcontracting Finally Nearing the Finish Line?

On June 30, 2016, a major new SBA regulation took effect, overhauling the limitations on subcontracting. The SBA’s new regulation, codified at 13 C.F.R. 125.6, replaced the “old” formulas for calculating compliance–like “cost of the contract incurred for personnel,” for service contracts, with new, easier-to-use formulas based on the amount paid by the government. And, in a major boon for small businesses, the SBA’s new regulation allowed small primes to count work performed by “similarly situated entities” toward the prime’s own self-performance.

But more than five years after the SBA regulation took effect, the FAR’s provisions governing the limitations on subcontracting still resemble Marty McFly: stuck in the past. The FAR Council still has not updated the FAR to conform with the SBA’s regulations and the underlying Congressional mandate, causing considerable confusion for contractors trying to figure out which rule to follow.

Now, though, we may finally (hopefully!) be nearing the finish line for this important and long-delayed FAR change.

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