You say you want a revolution

On April 15, the Trump Administration issued Executive Order (EO) 14275 to “restore common sense to federal procurement.” As the EO explains, the Federal Government “is the largest buyer of goods and services in the world [but] conducting business with the Federal Government is often prohibitively inefficient and costly.”

The EO proposed a series of goals to be achieved by the overhaul:

• Faster acquisitions

• Greater competition

• Reduced bureaucracy

• Plain language regulations

• Elimination of non-statutory rules

  
  

The Trump Administration’s proposal seeks to reform the 1984 Federal Acquisition Regulation (FAR), which has been the principal framework governing policy and procedural guidance for all participants within the federal procurement ecosystem. Regardless of industry sector, FAR provides statutory mandates and regulatory instructions to federal entities (both civilian and Department of Defense) and to contractors supporting acquisition. Not surprisingly, to meet the needs of competing interests the FAR became more complex - tax code level complex.

Unlike the focused fixes promised in the 1994 Federal Acquisition Streamlining Act (FASA) and the 1995 Federal Acquisition Reform Act (FARA), this EO calls for a comprehensive rewrite of the FAR. The goal was to eliminate all non-statutory guidance and create agency-level Buying Guides to address the non-statutory regulations. The official title of the process is the Revolutionary FAR Overhaul (RFO).

There are four key provisions of the EO that shape implementation of the RFO.

• Regulatory Sunset: Non-statutory FAR provisions will expire after 4 years

  unless renewed.

• Agency Alignment: Each agency must designate a senior procurement official

  to coordinate reforms.

• Deviation Guidance: Interim rules and deviations will be issued while formal

  rulemaking proceeds.

• Ten-for-One Rule: For every new regulation, ten existing ones must be eliminated (per EO 14192).

Publication of the new FAR will be a two-phase process. Phase one will provide “lined

out” parts of the FAR. The purpose of the "lined out" documents in the new FAR is to represent material that has been removed from the FAR but may still be included in the agency Buying Guides.

In Phase two, in accordance with 41 U.S.C. § 1707, the FAR Council will initiate formal rulemaking which will follow the traditional notice and comment requirements, to include public input. When the rules are final, they will be published in the Federal Register. The current schedule has the FAR completed October 13, 2025; that date is likely notional.

So, what does this mean to the average contractor who wants to do business with the federal government? The initial reaction will be a cautious (perhaps conservative) risk assessment of the new federal acquisition space specifically, evaluating how it impacts themselves. I see the impacts in these broad areas:

Reduced Barriers to Entry

• Simplified rules mean fewer compliance hurdles.

• Small and mid-sized businesses may find it easier to compete for federal

  contracts.

• Commercial vendors with limited government experience could enter the market

  more easily.

Reduced Regulatory Burden

• Nearly 45% of FAR clauses—especially those not required by statute—may be

  eliminated.

• Less proposal prep and compliance documentation efforts.

• Agency-specific supplements (like DFARS or GSAM) are also being streamlined.

Shifts in Evaluation Criteria

• Performance, innovation, and best value may be prioritized over lowest price.

• Strong capability statements and past performance will become more critical.

Increased Risk and Uncertainty

• Interim guidance and deviations may create confusion in the short term.

• Contracting officer adaptation, therefore inconsistent application of new rules.

• Socioeconomic programs may be removed if not backed by statute.

The challenge with assessing impact of the overhaul prior to all FAR parts being released is the “where did it go” conundrum. For example, the Rule of Two has been a longstanding criterion for setting aside work when market research reveals that there are two or more responsible small businesses that could perform the work.

However, though clear in the FAR, it is not a policy based on statute. (The VA’s version is codified in 38 U.S.C. § 8127.) We will not know the fate of the rule until FAR Part 19 is released though there is legislation (H.R. 2804) that would codify the rule across all agencies. And so we begin the process of fixing something that we actually don’t yet know is broken.

In theory, all the foundational concepts of federal acquisition that are statute driven are still in place. But they may not be where you found them last year and the contextual guidance associated with the legal principles may be in yet to be developed guides. Like all revolutions, this may be messy for a while. An excellent source of official vendor guidance is provided at Acquisition.gov/FAQs.

Jimm Rich

Senior Advisor

A member of the Dawson team since 2016, Jimm served as Chief of Contracting for the U.S. Army Corps of Engineers’ Baltimore, Kansas City and Galveston districts.

The views expressed here are those of the author and do not necessarily reflect the

views of Dawson & Associates.